environmental and social safeguard assessment
TRANSCRIPT
LOI MOFAGFSDPPPACSLOI201001
ENVIRONMENTAL AND SOCIAL SAFEGUARD ASSESSMENT
ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK
MARCH 2011
WEST AFRICA REGIONAL FISHERIES PROGRAM IN GHANA (WARFPG)
Submitted to
The Secretary to the Fisheries Commission and Director of Fisheries The Ministry of Food and Agriculture Accra Ghana
By
United Kingdom
Church Barn Church Lane Tickenham Bristol BS21 6SD
Tel +44 (0) 1275 811345 Fax +44 (0) 1275 811333 E-mail infotheIDLgroupcom wwwtheIDLgroupcom
Ghana Office
House No F8721 Fifth Close Ring way Estates Accra-Ghana
Tel 0302 912909 Fax 0302 242425
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PROJECT TEAM
Terry Green - Project Director
Peter Jon Nelson ndash Team Leader - Environmental and Social Assessment Consultant
Victoria Wiafe - Project Manager ndash IDF Group Ghana
Dr Andrew Baio ndash International Fisheries Consultant ndash Sierra Leone
Dr Edward Kofi Abban National Fisheries Consultant ndash Ghana CSIR
Audrey Allotey Research Assistant
iii
ACRONYMS
AF Affected Fisheries
CMA Co-management Associations
EIA Environmental Impact Assessment
ESMF Environmental and Social Management Framework
ESIA Environmental and Social Impact Assessment
FC Fisheries Commission
MCF Monitoring Control and Surveillance
MOFA Ministry of Food and Agriculture
MPA Marine Protected Area
NPF National Process Framework
NGO Non-governmental organisation
PAP Person affected by the project
PC Participating Communities
RAP Resettlement Action Plan
RPF Resettlement Policy Framework
TURF Territorial User Rights to Fisheries
WARFP West Africa Regional Fisheries Programme
WB World Bank
ZMGFR Zoning Map of Ghanarsquos Fishery Resources
v
TABLE OF CONTENTS EXECUTIVE SUMMARY 1 PART A ndash ENVIRONMENTAL AND SOCIAL SAFEGUARDS ASSESSMENT AND DRAFT ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK 1 INTRODUCTION 7
2 PLAN AND PROGRAMME DESCRIPTION 11
Part 1 The Draft Fisheries and Aquaculture Sector Development Plan 11 Part 2 The World Bankrsquo Contribution to the Ghana Fisheries Plan 11
3 BASELINE CONDITIONS 15 31 Profile of the Fisheries Industry 15 32 Environmental Conditions 20
4 POLICY AND LEGAL FRAMEWORK FOR ENVIRONMENTAL ISSUES 25 41 World Bank and Other Donorsrsquo Safeguard Policies 25 42 Governance Framework in Ghana 28
5 WORLD BANK SAFEGUARD ISSUES 37
6 ENVIRONMENTAL AND SOCIAL ASSESSMENT OF DRAFT FISHERIES AND AQUACULTURE SECTOR DEVELOPMENT PLAN (FASDP) 45 61 Positive Environmental and Social Impacts 62 Adverse Environmental and Social Impacts 7 ASSESSMENT OF POLICY OPTIONS 53 8 DRAFT ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK 57 PART B NATIONAL PROCESS FRAMEWORK AND DRAFT NATIONAL RESETTLEMENT POLICY 9 DRAFT NATIONAL PROCESS FRAMEWORK 67 10 DRAFT RESETTLEMENT POLICY FRAMEWORK 71 BIBLIOGRAPHY ANNEXES 1 Annex 1 to the Terms of Reference 2 Environmental and Social Evaluation Matrix
1
EXECUTIVE SUMMARY
This report draws together the contents of two separate documents which examine a number of interrelated issues concerned with environmental and social safeguards for the development of the fisheries sector in Ghana
The first document (Part A) contains the Environmental and Social Assessment (ESA) of the Ghana Fisheries and Aquaculture Sector Development Plan (FASDP) together with a draft of the Environmental and Social Management Framework (ESMF) that will be adopted by the Government of Ghana This document is reproduced in Chapters 1-8 of the Composite Report
The second document (Part B) contains the outline structure of Ghanarsquos National Process Framework (NPF) for implementing the design and implementation of local fishery co-managementmaintaining sustainability of local livelihoods and local monitoring of fisheries efforts together with an outline Resettlement Policy Framework (RPF) These elements are covered in Chapters 9-10 of the Composite Report
This Composite Report and its individual components have been prepared on behalf of the Government of Ghana and the World Bank Following review by both parties it will be adopted as part of the framework leading to promotion of the Ghana Fisheries and Aquaculture Sector Development Plan
Chapter 1 of the Report describes the need for environmental and social safeguards in the fisheries sector It notes that the overall aim of FASDP is to improve fish stocks and increase the sustainability of fishing activity which will have long term environmental and social benefits for the Country
Chapter 2 summarises the basic aims of the Ghana Fisheries and Aquaculture Sector Development Plan and proposals for financial and technical aid which are being developed by the World Bank A decision on funding support will be taken by the World Bank in 2011 The World Bank is proposing to support FASDP under four key components These are Good Governance and Sustainable management of the fisheries reduction of illegal fishing increasing the contribution of the marine fish resources to the local economies and assisting with coordination monitoring evaluation and programme management
Chapter 3 provides a baseline description of the current nature and importance of Ghanarsquos marine and inland fisheries which provide 65 of the countries protein requirements and sustain the livelihoods of almost 10 of the Ghanarsquos population Unfortunately however fishing is approaching a crisis In recent years the annual volume of catch has fallen (from in excess of 500000 to under 400000 tonnes) but at the same time fishing effort has increased If it were not for government subsidy the economic returns could no longer be justified since it costs more to catch and land fish than they are actually worth in the market place Fishing activity (principally trawling) is causing substantial damage to the marine environment while illegal methods in the canoe sector including dynamiting and use of chemicals threaten fish stocks and human health
Chapter 4 examines the governance legislative and policy framework under which reforms in the fisheries sector will take place The chapter identifies five World Bank safeguard policies that are potentially triggered by FASDP These are OP 401 Environmental Assessment OP404 Natural Habitats OP 409 Pest Management and OP 411 Physical and Cultural Resources and OP 412 Involuntary Resettlement In most cases the range of projects proposed under FASDP would have minimal impacts under these safeguards but there is nevertheless a need to ensure that adequate
2
protection and mitigation is provided through implementation of an Environmental and Social Management Plan
Chapter 5 considers the four funding components under which the World Bank is proposing to support the Ghana Fisheries and Aquaculture Sector Development Plan These cover
1 Good governance and sustainable management of the fisheries 2 Reduction of illegal fishing 3 Increasing the contribution of the marine fish resources to the local economy and 4 Coordination Monitoring and Evaluation and Program Management The potential for investment to give rise to adverse effects on the environment andor social conditions is reviewed It is concluded that that there are unlikely to be any significant adverse environmental or social effects as a result of the planned investments The only possible exception relates to the effectiveness of measures that are put in place under Sub-Component 12 to support pilot stakeholder-based fishery initiatives The outcome of the overall program will depend heavily on the success of these pilots For this reason it is essential that planning of the pilot initiatives is linked closely with measures for supporting alternative livelihoods and strengthening processing and marketing initiatives under Sub-Components 13 and 14
Chapter 6 provides an analysis of the environmental and social issues raised by the wider fisheries and aquaculture programme and as such it constitutes the Environmental and Social Assessment (ESA) A matrix is used to identify potential interactions between elements of marine and inland fishery capture operations and the natural environment together with possible socio-economic effects A similar matrix is also used to examine the potential for aquaculture development The overall effects of the planned interventions are positive in terms of both environmental and socio-economic gains but there are potentially some adverse social and economic consequences for a limited number of individuals whose livelihoods will be affected by restrictions on access to fishing or from changes in economic conditions affecting the purchase processing and marketing of fish Mitigation measures are considered subsequently in Chapter 8
Chapter 7 briefly considers the possible consequences of taking no action to deal with the declining stocks and profitability of fishing (the do-nothing option A) This is a standard part of the methodology for conducting an Environmental and Social Assessment The conclusions are compared with the alternatives of taking limited action (a lsquoweakrsquo option B) or of implementing the full set of plans and proposals (the lsquooptimumrsquo option C) The comparison includes the conclusion that the fisheries industry is often studied and dealt with in isolation from other parts of the economy However in order for the planned reforms to have maximum beneficial impact a new approach is required to integrated coastal development in which a range of ministries and agencies should be involved
Chapter 8 sets out a draft Environmental and Social Management Framework (ESMF) This picks up areas of risk identified in the ESA Report and proposes remedial action The ESMF notes that the principal goals of government policy are to
bull Improve management of fisheries the conservation of aquatic resources and protection of the natural environment
bull Promote value addition in the fisheries sector and the improvement of livelihoods in fisheries communities
bull Encourage sustainable development of aquaculture
3
bull Improve the services provided to the fisheries sector by the Fisheries Commission and supporting institutions
The Draft ESMF sets out eight specific interlinked actions namely
1) Preparation of local management plans and close surveillance of all new fishing enterprises in deep waters
2) Preparation of environmental protection clauses to be included in all contracts and agreements for physical development work
3) Regular inspection by environmental protection officers of construction work at harbours and landing sites
4) Establishment of community management plans to provide support to those groups and individuals who are adversely affected by any of the measures listed above
5) Creation of community liaison groups to actively support community development alternative livelihoods and conversion to new areas of economic activity for those Fisher families or individual fishers who are adversely impacted
6) Introduction of skills training centres and business advice for small and medium enterprise development
7) Establishment of a coastal development approach drawing on the resources of the ministry of local government agriculture and tourism (others to be added) to coordinate integrated projects and initiatives for economic development linked with the existing coastal zone management plans
8) Creation of a liaison group between the government of Ghana and its international development partners to ensure that investment in the fisheries sector is targeted in the most effective way to deliver plan objectives and avoid duplication of effort
Chapter 9 provides a draft National Process Framework (NPF)) to implement the recommended process framework laid down by the West Africa Regional Fisheries Program (WARFP) which Ghana will become part of This framework explains how eligibility criteria will be employed to determine which settlements qualify as participating communities and what the responsibilities of these communities will be in terms of setting up Co-management Committees (CMCs) and selecting classes of Project Affected People (PAPs) who will be eligible for assistance under national guidelines to be prepared by the Fisheries Commission The ESMP also outlines proposals for income restoration measures in accordance with World Bank guidance as interpreted through the West Africa Regional Fisheries process framework that where open access to fishery resources is restricted for the common good any adversely affected individuals should not be penalized but should receive assistance to restore their livelihoods at least to the extent that they are impacted by the project activities and preferably to an improved state1
1 Extract from Executive Summary Process Framework West African Regionl Fisheries Program (P106063) Cape Verde Liberia Sierra Leone Senegal Commission sous Regionale des Peche Dakar Senegal
Measures are also outlined for conflicts or grievance resolution administrative and legal procedures and monitoring arrangements
ldquoSection V Livelihood Restoration Measures World Bank policy requires that livelihoods be restored at least to the extent that they are impacted directly by project activities and preferably inproved This policy prescription is based on the principle that people who give up most for the public good ndash the PAPs- should not be penalised and impoverished as a result of their loss for the greater good The aim thereopfre is to improve the public good (in this instance marine resources) while also ensuring that those who lose access to resources and income because of restrictions on marine resources are assisted effectively to restore that part of their income that is affected through alternative livelihood measuresrdquo
4
Chapter 10 looks in more detail at specific safeguards relating to possible involuntary relocation of people as a result of the long term fisheries programme It constitutes the Resettlement Policy Framework (RPF) which while not a formal legal requirement of the World Bankrsquos lending policy is nevertheless recommended as good practice
5
PART A ENVIRONMENTAL AND SOCIAL SAFEGUARDS ASSESSMENT
The Environmental and Social Safeguard Assessment comprises bull Three background chapters (1-3) bull Two chapters which deal with assessment of the potential effects of the World Bankrsquos financial
and technical support for the Ghana Fisheries Programme over the initial five years (Chapter 4) and the longer term effects of the overall Fisheries Programme which is expected to run for 10-15 years (Chapter 5)
bull Analysis of the consequences of taking no action (the do-nothing option) in Chapter 7 and bull A draft Environmental and Social Management Framework (Chapter 8)
7
CHAPTER 1 INTRODUCTION
11 INTRODUCTION The government of Ghana is embarking on a Fisheries and Aquaculture Sector Development Plan (FASDP) for restructuring its coastal and inland fisheries The aim is to reverse the current trend whereby fish stocks are increasingly diminishing and the current rate of fishing is unsustainable resulting in less productive fisheries increased costs with declining profitability and the risk of exacerbating nutritional deficiencies and poverty within fishing communities To date the government has enacted legislation (Fisheries Act 2002) prepared policies (2008 updated in 2010) and published regulations (August 2010) but the Ministry of Food and Agriculture and the Fisheries Commission lack the capacity and financial resources to implement all of these initiatives The World Bank is therefore considering a supporting programme of technical assistance and finance which will assist with governance reforms the introduction of licensing for all vessels a reduction in the size of the industrial and semi-industrial fishing fleets and the progressive transfer of fishing activity to the canoe sector International support for Ghanas fishing industry is being coordinated under the West Africa Regional Fisheries Programme (WARFP) This initiative began with four countries Cape Verde Liberia Sierra Leone and Senegal It is now being extended to the following countries Ghana Guinea Guinea Bissau and Gambia A process framework has been developed by the Commission sous Regionale des Peche (Based in Dakar Senegal) to assist member countries of WARFP to prepare their own national process frameworks together with accompanying environmental and social safeguards assessment an environmental management plan and resettlement policy This report has been designed to provide the outline structure and contents for these documents on behalf of the Government of Ghana Another important function of the report is to review the application of the World Banks own Environmental and Social Safeguard policy to the planned investment Both the governments development plan (FASDP) and preparation of the World Banks financial assistance package are at an early stage Consequently this report covers (and can only cover) the broad principles and sets out initial conclusions It will be necessary for further reviews to be undertaken when the Government of Ghanarsquos programme has been developed in more detail Objectives of the Environmental and Social Assessment (ESA) The overall aims of planned interventions in the fisheries industry of Ghana are to improve fish stocks and increase the sustainability of fishing activity which will have long-term environmental and social benefits for the country However the process of introducing change is likely to have some short-term adverse effects on individuals and particularly those who are vulnerable or disadvantaged within poorer fishing communities unless appropriate mitigation measures are taken The purpose of the environmental and social assessment set out in chapter 6 is to identify potential environmental and social impacts both individually and cumulatively and to assess their relative magnitude duration reversibility and importance Based on these findings the draft management framework (see chapter 8) sets out proposals for avoiding or mitigating unacceptable change The process of reforming the fisheries sector will take a number of years and the existing FASDP covers only the first five years With the exception of proposals to scale down the size of the industrial and semi-industrial fishing fleets it is unlikely that major changes will take effect in terms of fishing activity during this five-year period Consequently from the standpoint of the World Banks investment there are likely to be relatively few issues in terms of potential conflict with safeguarding policies Later
8
however significant change is within the fishing industry and particularly onshore processing and marketing of fish products An important element in this report has therefore been the need to define the point at which the banksrsquo responsibilities are seen to terminate and all liabilities are transferred to other supporting donors and the government of Ghana In the short term a reduction in the industrial fleet may lead to the loss of 1000 to 3000 jobs for crew members although in practice most of this work is only part time and many of the vessels that are due to be withdrawn are no longer seaworthy In the longer term it is intended to encourage more selective fishing by limiting open and unfettered access to fish stocks eliminating illegal and damaging processes including dynamiting uncontrolled light fishing and the use of small size monofilament nets and introducing seasonal restrictions to protect breeding cycles The intention is that these measures will be managed jointly by the government and communities through co-management systems At the same time major efforts will be made to reduce the level of post-harvest losses and to increase the value of fish products The expectation is that the number of industrial semi-industrial vessels and canoes will be stabilised at a fixed lower level within five years Once this point is reached and no further licences are granted individual licences will acquire higher values especially as fish stocks recover and the size and value of fish catches starts to increase Subsequently licenses are likely to be sold and traded as less efficient owners drop out of the market and sell on to stronger individuals and companies In terms of onshore activities fish landing processing and marketing will become more efficient and losses will be reduced through use of better smokers freezing and drying equipment Previous studies in West Africa and elsewhere (Bennett et al 2001) have shown that the transition away from open access to a more regulated system of access management can give rise to social risks Specifically older men are likely to be displaced when they are no longer fit enough to withstand the rigours of fishing while a rising number of young men may find it harder to enter a career in fishing Women who currently manage or assist with all areas of buying processing and marketing using traditional clay ovens may also experience competition as new companies and enterprises are established to take advantage of higher profitability in the fishing sector perhaps using better equipment newer technologies and different logistics arrangements or their own transportation Methodology This study has followed the methodology developed within the process framework for the West Africa regional fisheries programme (WARFP) Figure 1 sets out both sequence and timescale for the work
The range of jobs at risk is based on assumptions about the number of vessels and average crew size and cannot be determined with any degree of accuracy until the necessary surveys are undertaken
9
The report is based on three major areas of activity 1 documentary analysis and utilisation of the studies already carried out by the fisheries commission 2 meetings with institutional stakeholders principally affected by the project and 3 Consultations and visits to some of the key fishing villages and communities The planned presentation of findings to Stakeholders has been postponed at the Clientrsquos request due to other pressing commitments in the agriculture and fisheries sectors This presentation will however need to be subsequently undertaken by the Ministry and the Fisheries Commission
11
CHAPTER 2 PLAN AND PROGRAMME DESCRIPTION
INTRODUCTION This chapter is divided into two parts Part 1 sets out the progress which the government Ghana is making in giving effect to the legislation policy and regulations Part 2 describes the proposed programme of assistance being offered by the World Bank with the specific aims of strengthening governance and enforcement systems (Components 1 and 2) and in promoting value addition and reduction of post-harvest losses
PART 1- THE DRAFT FISHERIES AND AQUACULTURE SECTOR DEVELOPMENT PLAN (FASDP) This plan (FASDP) covers the period 2010-2015 It recognises the importance of Ghanarsquos fisheries which generate in the order of US$ 1 billion a year contribute 45 to GDP and indirectly support the livelihoods of 22 million people However through over-fishing and lack of investment in management and value addition the average income per canoe has dropped by up to 40 over the last ten years to the point where it costs as much to fish as the catch is worth By comparison well managed fisheries in other parts of the world are capable of generating economic returns of 30-60 on investment (equivalent to a potential income of US$ 300 million a year for Ghanarsquos fisheries) The Draft FASDP acknowledges that the fishing sector is expected to make a substantial contribution towards doubling the size of the Ghanaian economy by 2015 (GPRS II) as part of the Republic of Ghana Fisheries and Aquaculture Policy Seven targets are set in the draft FASDP 1 Maintaining capture fisheries production at current levels 2amp3 Increasing revenue and profitability in capture fisheries by at least US$ 50 million a year after
five years 4 Increasing aquaculture production to 35000 tonnes a year after five years 5 Retaining Ghana as a landing and processing hub for the West Africa tuna industry 6 Developing fisheries management to allow effective control of all commercial fishing effort in
Ghanaian waters and 7 Ensuring fisheries management costs are sustainable and that the fisheries sector overall make a
fiscal contribution to Government revenues There is an underlying presumption that the canoe sector will remain at the heart of Ghanarsquos fishing industry but the plan is not prescriptive and leaves open the ways of achieving the overall goals At the same time there is an underlying assumption that the long term sustainability of Ghanarsquos fisheries will depend upon discouraging further entry by new operators
PART 2 THE WORLD BANKrsquos CONTRIBUTION TO GHANA FISHERIESPLAN (FASDP)
The essential aim of the World Bankrsquos contribution to FASDP is to provide investment which will build the necessary policy and capacity for effective fisheries management designed to reduce fishing effort while maintaining approximately the same catch levels and to address the impacts of change for fishers
12
and the communities in which they live Based on the currently available draft Project Appraisal Document (PAD) each of the components is now described in turn Component 1 - Good governance and sustainable management of the fisheries This component on good governance comprises four subcomponents which are broken down in turn into a number of separate activities Sub-component 11 developing the capacity rules procedures and practices for good governance of the fisheries Activity 111 reviewing the Fisheries Act and developing regulations to support the Sector Policy and the Fisheries and Aquaculture Sector Development Plan Activity 112 Developing an operational policy to enable implementation of the aquaculture and fisheries sector development plan Activity 11 3 strengthening fisheries management systems and capability (fisheries management plan development aquaculture implementation technical support and training) Activity 114 strengthening fisheries Information Systems (catch recording and monitoring systems statistical analysis and training)
Sub-component 12 introducing fishing rights
Activity 121 developing pilot stakeholder-based fisheries management initiatives around defined fisheries units (ie local management initiatives tighter defining fisheries resources in up to 6 selected Fisher communities) Activity 122 introducing and administering a licensing regime
Subcomponent 13 Adjusting fishing effort and capacity to more sustainable levels marine resource conservation and supporting alternative livelihood opportunities when needed Activity 131 vessel decommissioning Activity 132 compensation packages for crew of decommissioned industrialsemi-industrial vessels Activity 133 alternative livelihood development to incentivise voluntary capacity reduction in the canoe sector Activity 134 marine resources management and conservation
Subcomponent 14 social marketing communication and transparency Activity 141 communications stakeholder consultations and awareness raising programmes to support fishery development Component 2 reduction of illegal fishing Under the West Africa regional fisheries programme subcomponent 21 allows for enabling environment for reduction of illegal fishing These provisions already exist within Ghana and this subcomponent is therefore omitted Subcomponent 22 monitoring control and surveillance (MCS) systems Activity 221 developing compliant systems and capability
13
Component 3 increasing the contribution of the marine fish resources to the local economies Subcomponent 31 product diversificationvalue chain development (freshfrozen producttrade facilitation) Activity 311 landing site development Activity 312 Port development Subcomponent 32 fish product trade infrastructure information and systems - regional minimum integrated trade expansion platform (MITEP) Activity 321 export certification centre development Activity 322 fish processing technology improvements Activity 323 national fisheries advisory group Subcomponent 33 marine and inland aquaculture development Activity 331 space developing aquaculture policy and legal framework Activity 332 improving genetic policy of tilapia fingerlings and breedstock Activity 333 catalysing aquaculture development Component 4 Coordination monitoring and evaluation and program management Subcomponent 41 national implementation subcomponent 42 regional coordination Each of the components sub-components and activities are described in more detail in Chapter 5 which assesses the nature of environmental and social safeguards issues in terms of the World Bankrsquos planned investment
15
CHAPTER 3 BASELINE CONDITIONS
INTRODUCTION This chapter discusses the existing fishery resources of Ghana and describes recent environmental and social trends It identifies some of the pressures that led to the reduction in value of fishing activity and indicates the threats that could be posed if no action is taken in accordance with the planned fisheries and aquaculture program to deal with them FISHERY RESOURCES The continental and coastal waters of Ghana are potentially very rich due to a combination of warm waters and nutrients carried in ocean currents which up-well seasonally on the continental shelf The tonnage of fish caught in marine waters peaked in the mid-1990s around 500000 tonnes and currently averages around 400000 t(See Figure 1) Figure 1 Wild Capture Production in Ghana 1950-2005
2
Table31 Top 10 Species Exported (by value)
1 Canned tuna ($72000000) 2 Fresh tuna ($7200000) 3 Tilapia (no figure available) 4 Miscellaneous dried fish ($1000000) 5 Salmonids frozen ($900000) 6 Marine fish frozen ($600000) 7 Cuttlefish and squid ($600000) 8 Shrimps and prawns ($90000) 9 Sardines ($80000) 10 Crustaceans frozen ($50000) Source FAO Fishstat
The principal catch from deep waters is tuna Industrial vessels registered in Ghana target these species in international waters but also illegally in coastal waters Herring sardine and anchovies are fished in coastal waters by semi-industrial vessels and canoes Table 31 shows the top 10 species of fish exported from Ghana in 2005 PROFILE OF THE FISHING INDUSTRY Fishing is of vital importance in Ghana not only in terms of its contribution to gross domestic product (45 per annum) but because fish provides 65 of the countrys protein In recent years (between 2003-2008) and more specifically in 2004 the countryrsquos annual fish requirement has been estimated to be 882000 tonnes of which the country produces just about half (Tetteh 2007) Of the total population of 22 million people it has been estimated that between 15 and 22 million people are employed or gain their livelihoods from fishing (8-10) Of these there are 210000 men who are directly employed as
2 This figure is the Fisheries Departmentrsquos estimate for 2008
16
fishers The total export of seafood was valued US$824 billion in 2005 Ghanas fishing industry can be divided into three sections marine capture inland capture and aquaculture It can be further analysed by scale of operations distinguishing between industrial semi-industrial and artisanal sectors Marine fisheries Industrial sector Commercial fishing for tuna began in 1962 In the early 1980s Ghana sought to develop an industrial fishing fleet and there are currently 90 industrial trawlers and other vessels which are located in Tema and Takoradi Sekondi The port of Tema was expanded from 1962 to create four main areas the Inner Harbour Outer Harbour Canoe Basin and Commercial Area In 1999 fish landing facilities were improved at the Albert Bosumtwi Sam Fishing Harbour built in Sekondi This harbour is equipped with a cold store an ice-making plant offices a berthing bay for inshore vessels a jetty for canoes and a net drying area Under Ghanaian law more than 50 of the ownership of industrial vessels must be registered with a Ghanaian company or individuals However in practice many vessels are owned by foreign nationals with token Ghanaian ownership Relatively few of these large vessels regularly put to sea and a number are in poor condition or obsolete Nevertheless the impact of trawling activities by Ghanaian registered and foreign owned vessels has been very considerable in coastal waters in recent years Fish landed from industrial vessels is usually transferred directly to Canning factories in Tema and Takoradi Ghana has the largest canning industry in West Africa In the region of 30000 tonnes of tuna are landed In addition to trawling some industrial vessels are engaged in shrimping the use of tuna lines and polls purse seining and demersal trawling Semi-industrial sector in addition to deep sea trawlers there are around 230 large semi-industrial ships propelled by inboard motors which are used for trawling in shallow waters during the off-season and purse seining during upwelling seasons There are currently reported to be 48 bottom trawlers 14 pair trawlers 2 shrimpers 33 pole and line vessels and 10 tuna purse seiners operating from 2 of the 7 landing sites Canoe sector Ghanas artisanal fishing sector is based on between 10000 and 12000 wooden canoes Fifty seven per cent of the fleet is powered by outboard motors supported by paddle and occasionally sail Each Canoe carries a crew of between three and 20 men depending on size and length There are over 334 landing sites along the 550 km coast of Ghana and the majority of fish caught by canoe (180000 tonnes) is returned to these sites accounting for 70 of Ghanarsquos fish production The principal landing sites are at Teshie Jamestown Chorkor Shama Axim Elmina Winneba Mumford Akplabonya Adina Atiteti Abutiakope and more Fishing is undertaken by men but the majority of canoes are owned by women who pre-finance fishing trips (purchasing gear and premixed fuel) and purchase the catch Women also predominate in processing and marketing fish and fish products Only about 20 of fish sold fresh a further 20 is salted and the majority (60) is smoked It is estimated that up to 30 of the catch is spoilt through lack of ice for storage or alternative processing facilities
17
Inland fisheries Water Resources Ghanarsquos inland fishery resources consist of a natural lake( Lake Bosomtwe) and nine major river basins which from east to west of the country are
bull the Volta bull Densu bull Ayensu bull Ochi bull Kakum bull Pra bull Ankobra and bull the Tano
The River Tano forms the border between Ghana and Cote drsquo Ivoire The largest of the rivers is the Volta which drains more than two-thirds of the country through several large tributaries in virtually all regions of the country The Volta river system also incorporates the Volta reservoir generally known as the Volta Lake which has a surface area of around 8400 km2 The Volta lake discharges through the Akosombo dam before flowing through a delta into the Atlantic Ocean The eight other river systems are relatively smaller simpler and open more directly into the Atlantic There are also several reservoirs created on the smaller river systems mainly for potable water production irrigation and flood control These reservoirs irrespective of their primary purposes enhance availability of more permanent aquatic habitable space for fish and therefore support some fisheries Finally with all the river systems opening into the Atlantic there are a series of lagoons and estuaries which act as interfaces between the rivers and the sea These water areas constitute another type of inland water resource for salt and brackish water fishes Inland Fish resources Within the inland water resources of Ghana there are over 150 fish species more than 90 of which are fished for food
In commenting on inland fisheries in Ghana it must be noted that virtually all available information on inland fisheries is obtained from the Volta Lake No national fish production records have been kept on the fisheries of the eight smaller river systems and the lagoons and estuaries Thus the usual statement that inland fish production constitutes about 20 of what the country produces should refer to fish production from the Volta Lake In practice the total inland fish contribution could more realistically be estimated at about 30-35 of national fish production This is a very considerable but understated contribution to national food security and nutrition
Fishing vessels The dominant fishing vessel on the Volta Lake is the canoe the majority of which are built from wooden planks On some other river systems while plank canoes predominate a small number are carved as dug-outs from single tree trunks There is some variety in sizes of the canoes depending on how many planks are used to build the boat and the size of tree trunk used in building a canoe The total number of canoes estimated on the Volta Lake during a survey in 2000 was 24035 On the tributary rivers of the Volta Lake and other river systems in the country the planked canoe is the main vessel used in fishing
18
Fishing gear There are about eleven main kinds of gear used for fishing on the Volta Lake They are Gill Nets Cast Nets Hook and Line Basket and wire mesh traps Winch net Beach seine Bamboo Nifa-nifa Wangara Spears and Atidzas On other rivers in the country Gill nets Cast nets Hook and Line and traps are the fishing gear used On both the lake and rivers the Gill net is the main gear
People Involved In the 2000 frame survey of the Volta Lake conducted by the Fisheries Directorate of Ghana the estimate of fishers on the Volta Lake was put at 71861 Fishers on the lake work in collaboration with a host of fishmongers or handlers who also function as wholesalers for individual fishing groups Assuming that the fisher population on the lake has increased by a modest 3 in the ten years from 1998 to 2010 a fisher population of about 93500 could be considered to be on the Volta Lake now If again it is estimated that number of fishers on rivers in the country were to be a tenth of those on the lake this would put the fisher population on inland waters (apart from the Volta Lake) at about 9350 fishers A very conservative estimate therefore puts the total number of individuals who are directly engaged in inland fishing at over 100000 This excludes all directly associated groups such as fish handlers processors and traders An estimate of secondary fisheries operators such as boat builders out-board motor operators and mechanics as well as bulk salt and fuel wood sellers and those engaged in buying selling and distributing fish would have to be considered in developing estimates for both direct and indirect employment in inland fisheries but the number can be assumed to lie between 125000 and 150000 people
Aquaculture Under Ghanarsquos legal framework aquaculture is defined as ldquoany activity designed to cultivate or farm fish and other aquatic living resourcesrdquo Currently only fin fishes are involved in aquaculture in Ghana
Current culture media and environment Currently fish culture takes place almost exclusively in fresh water in Ghana either in cages brush parks or dugouts Dug-outs are excavations made in floodplains in the savannah parts of the country were water scarcity has been a major hindrance to development in general and food security in particular Dug-outs get filled with flood waters and whatever the water carries during major wet periods of a year in the savannah areas Waters that fill Dug-outs invariably contain fish which are trapped in the Dug-out after the wet period These water bodies are managed until the end of the dry period and the fish are harvested before the next flood period Since the 1960rsquos various strategies to augment fish production from Dug-outs have been developed and tested These involve adding fingerlings of selected fish species to those which are lsquonaturally stockedrsquo in Dug-outs by floods Dug-outs are the major fish culture production approach in the savannah parts of the country which accounts for a little more than half the area of the country The Environment of fish culture Currently fish culture is taking place mainly in freshwater environments Brackish water fish culture and mari-culture activities which will bring lagoons estuaries and the sea into fish culture production have long term potential for development Fishes in culture Fishes being cultivated in Ghana In order of importance are Nile tilapia Oreochromis niloticus the African catfish Clarias gariepinus species of the catfish Heterobranchus and the Bony tongue Heterotis niloticus Scale of Culture Based on level of production fish culture operations can be categorized as follows
bull Large scale commercial where an enterprise produces up to 10000 tonnes per year
19
bull Medium scale commercial where a single enterprise produces between 50 and 500 tonnes bull Small scale commercial where an enterprise produces between one and 20 tonnes and bull Very small scale commercial with productions below 20 tonnes
Fish culture production Cultured fish contribution to national production was officially stated as 9000 tonnes for the year 2009 However informed opinion amongst fish farmers indicates that a figure of between 16000 and 20000 tonnes in 2010 would be closer to reality This statement is based on the facts that most producersrsquo published figures are underestimates several small to medium scale producers are not recorded in official lists and the recording of newly established fish farms has lagged actual establishment especially since 2009 Although cultured production up till 2009 may not have been significant considering a shortfall of about 460000 mt (as recorded in 2004) between captured fish production and national demand this reflected the fact that there were only two large scale commercial producers in the country each of which had had less than ten years of operation Anticipated growth in fish culture production within the next five years is expected to be dramatic as some of the critical challenges of the industry are resolved
CHALLENGES AND PROSPECTS Marine Fisheries The fishing sector is vital for food security and job creation to help alleviate rural poverty in Ghana However the levels of fisheries harvests are generally considered to be close to or to have exceeded the maximum sustained yield Future sustainability in the industry will depend upon the restriction of open access to fisheries and the introduction of management systems which allow fish stocks to recover and the establishment of consistent yields in both marine and inland waters Inland Fisheries Environmental conditions on the Volta Lake constitute the major environmental and social challenges for fisheries its sustainability and profitability In terms of future prospects success will depend heavily on implementation of the lsquoGhana Fisheries and Aquaculture Sector Development Planrsquo and the capacity of the system in Ghana to enforce the Fisheries Regulations passed by parliament in August 2010 Aspects of the Development plan that offers great prospects for the lakes fisheries include the provisions for eventually licensing boats (although the scale of this task should not be underestimated) and measures to involve communities in management of fisheries resources of the Lake
Aquaculture The main challenges facing aquaculture development in Ghana relate to bull The high cost of fish feed (significantly due to its importation from other countries) bull None availability of commercial fish hatcheries as enterprises bull Lack of a nation-wide distribution network for fish seed and cultured fish producers Most
sources of fingerlings are concentrated in one part of the country and since farms all over Ghana obtain their fingerlings individually transportation costs add significantly to overall production costs
bull Now emerging certification and monitoring to check the health and safety of aquaculture processes and products
bull The absence of adequate regulations regarding establishment of an aquaculture enterprise until August 2010 (In the absence of regulations only the large and medium scale commercial farms worked towards conforming to international performance Standards and operational regulations for certification of farms and their products still remain in a draft state)
bull Low national support for research to support expansion and systematic development of aquaculture
20
The prospects for development of aquaculture as an industry in Ghana are good since a number of practical policy and legal frameworks have been put in place to resolve the basic challenges to the industry listed above These include
bull Construction of the first local fish feed plant by an international fish feed company with the expectation of having initial products on the Ghanaian market during 2011
bull A lsquoLarge scale commercial fish farmrsquo with great capacity for fingerling production is shifting emphasis to fish seed production And several localized fish seed producers are expanding operations
bull Distribution strategies by cultured fish producers have started to emerge on a limited scale and are expected to evolve with increasing production as existing commercial farms expand and new ones join in
Now that regulations regarding establishment of aquaculture enterprises have been gazetted there is likely to be a positive response amongst fish farmers of all size categories New operational standards are being prepared which will introduce minimum standards for local certification This should set the stage for preparation of fish culture products and the broadening of choice for consumers while also qualifying Ghanaian producers to enter external markets
ENVIRONMENTAL CONDITIONS The coastal and marine environment a critical zone of influence for this study comprises a 550 km coastline a coastal belt ranging from 1 to 20 km in width and coastal waters extending to 200 nautical mile limit which was established in 1977(under the territorial waters and continental shelf act 1973 as amended by the territorial waters and continental shelf amendment decree 1977) The Coastal Belt The coastal belt accounts for only 65 of the land mass of Ghana but it is one of the most densely settled areas accounting for 25 of the population and80 of the industrial establishments in Ghana Historically the coastal zone was cultivated for coconut (copra) but this industry is in decline Vegetables and other agricultural produce are grown on better soils but the principal economic activities are fishing transportation salt production and sand and stone winning Tourism also offers great potential There is considerable expectation that the discovery of offshore oil and gas deposits will bring new wealth to parts of the coastal corridor However present plans to transfer crude products to tankers at sea and then export them directly will limit industrial activity to a support role A high percentage of industrial and municipal wastes is dumped at landfill sites within the coastal zone which creates pollution risks The coastal belt is generally a low-lying area less than 200 m above sea level Vegetation types reflect the rainfall gradient and consist of coastal shrub and Savannah to Winneba southern marginal forest to the east of Sekondi dry semi-deciduous and moist semi-deciduous forest to the east of Cape Three Points estuary and wet evergreen forest in the extreme south Soils are variable within this area ranging from fertile pockets river valleys to Sandy poorer quality soils close to the sea The Coast The coast line divides into three sections (Ly 1980)
bull West of Cape Three Points this area has a wide and flat beaches backed by coastal lagoons and
21
wave heights are generally low bull Between Cape three points and Tema the coast consists of a series of rock headlands enclosing
shallow bays together with sandbars or spits enclosing coastal lagoons The surf zone is a medium to high energy environment with wave heights often exceeding 1 m South-westerly prevailing winds give rise to longshore drift in an easterly direction
bull Between Tema and Aflao most of the shore is sandy although there are rocky outlets The coastal zone is important internationally in providing feeding roosting and nesting sites for thousands of migratory birds Environmental degradation is significant in Ghana and is recognized in the countryrsquos environmental action plan It contributes to rising poverty levels coupled with poor human health and inadequately planned urbanization which fuel a vicious cycle inhibiting human development The core issues include
bull Domestic sanitation bull Increased urbanization without appropriate infrastructure bull Wetlands and mangrove degradation bull Coastal erosion and bull General biodiversity loss
Briefly each of the above could directly or indirectly adversely influence fisheries and aquaculture separately or together For example in a recently completed study of water quality scenarios of the Volta Lake in relation to fish production as a component of a comprehensive study (The Challenge Program Project of Water amp Food) it was concluded among others that poor sanitation in highly populated fisheries communities adversely influenced water quality to the detriment of fish life and thus fish production With reference to aquaculture the same unsanitary conditions in highly populated shore communities adversely influenced water quality especially in terms of oxygen depletion when lake waters extend to the shore in high water periods This is a situation which has caused fish kills in cages because caged fish cannot escape lsquopollutedrsquo waters Degradation of wetlands and mangroves leads directly to a reduction in their capacities as spawning and nursery zones for both marine and inland water fishes which reduce fish production in both environments The situation outlined above is often contributed to by anthropogenic and industrial pollution due to urbanization without appropriate infrastructure Another issue linking human activity to a deteriorating environment is demonstrated by the encroachment of aquatic weeds on inland waters such as the Volta Lake Weed growth is accelerated by farming reservoir catchments which increases nutrient levels and the building of dams which reduce or cut off intrusion of sea water into rivers Currently as climatic change observable impacts such as floods seem to escape predictions The project could possibly contribute to mitigating against direct and indirect effects of climate change on fishing and aquaculture through investment into climate change orientation and education of fishers and fish farmers to mainly influence reasonable precautions they take Marine waters The continental shelf is relatively narrow projecting out to 25-35 km except in the area of Cape Coast to Salt Pond where it extends to almost 80 kms Sandy and rocky substrates which previously supported coral and seaweeds have been severely affected by former trawling activity which indiscriminately
22
dredges material from the seabed Coastal waters are enriched by freshwater discharges from the relatively small number of rivers and by two seasonal up-wellings which occur between late June and early October (the main upwelling) and January and March (the minor upwelling) The origin and driving mechanisms of these up-wellings are not fully understood and both their location and strength varies from year to year
Lake Volta and other inland water
Major environmental issues on the Volta Lake which might also be considered as challenges to sustainable fisheries on the major inland fisheries resource can be summarised as follows
bull The Volta Lake is known to be low in nutrients It therefore has low standing crops of phytoplankton and zoo plankton to support high fish production
bull The northern segment of the lake together with tributary rivers constitute the spawning and feeding grounds for majority of fish species in the lake during the wet season however these segments are intensely fished during the same period
bull The Volta Lake is divided into eight unequal strata with different distribution of boats per Km2 At the last estimation of carrying capacity in 2000 stratum V and II had the highest (527) and lowest(157) number of boatsKm2 respectively
bull The rate of siltation in the lake is considered to be increasing due to erosion associated with high rates of deforestation
bull A major challenge exists in getting fishers fishing communities and fishing entrepreneurs to understand and comply with fishing regulations aimed at conserving fish and fisheries resources
bull There is a lack of resources studies and research to support fisheries management of the Lake
bull High illiteracy exists amongst lake shore communities
bull Open access to the fish resources of the Lake has been in operation since its formation
bull Declining fish yields are occurring in the lake (468 Kgha in 1976 to 320 Kgha in 2003-MOFA) brought about by the constraints listed above
bull The commonly assumed estimate of potential fish production from the lake of around 75500 mtyr) is considered to be a serious underestimate since Stratum VII alone was estimated to produce 33800mtyr in 1996
bull The policy environment for aquaculture is currently strongly supportive of the industry and related enterprises
bull There is good quality and more than sufficient water to allow some kind of aquaculture to be developed in every region of the country with the Volta lake (about 8400 Km2) as the single most important water unit for fish culture Currently it appears that the free access to the fish resources of the lake has to some extent been applied to establishment of small scale caged fish culture enterprises a situation constituting environmental risk to investments of large scale commercial fish culture establishments in the lake
bull The Volta Lake is low in nutrients (Obeng 1964) resulting in a situation where higher fish yields could be sustained if greater quantities of fish feed were available
23
bull In Ghana the Nile tilapia O niloticus occurred naturally only in the Volta system Due to positive culture characteristics of the fish it has been moved into virtually all other river basins in the country The situation provides opportunities for hybridization of the Nile tilapia with other tilapia species native to the river basin into which the Nile tilapia has been moved
25
CHAPTER 4 POLICY AND LEGAL FRAMEWORK FOR ENVIRONMENTAL AND SOCIAL ISSUES
41 INTRODUCTION
Development and implementation of the Ghana Fisheries and Aquaculture Sector Development Plan and the World Bankrsquos supporting program need to be developed with full regard to existing international conventions national legislation policies and regulations This chapter highlights the main legislative and policy considerations for the protection of the environment natural resources fisheries and social and economic development It begins with reference to the World Bankrsquos safeguard framework and those of other donors This is followed by a section on the governance framework in Ghana
42 WORLD BANK AND OTHER DONORSrsquo SAFEGUARDS POLICIES
The World Bankrsquos safeguard policies exist to ensure that all projects which it finances are developed and implemented on environmentally and socially sound principles A range of different policies exist and these have been carefully considered to ensure that the Ghana Fisheries and Aquaculture Development Sector Development Plan complies with these safeguards All policies have been screened and those that have no bearing on the fisheries programme have been excluded from Table 41 below Table 41 lists policies which could have some applicability to the FASDP even if this interaction might be very slight It is important to stress that the comments in the third column of Table 41 relate to the entirety of the Fisheries and Aquaculture Sector Development Plan whose effects will continue to be experienced long after the World Bankrsquos financial support has been expended Most of the activities in the FASDP will have no effect in relation to safeguard objectives and where there are implications these are likely to occur at precise locations (for example at fish landing sites) rather than throughout the industry Where potential interactions have been noted the necessary mitigating measures are incorporated in the Draft Process Framework
Table 41 World Bank Safeguard Policies in Context
Safeguard Policy
Safeguard Policy Objective Brief Description and relevance to FASDP
OP 401 Environmental Assessment
This policy aims to ensure that Bank-financed projects are environmentally sound and sustainable and that the decision-making process is improved through appropriate analysis of actions and mitigation of their likely environmental impacts This policy is triggered if a project is likely to carry potentially adverse environmental risks and impacts on its area of influence OP 401 covers impacts on the natural environment (air water and land)
The majority of actions planned under FASDP will be beneficial to the marine environment and to inland waters However new construction activities could have impacts and depending on the project and the nature of impacts a range of instruments can be used to ameliorate and mitigate adverse effects while enhancing beneficial effects These include EIA environmental audit risk assessment and environmental management plans (EMP) The need for EIA and EMP is considered in this report
26
OP 404 Natural Habitats
This policy recognizes that conservation of natural habitats is essential to safeguard their unique biodiversity and to maintain environmental services and goods for human society and for long-term sustainable development The Bank therefore supports the protection management and restoration of natural habitats in its project financing as well as policy dialogue and economic and sectoral work Natural habitats comprise many types of terrestrial freshwater coastal and marine ecosystems They include areas lightly modified by human activities but retaining their ecological functions and most native species
This policy is triggered by any project (including any sub-project under a sector investment or financial intermediary) with the potential to cause significant conversion (loss) or degradation of natural habitats whether directly (through construction) or indirectly (through human activities induced by the project) This policy is applicable to the Ghana Fisheries Programme because the project focuses on the integrated management of natural habitats However by screening all proposals under the ESMF any sub-projects that might impact these habitats will not be funded
OP 409 Pest Management
The objective of this project is to (i) promote the use of biological or environmental control and reduce reliance on synthetic chemical pesticides and (ii) strengthen the capacity of the countryrsquos regulatory framework and institutions to promote and support safe effective and environmentally sound pest management
The policy is triggered if (i) procurement of pesticides or pesticide application equipment is envisaged either directly through the project or indirectly through on-lending co-financing or government counterpart funding (ii) the project supports an activity requiring the use of pesticides that may have negative effects on the environment The only instance in which this policy might be triggered by the Ghana Fisheries Programme is if aquatic herbicides or antibiotics were to be used in connection with aquaculture This is most unlikely but can be monitored through the implementation programme
OP 411 Physical Cultural Resources
The policy objective is to assist countries in avoiding or mitigating adverse impacts of development projects on physical cultural resources For the purposes of this policy ldquophysical cultural resourcesrdquo are defined as movable or immovable objects sites structures groups of structures natural features and landscapes that have
Under the Ghana Fisheries Programme construction and rehabilitation activities that could have negative impacts on cultural property will be avoided In the case of discovery of remains national procedures will be applied
27
archaeological paleontological historical architectural religious aesthetic or other cultural significance
OP 412 Involuntary Resettlement
The objective of this policy is to (i) avoid or minimize involuntary resettlement where feasible while exploring all viable alternative project designs (ii) to assist displaced persons in raising their former living standards income-earning capacity and production levels or at least in restoring them (iii) encourage community participation in planning and implementing resettlement and (iv) provide assistance to affected people regardless of the legality of land tenure
The policy covers not only physical relocation but any loss of land or other assets resulting in (i) relocation or loss of shelter (ii) loss of assets or access to assets (iii) loss of income sources or means of livelihood whether or not the affected people must move to another location The activities of the Ghana Fisheries Programme are likely to result in loss of assets or access to assets and loss of income sources or means of livelihood for some groups and individuals The potential for such losses will be carefully scrutinised and compensated for through the National Process Framework and Resettlement Policy Framework described in this report and appropriate procedures will be followed where necessary
Other donors and aid agencies including International and National NGOs play an active role within the fisheries sector in Ghana and their safeguards standards will be observed through operation of the Environmental and Social Safeguards Management Plan
28
43 THE GOVERNANCE FRAMEWORK IN GHANA
The Ministry of Food and Agriculture (MOFA) Preparation of Fisheries laws and policies fall under the responsibilities of the Minister of Food and Agriculture who in turn delegates functions including implementation to a semi-autonomous body the Fisheries Commission
The Fisheries Commission (FC) was established under the Fisheries Commission Act (625 2002) It oversees management regulation and utilisation of the fisheries resources of Ghana drawing on powers set out in the Fisheries Law (PNDC 256 1991) Fisheries Act 625 provided for the establishment of a more robust Fisheries Commission (FC) which is an amalgamation of the erstwhile FC and Department of Fisheries
Ten individuals constitute the Board which is led by a chairman (appointed by the President of Ghana in consultation with the Council of State) supported by three members drawn from the ministries of transport defence and environment There are three representatives from the following parastatal organizations - the Ghana Marine Fishing Officers Association Water Research Institute and Ghana Irrigation Development Authority- and two representatives (one from the artisanal and one from the industrial sections )of the National Fisheries Association of Ghana Finally the tenth member is a person with requisite knowledge of the fishing industry or natural resources renewal management
The day to day work of the Fisheries Commission is undertaken by the Department of Fisheries (DOF) which serves as the implementation secretariat of the Fisheries Commission as stipulated by the Fisheries Act 625 of 2002 Specific tasks that are undertaken by the Department of Fisheries include
bull preparing fishery resource management plans bull developing regulations for the fishing industry bull organizing monitoring surveillance and enforcement for the national fishery resources and
ensuring compliance with national fisheries law and institutionalizing co-management concepts
The MCS Division of the DoF (established under the Fisheries Sub sector Capacity Building project) works in conjunction with the Ghana Navy and undertakes sea patrols to exclude industrial fishing vessels from the 30-metre depth IEZ reserved for artisanal fisheries The MCS also conducts inspection of industrial vessels at the fishing ports of Tema and Takoradi for
bull valid fishing licences bull legality of fishing gear bull skipperrsquos certificate bull log book and crew composition
The MCS undertakes similar functions for inland fisheries on Lake Volta
The Ministry of Local Government and Rural Development (MLGRD) is responsible for managing fishers fish processors and fishery resources at district and sub-district levels which it undertakes through the District Assemblies In 2002 the District Assemblies in collaboration with DoF were mandated to facilitate fishery resource management by
bull helping to form and sustain Community Based Fisheries Management Committees (CBFMCs) bull cooperating with the DoF MCS units bull providing legal and financial support to the CBFMCs and bull approving levies proposed by the CBFMCs
29
Community-Based Fisheries Management Committees are charged with the responsibility of enforcing national fisheries laws at community level as well as initiating and enforcing their own by-laws
44 THE LEGAL FRAMEWORK
441 International Conventions
Ghana has ratified a number of international conventions and treaties which have an important bearing on the state of its marine and inland waters and the condition of the fisheries These are listed in Box 1 below
Box 1 International Conventions treaties and agreements to which Ghana is a signatory 1 International Convention for the Prevention of Pollution of the sea by Oil 21 October 1962 2 Convention on the Africa Migratory Locust 25 May 1962 3 Treaty Banning Nuclear Weapon Tests in the Atmosphere in Outer Space and Under Water 5th August 1963 4 International Convention for the Conservation of Atlantic Tunas 4 May 1966 5 Africa Convention on the Conservation of Nature and Natural Resources 15 September 1968 6 International Convention on Civil Liability for Oil Pollution Damage 29 November 1969 7 International Convention Relating to Intervention on the High Seas in Cases of Oil Pollution Causalities 8 Convention on Wetlands of International Importance Especially as Waterfowl Habitats 2 February 1971 9 Treaty and Prohibition of the Emplacement of Nuclear Weapons of Mass Destruction on the Seabed and the Ocean Floor and in the Subsoil Thereof 11 January 1971 10 International Convention on the Establishment of an International Fund for Compensation of Oil Pollution Damage 18th December 1971 11 Convention Concerning the Protection of World Cultural and Natural Heritage 16 November 1972 12 Convention on International Trade on Endangered Species of Wild Fauna and For a 3 March 1973 13 Convention on the Military or Any other Hostile Use of the Environmental Modification Techniques 10 December 1976 14 Convention on the Conservation of Migratory Species of Wild Animals 23 June 1979 15 Convention for the Cooperation in the Protection and Development of the Marine and Coastal Environment of the West and Central African Region1981(Abidjan Convention) 16 United Nation Convention on the Law of the Sea 10 December 1982 17 Montreal Protocol on Substances that Deplete the Ozone Layer 24 July 1989 18 Convention to Combat Drought and Desertification 19 Framework Convention on Climate Change June 1992 20 Convention on Biological Diversity1992 442 Environmental-Related Conventions Environmentally related conventions ratified by Ghana include
bull International Convention for the Prevention of Pollution of the sea by Oil 21 October 1962
bull Convention on the Africa Migratory Locust 25 May 1962 Treaty Banning Nuclear Weapon Tests in the Atmosphere in Outer Space and Under Water 5th August 1963
bull International Convention for the Conservation of Atlantic Tunas 4 May 1966 bull Africa Convention on the Conservation of Nature and Natural Resources 15 September 1968 bull 992256International Convention on Civil Liability for Oil Pollution Damage 29 November
1969 bull International Convention Relating to Intervention on the High Seas in Cases of Oil
30
Pollution Causalities bull Convention on Wetlands of International Importance Especially as Waterfowl Habitats
2 February 1971 bull Treaty and Prohibition of the Emplacement of Nuclear Weapons of Mass Destruction
on the Seabed and the Ocean Floor and in the Subsoil Thereof 11 January 1971 bull International Convention on the Establishment of an International Fund for
Compensation of Oil Pollution Damage 18th December 1971 bull Convention Concerning the Protection of World Cultural and Natural Heritage 16
November 1972 bull Convention on International Trade on Endangered Species of Wild Fauna and For a 3
March 1973 bull Convention on the Military or Any other Hostile Use of the Environmental
Modification Techniques 10 December 1976 bull Convention on the Conservation of Migratory Species of Wild Animals 23 June 1979 bull Convention for the Cooperation in the Protection and Development of the Marine and
Coastal Environment of the West and Central African Region1981(Abidjan Convention)
bull United Nation Convention on the Law of the Sea 10 December 1982 bull Montreal Protocol on Substances that Deplete the Ozone Layer 24 July 1989 bull Convention to Combat Drought and Desertification bull Framework Convention on Climate Change June 1992 bull Convention on Biological Diversity1992
443 National Legislation
The principal national legislation that affects fisheries in Ghana is listed below
1 Fisheries Regulation 1984 LI 1294 2 Fisheries (Amendment) Regulation 1977 3 Maritime Zones (Delimitation) Law 1986 4 PNDC Law 256 of 1991 5 Fisheries Commission Act of 1993 and 6 Fisheries Act 625 of 2002 7 Fisheries Regulations passed in 2010 LI 1968
Other laws that have relevance to the fisheries sector include
1 Wild Animals Preservation Act 1961 (Act 43) 2 Volta River Development Act 1961 (Act 46) 3 Ghana Water and Sewerage Corporation Act 1965 (Act 310) 4 Oil in Navigable Waters Act 1964 (Act 235) 5 Irrigation Development Authority Decree 1977 (SMCD 85) 6 Minerals and Mining Law 1986 (PNDCL 153) 7 Environmental Protection Agency Act 1994 (Act 490) 8 Ghana Highway Authority Act 1997 (Act 540) 9 Timber Resources Management Act 1998 (Act 547) and 10 Minerals and Mining Act 2006 (Act 703
31
434 Policies A number of Environmental related Policies exist in Ghana however there is no specific policy on the coastal zone These include
bull The National Environment Policy bull National Wetlands Policy bull Agricultural Policy bull Tourism Development Policy bull Land Management Policy bull National Health Policy bull Energy Policy bull Minerals Policy bull Wildlife Conservation Policy
The main thrust and orientation of national policies on the protection management and development of the marine and coastal environment focuses on the following three major areas
bull Integrated coastal zone management and sustainable development bull Marine environmental protection both from land-based activities and from sea-based
activities and bull Sustainable use and conservation of marine living resources (both of the high seas and
under national jurisdiction) Specific plans have been developed to ensure the realization of prudent management of the marine and coastal environment These include
bull Coastal Zone Management Indicative Plan 1990 bull National Environmental Action Plan 1994 bull Draft Integrated Coastal Zone Plan 1998 bull Coastal Zone Profile of Ghana 1998 bull National Oil Spill Contingency Plan with specific reference to the marine environment
2002 bull Environmental sensitivity map of the coastal areas of Ghana 1999 and 2004
Despite the existence of these plans active integration and coordination has been lacking in practice at local level 434 Regulations Though several legislations exist on coastal protection and sustainable development there is no omnibus legislation on the environment Legislation relating to the area include the following
bull Beaches Obstruction Ordinance 1897 (Cap 240) bull The Mineral and Mining Law 1986 (PNDC 153) bull Rivers Ordinance 1903 (Cap 226) bull Land Planning and Soil Conservation Ordinance No 32 of 1953 as Amended by the bull Land Planning and Soil Conservation (Amendment) Act 1957 (No 35 of 1957) bull Maritime Zones (Delimitation) Law 1986 (PNDCL 159) urban planning and
32
bull development bull Town and Country Planning Ordinance (Cap 84) bull Wild Animals Preservation Act Act 235 1964 bull The Towns Ordinance (Cap 86) bull National Building Regulations 1996 (LI 1630) bull Volta River Development Act 1961 bull Fisheries Act 2002 Act 625 bull Fisheries Law 1991 (PNDC 256) bull Fisheries (Amended) Regulations 1977 and 1984
The sustainable use and conservation of marine resources is encouraged through legislation regulations education and awareness creation programmes as well as the enforcement of existing regulations and legislation The legal framework for coastal zones issues and management in the country are contained in the following documents
bull The 1992 constitution bull EPA Act 1994 (Act 490) bull Environmental Assessment Regulations 1999 (LI 1652) bull Local Government Act 1993 (Act 462) bull Environmental Standards and Guidelines bull
In addition there are other specific legal frameworks which include a) The legal framework for Ecosystem Protection which are
bull Wild Animals Preservation Act 1961 (Act 43) bull Wildlife Conservation Regulations 1971 (LI685) bull Wild Reserves Regulations 1971 (LI 740) bull The Wetland Management (Ramsar sites) Regulation 1999 bull Oil in Navigable Waters Act 1964 (Act 235)
b) The legal framework for Fisheries Resources which are bull Fisheries Law 1971 (PNDCL 256) bull Fisheries Act 2000
c) The legal framework for Oil and Gas Industry bull Petroleum (Exploration and production) Law 1984 (PNDCL 84) bull Mineral (Offshore) Regulations 1963 (LI 257) bull Mineral (Oil and Gas) Regulations 1963 (LI 256) bull Oil and Mining Regulations 1957 (LI 221)
d) The legal framework for Tourism Promotion (including coastal tourism) bull Ghana investment Promotion Centre Act 1994 (Act 478) bull Companies Code 1963 (Act 179) bull Free Zone Act 1995 (Act 504) bull Ghana Tourism Board bull Ghana Commission on Culture
44 ACTIVITIES RELATING TO FISHERIES INTERESTS
33
Over the years several activities have been undertaken which are of relevance to protection of the marine environment and fisheries These include
bull Ghana Environmental Resource Management Project in Coastal Wetlands Management Component
bull Gulf of Guinea Large Marine Ecosystem Project bull Fisheries Sub-sector Capacity Building Project bull Establishment of a Protected Wetland Ecosystem on the coast bull Development and Implementation of Oil Spill Contingency Plan bull Monitoring of fish stock levels and associated oceanographic parameters bull Institution of a programme of Monitoring Compliance and Surveillance of the marine
environment bull Development of industrial pollution standards bull Development of University course on Coastal Zone Management bull Increased public education on sound coastal and marine environmental practices
45 RELEVANT INSTITUTIONS With regards to protection management and development of the marine and coastal environment a number of ministries and agencies have been identified as potential stakeholders Those shown with an asterisk are likely to have a particularly active role
bull Ministry of Environment and Science bull The Environmental Protection Agency bull Ministry of Tourism bull Ministry of Local Government and Rural Development bull Ministry of Ports bull District Assemblies bull Ghana Ports and Harbours Authority bull Hydrological Services Department bull Ministry of Food and Agriculture bull Ghana Tourist Board bull Ghana Investment Promotion Centre bull Fisheries Commission Ministry of trade Industries and PSI bull Ministry of Lands and Natural Resources Forestry and Mines bull Ministry of Energy bull Ministry of Health bull Ministry of Education Youth and Sports bull Ministry of Defence bull Ghana Navy bull Ministry of Works and Housing bull Ministry of Women and Childrenrsquos Affairs bull Ministry of Roads and Transport bull National Development Planning Commission bull Council for Scientific and Industrial Research bull Universities and Research Institutions bull Ghana Meteorological Agency bull Town and Country Planning Department bull Water Resources Commission
34
bull Ghana National Petroleum Corporation bull Volta River Authority bull Geological Survey Department bull Forestry Commission (Forestry and Wildlife Division) bull Traditional Rulers and their analogous ministry and laws
Non-Governmental Organisations including Resource Development amp Environmental Oriented Development Organisation
bull Friends of the Earth bull Green Earth bull Wildlife Society bull Recerca e Cooperazione bull Centre for African Wetlands bull And many others
46 PARTNERSHIPS Few formal partnerships exist However support for coastal conservation activities has been received from the private sector as well as from Government Regional and sub-regional collaboration efforts occur at various levels although the level of practical intervention is sometimes limited The science and technology unit of ECOWAS is engaged on issues relating to the management of the Gulf of Guinea In addition a bilateral arrangement exists between Ghana and Cote drsquoIvoire for the management of and datasharing on Sardinella stocks which migrate between the two countries The NEPAD framework among the coastal states of Africa is also developing an interest in marine and coastal management 461 Technical and financial support Ghana receives technical support in the form of training research and project implementation from national bilateral and multi-lateral sources Financing of activities in the sector is primarily supported from the national budget However donor support from both bilateral and multilateral sources has also been obtained for specific programmes such as the World Bank sponsored Fisheries Sub-sector Capacity Building Project UNOPS sponsored Environmental Sensitivity Map for Coastal Areas The Ghana Coastal Wetland Project of the World Bank UNEPrsquos WACAF Programmes and The Darwin Marine Biodiversity of West Africa Project by DFID implemented by the University of Ghana 47 ACTIVITIES Activities undertaken in the country with importance to the marine and coastal area are outlined in the following sections 471 Environment-related activities
bull Ecological Baseline studies of Korle Lagoon (1990-2000) This was carried out to satisfy EIA requirement and as a result pollution status of the lagoon was established
bull Lower Volta Mangrove Project (1996-1998) The objective is to ensure sustainable management of mangrove stands and as such baseline information was documented
bull Save the Seashore Birds Project (1985-1995) This was to protect the seashore birds and as a result conservation awareness of seashore birds was achieved
bull Ghana coastal wetlands management project (1996-1999) In this management of the five coastal wetlands designated as Ramsar Site was put in place
bull Darwin Marine Biodiversity of West Africa Project It is a training project in marine biodiversity assessment
35
472 Social-related activities bull A considerable amount of attention is currently being given to the potential impact of oil-related
development in coastal regions following the publication of Environmental and Social Impact Assessments and Management Plans relating to the Jubilee Oil Field discoveries
473 Coastal area management bull Climate and vulnerability and adaptation assessment on water resources agriculture and the
coastal zone Projects (1997-1999) The projects assessed the vulnerability of the coastal zone to climate change
bull Coastal area management plan for Princess Town (1998-2000) which aimed at providing a plan for the management of Princess Town
bull Keta Sea Defence Project Work (2000-2004) The project aimed at protecting the Keta and its environs from the episodes of erosion faced in the area and also to ensure improvement in environmental and socio-economic conditions at Keta and its immediate surroundings
474 Regional Programmes bull Gulf of Guinea Large Marine Ecosystems Project (1996-1999) The project developed an
effective approach to prevent and control pollution in the Gulf of Guinea and conserve its biodiversity As a result regional institutional capacities were strengthened and also a coastal zone management profile and plans produced
bull UNEP WACAF Projects 1 amp 2 This aims at institutionalising and coordination of national contingency plans monitoring of pollution in the marine environment and control of coastal erosion
475 Other major programmes Other recent programmes and activities in the marine and coastal environments have included
bull Ghana Environmental Resources Management Project in Coastal Wetlands bull Fisheries sub-sector Capacity Building Project bull Establishment of a Protected Wetland Ecosystem on the coast bull Development and Implementation of Oil Spill Contingency Plan bull
48 ONGOING PROJECTS Ghana is currently implementing several projects in the marine and coastal area Some of these projects are linked to developmental projects for which impact assessments are required under the Environmental Assessment Regulations of 1999 Some of the projects are large scale in nature with extensive baseline and monitoring studies like the Keta Sea Defence Project and the West Africa Gas Pipeline project Others are projects being implemented under the auspices of the United Nations agencies and non-governmental organisations include
bull Combating Living Resource Depletion and Coastal Area Degradation in the Guinea Current LME through Ecosystem-based Regional Actions
bull Amansuri Conservation and Integrated Development Project (ACID) bull Danida Water and Sanitation Sector Programme II Support to Integrated Water Resources
Management (IWRM) Component (2004-2008)The Densu Basin aspect of the IWRM component
bull Reduction of Environmental Impact from coastal tourism
bull Bui Hydro Power Project
bull Sea Defence Project at Atorkor
bull Sea Defence Projects in selected towns in the Western Region of Ghana
36
49 CONCLUDING REMARKS
This chapter has highlighted the wide range of conventions laws policies regulations and activities affecting the inland and coastal regions and inland freshwater and marine environment of Ghana It will be important to keep all of these processes and procedures under review as the Fisheries and Aquaculture Sector Development Plan is taken forward to the implementation stage
The main responsibility for ensuring delivery of the Fisheries and Aquaculture Sector Development Programme will rest with the Fisheries Department of the Ministry of Food and Agriculture and the Fisheries Commission supported by the MCS Division and Ghana Navy However a key part of the programme is the development of local co-management arrangements and the Ministry of Local Government and Rural Development and individual District Assemblies will play a key role in helping to form and sustain Community Based Fisheries Management Committees
Over time a significant number of fishermen and individual fish processors are likely to leave the sector as harvesting landing and processing of the catch becomes more efficient Management of these changes especially where disadvantaged and vulnerable sections of the community are affected will need substantial support and investment and a high degree of coordination amongst government ministries and agencies NGOs and international partners to ensure that development assistance is effectively targeted
37
CHAPTER 5 WORLD BANK SAFEGUARD ISSUES
51 INTRODUCTION
The World Bankrsquos proposed funding support to the Government of Ghana covers an initial five yearsrsquo period which could potentially be extended at a later date As the Government of the Republic of Ghana notes in the draft FASDP ldquoimproving the management of the countryrsquos fisheries and ensuring that the impacts on individuals and communities are properly addressed will take 20 or more years to effectrdquo It has therefore been judged important in this report to distinguish between changes that might occur as a direct result of the World Bankrsquos financial assistance thereby triggering the Bankrsquos environmental and social safeguards and changes that could result from longer term adjustments to fisheries and other sectors of Ghanarsquos economy as a result of wider influences by Government other donors and world-wide factors (for example international progress in world trade agreements)
The aim in this chapter is to identify changes which are likely to fall within the purview of the World Banks reputational risks and responsibilities under the first five years of the Fisheries and Aquaculture Sector Development Plan (FASDP) It should be clearly understood that the views expressed are those of the consultancy team and it will be for the World Bankrsquos internal advisors to decide what formal recommendations are made to the World Bank Board
Trends that may emerge in later stages of the implementation of FASDP ndash subsequent to the initial five year period - are discussed in chapter 6
52 THE CURRENT SITUATION
The general status of Ghanarsquos fisheries has been described in Chapters 3 while the legal and policy context has been set out in Chapter 4 The World Bankrsquos investment is being planned specifically to support government policy with the aim of providing a more efficient and better regulated fisheries sector Currently open access is leading to progressive deterioration in fish stocks and lower economic returns Based on many international examples of successful intervention the current proposals (see Chapter 2) are to provide support to introduce formal licensing of all vessels and proper monitoring and control over the seasonal timing and location of fishing activity use of gear and approved nets and self regulation through co-management structures under which the Government and fishing communities will work together to achieve recovery of fish stocks higher income levels for fishers and better returns on catches by reducing post harvest losses and improving processing and marketing operations
53 ANTICIPATED OUTCOMES
It is expected that the proposed reforms and changes will eventually lead to significant improvement in the marine environment restoration of fisheries and enhanced incomes In this respect the provision of grants and loans from the World Bank will bring about major benefits to the economy livelihoods and the environment in the longer term The question that has to be addressed however is - are there likely to be any short term adverse environmental or social consequences from the Bankrsquos own investment strategy Answers are considered in relation to each of the planned components sub-components and activities which are summarised in Table 51 A colour coding and numbering system has been adopted to distinguish those activities that are seen as particularly relevant from the standpoint of the environmental and social assessment Elements highlighted in green are those likely to have positive and beneficial effects on the environment and social conditions those highlighted in orange red have potentially negative or adverse consequences if not handled properly
38
Component 1 Good Governance and Sustainable Management of the Fisheries
Sub-Component 11 seeks to develop the capacity rules procedures and practices that will lead to better governance As such these procedural interventions will have no direct effect on the environment or social conditions of fishing communities However it will be important to ensure that the drafting agencies (government departments and consultants) give due attention to environmental and social objectives during this phase of work Three specific areas are highlighted including undertaking a socio-economic impact assessment with mitigation measures as part of the plan for fishing capacity reduction reviewing the economic and social implications of subsidies and fish import tariffs in the fisheries sector and developing the policy for the development and operation of community-based management networks built around defined fisheries management units
In developing regulations and guidelines it will be important to consider how less able individuals and vulnerable sectors are going to adapt to new systems For example the new regulations on licensing canoes including completion of registration forms the display of registration numbers on vessels and demonstration of basic competence in health and safety standards may prove taxing demands for owners and crew lacking any formal education Similarly legal instruments that are used to remove fuel subsidies or other benefits will need to be carefully explained A socio-economic impact assessment is proposed in the draft PAD to be accompanied by appropriate mitigation measures This assessment should consider amongst other things
bull whether support should be offered and if so under what conditions to any company community or individual who fails to secure a license for a particular class of vessel
bull how the transfer or sale of licenses will be regulated in the wider public interest to ensure transparent processes and avoid the creation of monopolistic and oligopolistic elites
bull who wins and who loses from any planned changes to subsidies and fish import tariff adjustments
bull how the performance of community-based management networks will be judged bull what action will be taken to mitigate the loss of any traditional fishing grounds that become the
subject of marine protected area development or are subject to exclusion zones to protect oil drilling and production platforms
Sub-Component 12 introduces the concept of fishing rights This is to be initiated through a series of four pilot stakeholder-based fishery initiatives and the rolling out of licensing procedures Discussions with stakeholders have made it very clear that the credibility of the entire fisheries policy and programme could be challenged if these pilots do not show positive and constructive ways of moving forward with fisheries reform There is a great deal of distrust for new procedures amongst the fishing communities based on the knowledge that many previous initiatives have failed It is therefore essential that the pilots are led by a strong implementation team are adequately financed and include a credible transparent and inclusive process for debate discussion and consultation Co-operation from the selected communities will be more likely to be achieved if they can see early results in terms of income generating activities
Sub-Component 13 is targeted at adjusting fishing effort and capacity to more sustainable levels and supporting alternative livelihood opportunities These activities are critical in giving effect to the policy decisions that have already been taken to reduce the size of the industrial and semi-industrial fishing fleet and to strengthen the role of the canoe sector Specific measures are proposed for compensating crew members who lose their jobs and for providing training to young men who are willing to transfer
39
out of the fishing sector The scale of this task should not be under-estimated however since there are currently few alternative employment opportunities in the coastal belt for manual workers with low education and skill levels which typify the status of many young fishermen The concept of creating some additional employment with conservation of the coastal littoral and marine ecosystems is strongly supported since this can be linked with development of tourism
Sub-Component 14 is another element that is strongly focused on delivering improved livelihoods with its emphasis on social marketing communication and transparency The focus on stakeholder participation is particularly welcome and should lead to positive response providing it is backed with direct financial support to participating communities
Component 2 - Reduction of Illegal Fishing
There is no Sub-Component 21 within the Ghana Fisheries Programme
Sub-Component 22 aims to develop monitoring control and surveillance (MCS) systems These measures are largely procedural and apart from the relatively small team that will be recruited to operationalise the systems it will have minimal effects on either the environment or social conditions One element that is highlighted in Table 51 relates to provision of facilities and training for participatory coastal surveillance of small-scale fisheries This should have direct and strongly positive benefits for participants and the communities who are enrolled in the training programmes
Component 3 increasing the contribution of the marine fish resources to the local economies
Sub-Component 31 will support the development of basic infrastructure at nine marine fish landing sites and two inland sites The scale of physical construction will be restricted to repair and minor extension of roads and jetties wharves and construction of net mending screens and storage sheds These activities are unlikely to have any significant adverse environmental impacts and should lead to positive social effects
Sub-Component 32 will underpin efforts to improve fish product trade infrastructure information and systems Introduction of new technology for smoking and curing fish and the extension of existing ice preparation plants will start to have positive beneficial effects within the selected communities
Sub-Component 33 provides a modest level of support to marine and inland aquaculture development Aquaculture development should include finalization establishment and enforcement of current draft operational standards to cater for environmental friendliness of fish culture industry for its own survival The main focus will be on developing policy and legal frameworks together with support for stock improvement These measures will have some impact on affected communities in the short term but are clearly aimed at longer term benefits
40
Component 4 Coordination Monitoring and Evaluation and Program Management
Sub-Components 41 and 42 are directed specifically at strengthening the capacity of the Governmentrsquos institutions for national implementation and regional co-ordination As such they will have no direct environmental or social impacts
54 SUMMARY AND CONCLUSIONS
This review of potential environmental and social safeguard issues under the World Bankrsquos targeted programme concludes that there are unlikely to be any significant adverse environmental or social effects as a result of the planned investments
The only possible exception relates to the effectiveness of measures that are put in place under Sub-Component 12 to support pilot stakeholder-based fishery initiatives It is of paramount importance that these pilots are successful and win the confidence of all participants since failure to achieve positive results could set back the entire fisheries programme For this reason it is essential that planning of the pilot initiatives is linked closely with measures for supporting alternative livelihoods and strengthening processing and marketing initiatives under Sub-Components 13 and 14
A number of the planned interventions may have longer term consequences as policies regulations and bye-laws are put into effect but these will be addressed in subsequent work by the Government of Ghana (see Chapter 6)
Table 51 Elements of the World Bank Programme and assessment of potential environmental and social risks
Description of Component Sub-Component and Activities
Measure of Likely Effects
Large (3)
Moderate (2)
Small (1)
None
Beneficial
3
2
1
Adverse
3
2
1
Component 1 Good Governance amp Sustainable Management of the Fisheries
Sub-Component 11 Developing the Capacity Rules Procedures amp Practices for Good Governance of the Fisheries
Reviewing developing programmes and projects designed to support the Fisheries and Aquaculture Development Sector Plan (FASDEP)
Developing an operational policy to enable implementation of the Aquaculture and Fisheries
Plan for fishing capacity reduction (including socio-economic impact assessment and mitigation) 3 2
Commercial vessel and fishing activity licensing plan including allocation criteria rules for transfer of licenses
41
Sector Development Plan and timetable and schedule of license fees
Compliance strategy and plan
Regulations for the management of fisheries including the identification and specification of fisheries management units (ie stocks species areas)
Recommendations for environmental and social safeguards arising from the review of the economic and social implications of subsidies and fish import tariffs in the fisheries sector
3
Policy for the development and operation of community-based management networks built around defined fisheries management units
3
Policy on adaptation strategies for climate change and marine protected area development
2 2
Review of the Ghana Tuna Industry to identify policy or infrastructure needs that threaten Ghanarsquos hub status
Strengthening capture fisheries management systems and capability
Development of fisheries and aquaculture management systems and processes and training
Strengthening fisheries information systems
Installation and operation of fisheries lsquodashboardrsquo database and information collection
Sub-Component 12 Introducing Fishing Rights ($15 M GEF)
Developing 4 pilot Stakeholder-Based Fisheries Management initiatives around defined fisheries units (ie local management initiatives tied to defined fisheries resources including demand-side governance initiatives)
3 2
Introducing and administering a licensing regime (registry establishment training stakeholder education) 2 2
Sub-Component 13 Adjusting Fishing Effort and Capacity to more Sustainable Levels and Supporting Alternative Livelihood Opportunities where Needed
Vessel decommissioning Decommissioning of 60 to 80 industrial trawlers in an environmentally friendly manner
2
Developing alternative livelihoods for crew of decommissioned industrialsemi-industrial
Skills training and small business development training and support for young (18-30 yrs) industrialsemi-industrial crew members willing to transition out of the sector
3
42
vessels
Alternative livelihood development to incentivize voluntary capacity reduction in canoe sector
Alternative livelihoods fund and CDD support to targeted fishing communities
3 2
Marine Resource Conservation
Would include confirming conservation priorities and management regimes and possible provision of support for alternative livelihood options (funded under 133) associated with conservation of coastal littoral and marine ecosystems as well as de facto protected areas associated with the development of oil and gas extraction
3
Sub-Component 14 Social Marketing Communication and Transparency)
Communications stakeholder consultations and awareness raising programs to support fisheries development
3
Component 2 Reduction of Illegal Fishing
Sub-Component 21 does not apply to Ghana
Sub-Component 22 Monitoring Control and Surveillance (MCS) Systems
Developing compliance systems and capability
Development of judicial and policy capacity (training)
Compliance risk assessmentstrategy systems and process development
Enforcement Unit establishment (dedicated facility)
Coastal surveillance stations 2
Facilities and training for participatory coastal surveillance of small-scale fisheries
3
Training for surveillance officers
Operation of aerial and water patrols (vessel leases aerial patrols operational costs patrol vehicles)
Observer program
Compliance education (stakeholder training signage) 1
Upgrademaintenance of the Vessel Monitoring System (VMS)
43
Component 3 Increasing the Contribution of the Marine Fish Resources to the Local Economies
Sub-Component 31 Fish Landing Site Clusters
Product diversificationvalue chain development
9 marine landing sites (basic infrastructure) at Axim Dixcove Fete Jamestown Moree Mumford Senya-Beraku Teshi and Winneba
3 1
2 inland fish landing sites (improved access and berthing infrastructure) at Abotoase and Dzemeni
3 1
2 ports developed (technical studies for 1 new port at Axim and additional berthing space in existing port of Elmina)
3 2
Sub-Component 32 Fish Product Trade Infrastructure Information and Systems
Export certification center development
Fish processing technology improvements 1 1
Technical assistance training and goods to support the National Fisheries Advisory Group
Sub-Component 33 Marine and Inland Aquaculture Development
Developing aquaculture policy and legal framework
Improving genetic quality of Tilapia fingerlings and breedstock
Catalyzing aquaculture development 2
Component 4 Coordination Monitoring and Evaluation and Program Management
Sub-Component 41 National Implementation
Technical assistance for Secretariat to the Fisheries Commission to implement the Project
Sub-Component 42 Regional Coordination
Technical assistance for Regional Coordination Unit at the CSRP support to Fisheries Information Systems (lsquoDashboardrsquo)
45
CHAPTER 6 ENVIRONMENTAL AND SOCIAL ASSESSMENT OF DRAFT FISHERIES AND AQUACULTURE SECTOR DEVELOPMENT PLAN (FASDP)
61 INTRODUCTION
This chapter examines environmental and social issues which need to be considered as part of the overall structural and economic adjustments in Ghanarsquos fisheries sector in the longer term (ie 1-15 years) The assessment deliberately focuses on the longer term because it will take a number of years before current plans start to have their full effect However the same temporal considerations apply to measures that are designed to avoid or mitigate potentially harmful effects so it will be important to start planning remedial actions as part of the joint Government of Ghana and World Bank fisheries programme
611 Key sectors and activities The fishing industry is divided first into marine capture and inland capture fisheries and then aquaculture For each of these three sectors activities are then broken down as follows Marine Capture Fisheries CATEGORY ACTIVITY Stock Management Research Surveillance reef building Harvesting Vessels Gear Skills capacity Marketing Sellers Buyers Processing Fresh fish Sun dried Smoking Freezing Consumers By market sector Support Sectors Boat Canoe Building fuel supply net making kiln construction
refrigeration transport cold store management Legal Enforcement Financing Investment in all elements Infrastructure Harbour wharf processing plant construction
Inland Capture Fisheries CATEGORY ACTIVITY Stock Management Research Surveillance Harvesting Vessels Gear Skills capacity Marketing Sellers Buyers Processing Fresh fish Sun dried Smoking Freezing Support Sectors Boat Canoe Building fuel supply net making kiln construction
refrigeration transport cold store management Legal Enforcement Financing Investment in all elements Infrastructure Harbour wharf processing plant construction
46
Aquaculture and Mariculture CATEGORY ACTIVITY Stock Management Research Surveillance Rearing Roe fingerling production cage -pond rearing Harvesting Vessels Gear Skills capacity Marketing Sellers Buyers Processing Fresh fish Sun dried Smoking Freezing Support Sectors Boat Canoe Building fuel supply cage construction kiln construction
refrigeration transport cold store management Legal Enforcement Financing Investment in all elements Infrastructure Harbour wharf processing plant construction
612 Evaluation Criteria The environmental and social assessment has been undertaken using a matrix (See Annex 114) which analyses the key sectors and activities of the fishing industry and the changes that are envisaged against a set of evaluation criteria Evaluation Criteria are broken down into environmental and social issues distinguishing between beneficial and adverse effects Table 61 below shows the relationship between the groups of criteria Table 61 List of Evaluation Criteria
Environment Social
Positive Adverse Positive Adverse
bull Sea bed rejuvenated
bull Fish stocks recovered
bull Biodiversity enhanced
bull Sea bed degraded
bull Fish stocks reduced
bull Biodiversity reduced
bull Increased harvest (catch volume)
bull Increased catch value
bull Reduced costs of inputs
bull Increased profit
bull Enhanced livelihoods
bull Increased job opportunities
bull Increased local economic multiplier
bull Reduced harvest (catch volume)
bull Reduced catch value
bull Increased costs of inputs
bull Reduced profit
bull Reduced livelihoods
bull Reduced job opportunities
bull Reduced local economic multiplier
The assessment process has involved systematically considering each sectoractivity against the evaluation criteria and recording either positive or negative results by drawing on the judgement of the consultancy specialists The findings are discussed in the paragraphs that follow and are reflected in Table 81 forming part of the Draft Environmental and Social Management Plan
62 DETAILED ASSESSMENT OF THE MARINE AND AQUACULTURE SECTORS
47
TunaIndustrial fleet streamlined and catch per vessel improved At present industrial trawlers have to travel increasing distances to fishing grounds and while the level of catch is remaining broadly static costs are increasing against available economic returns A major shortcoming is lack of investment in re-equipping the aging fishing fleet Many of the 90 vessels that make up this sector are increasingly unseaworthy and need to be replaced with modern trawlers and gear The plan is to buy out owners of substandard vessels by offering compensation at market value based on a full commercial survey Vessels remaining in the fleet will be required to meet exacting standards By reducing the number of old and inefficient boats this will allow each of the remaining vessels to catch a higher proportion of fish The aim is to ensure that Ghana is equipped with the latest vessels and technology in order to preserve the countryrsquos position as the hub of the West African tuna fishing and processing industry (see also the section on canneries below) The effect of these measures on the environment will remain broadly neutral since the same number of fish will be caught Providing other policies and increased surveillance are successful in preventing trawling in inland waters the smaller fleet will have to fish in deep oceanic waters This could potentially transfer some environmental effects on fish populations to other parts of the migratory cycle However this would become part of the international effort through fishing quotas to regulate overall catches Reduction in the size of the industrial fleet will mean that fewer men are needed to crew and service the vessels However in practice many men who work in this sector have only part time work and since a significant percentage of boats no longer put to sea the number of crewmen who will be displaced could be in the range of 1000-30003
It will be important to set up support services for those losing their jobs including retraining and welfare assistance where necessary
Decommissioning will necessitate the sale of seaworthy vessels and their removal from Ghanaian waters Other boats will need to be broken up and scrapped This process requires heavy duty specialized equipment and can release significant quantities of waste oil other toxic chemicals including refrigerants and asbestos used in pipe and engine room cladding Measures will need to be taken to ensure that proper environmental and health safety precautions are taken that decommissioning takes place in properly equipped boatyards and that all waste products are disposed of without environmental risk Cannery sector optimized The Fisheries and Aquaculture Sector Development Plan seeks to maintain the port of Tema as the centre of the Tuna canning industry in Ghana At present a proportion of Ghanarsquos tuna catch is diverted to neighbouring countries due to constraints on processing capacity These limitations include poor port infrastructure ageing equipment and delays in handling catch for some operators due to preferential treatment of vessels that are part-owned by the existing canneries Options for improvement include encouraging upgrading of the capacity of one or more existing canneries or promoting more competition in the processing sector and improving the infrastructure Providing modern building designs and construction techniques are employed and a full environmental assessment is undertaken in accordance with Ghanarsquos EIA regulations there should be no significant environmental or social risks associated with these development possibilities The potential economic benefit resulting from encouraging investment in this sector is very high
Industrial fishing excluded from inshore waters A major longer-term intention under the new fisheries plan (FASDP) is to ensure that existing regulations that restrict industrial and semi-industrial vessels from trawling in inshore waters are properly enforced This requires provision of surveillance
3 Based on an average crew of 20
48
equipment fast patrol vessels capacity building and training and increased staffing within Government agencies together with a full programme of awareness raising training and financial support to local bodies providing self-governance under new co-management services Restriction of industrial trawling in coastal waters will greatly ease pressures on fish stocks and reduce environmental damage to the sea bed In time this should lead to healthier fish population with more fish to be caught by the canoe industry as a result However the task of policing and enforcing regulations will not be easy and will take a number of years to bring into full effect Reduction in fishing activity by inshore trawlers will displace a number of crew members and have a short-term impact on dependent families until these individuals are either absorbed into the canoe fleet or find alternative employment There will therefore be a need to assist genuinely deserving cases where crew members (and their families dependents) need to transfer to other sectors of the economy These measures will only be required in the short term since the anticipated improvement in fish stocks will lead to improved economic performance in the canoe sector within which the bulk of employment exists
Expansion of deep water fisheries The fisheries plan notes that there may be a potential for exploitation or increased exploitation of some deep sea fish resources However the status and population dynamics of some affected species is not well known so any such activities should be scientifically monitored through research and enforced by MCS
Tema Secondi Port infrastructure improvements (equipmentbuildings) Under present conditions the transfer of fish from commercial and industrial vessels to canneries is often delayed by the time taken to offload crates and manouvre within the port area where there are conflicting activities There are also difficulties that arise when vessels owned by the canneries are given priority for landing leaving other boats waiting for many hours which can result in quality deterioration At this stage no details are available about the precise improvements that could be introduced and this will need to be investigated as the fisheries plan is advanced Any environmental effects from infrastructure improvements would be contained within the existing port areas and should be largely positive in reducing fuel (energy) costs and increasing overall efficiency It will however be important to carry out an environmental review of specific development proposals at the design stage especially if these involve plans for any dredging or for altering facilities for discharging waste and disposing of bilge water Both of these activities can have damaging effects on the sea bed (The first through dispersal of silt and sediment and the second through release of potential contaminants) Socio-economic effects from the infrastructure improvements should also be beneficial by removing delays increasing efficiency and reducing waste However there could be some slight reduction in manpower requirements leading to the need for skills retraining Regulating the catch (eg Fishing for selected species reducing juvenile catch to improve value of catch in inshore waters) The fundamental aim of the fisheries plan is to reduce the harmful effects on fish stocks and low economic returns from fish catches by phasing out open access for all and introducing regulation of fishing activity This is to be achieved through close cooperation between the Fisheries Commission Monitoring and Surveillance Unit as well as marine fisheries management division and individual fishing communities working together under a co-management framework The practical details will need to be worked out through each individual co-management group and initially the World Bank is offering to assist in the establishment of four pilots These bodies will test exactly what is required to increase fishersrsquo awareness to build capacity in self regulation and agree on appropriate measures
49
From discussion with stakeholders it is clear that while the broad principles are accepted the majority of the fishing community simply do not believe that the new regulations will be enforced because they have witnessed the failure of so many previous efforts to introduce firm management A major issue for the planned programme is therefore how to change this critical mindset without which very little progress is likely to be made in practice It will be necessary to demonstrate through the pilots that by regulating fishing activity direct benefits will accrue to those participating fishing communities Unfortunately efforts to eliminate harmful practices are unlikely to result in an immediate gain in fish stocks Instead catches are likely to fall in the short term It will therefore be essential to introduce other forms of incentive to cushion short term losses Such measures might include the purchase of new nets and gear for sale at subsidized price to local cooperatives the introduction of cash incentives for canoes demonstrating best practice in the use of gear and nets preservation of the catch using ice and landing and marketing fish of the required size and quality As restriction of open access starts to take effect there should be positive environmental gains in terms of improving fish stocks and less damage of the sea bed On the other hand both fishers and fish processors will feel the adverse temporary effect of reduced catches These social and local economic impacts will need to be monitored closely and assistance provided to help foster alternative livelihoods Cephalopus (Octopus) harvesting encouraged in inshore waters Although most fish species are currently exploited to unacceptably high levels within coastal waters there is a specific opportunity to increase the number of octopus caught by pot fishing This fishery could be developed by both the semi-industrial and canoe sectors Taking octopus in pots would have no adverse physical impacts on the sea bed and could allow very slight expansion in fish species that are preyed on by octopus At the same time it is important to note that there is only limited information on species composition and functioning of selected marine habitats including those of the octopus and more research should be undertaken on this and other species that could be selected for expanded fishing activity There would be clear socio-economic benefits arising from the creation of this new fishery Focusing fish landing at specific landing sites (to improve opportunities for subsequent marketing processing) Plans are already being developed for the enhancement of landing and processing facilities at a number of existing locations along the coast These locations include the construction of harbours at Jamestown and Elmina and development of landing sites at Teshie Ada Axim Dixcove Winneba Mumford SenyaBeraku Gomoa Fetteh Moree Keta Dzemeni and Tapa Abotoase Two sets of issues need to be considered in relation to these improvements all of which affect existing fish landing and processing sites The first is the nature of the physical works and infrastructure and it s potential effect on the marine and terrestrial environment The second is the socio-economic impact Both Elmina and Jamestown are long established fishing ports where the catch is landed either directly onto the beach or shallow wharves It is understood that the primary aim of the improvements will be to increase the area of permanent wharves to make it easier for fish to be offloaded to reduce the time taken in transferring stock to processing plants and to introduce modern technology In the case of other smaller landing sites the scale of improvements will be quite modest involving improvement to existing short stretches of access road the erection of stores for nets and other gear and provision of covered areas to provide shade for net-mending With all proposals for physical infrastructure development there will be a need to consider possible
50
environmental implications Due to the existing nature of these sites there are no major industrial or other commercial processes in the vicinity which could give rise to cumulative impacts including contamination of fish products The scale of plant needed for ice-making and storage and commercial smokeries is commensurate with the artisanal nature of the fishing activity itself and would not give rise to any significant environmental effects on air or water quality Harbour works could potentially involve some small scale dredging (for example the removal of accumulated silt) Where dredging is required it will be important to identify disposal areas (either at sea or on land) where silt can be deposited without damage to sensitive habitats In terms of economic and social impacts it is not clear at this stage who are likely to be the major investors from the private sector although it may be assumed that existing operators who have access to finance will be the main beneficiaries Over time as landing marketing and processing become more efficient it is possible that individuals in the traditional fish smoking sector will lose a significant proportion of their trade as the product switches to fresh or frozen fish sales for transfer to the major urban markets and the beach price for fish rises The draft Ghana fisheries and aquaculture sector development Plan notes in annex 2 that proposed facilities associated with the ports and landing sites may not have support from fish mammies or at least formidable commercial advocates able to resist any opposition from that quarter Inspection of major fish landing areas like Elmina and Sekondi indicates that the existing social and commercial structure of support activities to fish harvesting is very complex and involves almost every member of the community including children and the elderly Such activities include net mending boatbuilding metalworking (for cooking pots stoves and grills supplies (ropes weights tar paint wood) fuel supplies ice crates transport etc Leaders of the fishing community confirmed that in principle the improvements of facilities is welcomed provided that safeguards are in place for those who may lose part or all of their current trading activity through rationalisation Stabilise fleet capacity at a sustainable level Fishery experts consider that there would be significant benefits in reducing the number of canoes from the present 10000-12000 to around 8000-9000 which correlates with the number operating in the mid 1990rsquos when catches were at optimum levels At the same time the Fisheries and Aquaculture Plan stresses that the canoe sector will remain at the heart of the Ghana fishing industry and this has strong political enforcement Consequently there is unlikely to be any enforced reduction in the number of canoes holding licenses and owners of all existing canoes will be able to register their vessels The ability of canoe owners to pay annual licence fees should rise as the overall measures to increase efficiency and improve catches take effect However many people anticipate that over time as the annual cost of holding licenses rises less efficient fishers will sell their licenses (and hence their rights to fish) There may therefore be a de facto reduction in the size of the canoe fleet Even if numbers do not decrease the fleet could be stabilized at its present size by taking a decision not to grant new licences The draft plan discusses the fact that under existing law (section 53) there is a requirement for licenses to be issued on demand (presumably to ensure that Ghanaians are not barred from subsistence fishing) It is argued in the plan that this is a misconception since canoe fishing is largely a commercial activity and it is concluded that lsquoit is therefore essential that the number of canoe licenses can be controlled in future and the legal basis for these controls must be reviewed as a matter of priorityrsquo Decisions of this nature will require the full support of local co-management groups if they are to be effective but committees could easily come under pressure to make exceptions as the coastal population continues to rise and families without alternative livelihoods start lobbying for assistance
51
Accusations of preferential treatment of certain individuals by committees (or committee officials) - possibly linked with suggestions of bribery and corruption -could cause a lot of social tension and start to undermine community trust in the need to work together to improve fisheries management It is therefore most important that the detailed proposals for co-management address this risk and include proposals for mitigating individual hardship of the less advantaged ndash for example by offering voluntary retirement with some form of incentive Influencing marketing to maximise value and reduce post harvest losses (marketing cooperatives strong market structures etc) FAO has estimated that physical post harvest losses in Ghana amount to between 3 and 17 of smoked fish production and 16-20 of gillnet landings The plan notes that introduction of lsquonew generationrsquo small scale fish smokers should be introduced to replace the traditional Chorkor model This would improve fish product quality by eliminating charring of fish over open flames and also protecting operatorsrsquo eyes from the damaging effect of smoke and particles The other major improvement in post harvest value and profits would arise from greater use of ice throughout the supply chain Developing Aquaculture A distinction needs to be made between aquaculture development in ponds and dugouts which are self-contained and fish rearing in cages within open water In the case of farm ponds the commercial rearing of fish is little different to other forms of intensive livestock rearing Providing there is no direct connection to rivers and streams there is little likelihood of interaction between farmed and wild stocks which could spread fish infections and parasites In the case of fish farms in open water (rivers and lakes) there are well known risks of the spread of disease which can arise if overstocking occurs Intensive feeding of large numbers of fish in a confined area can lead to significant deterioration in water quality through the build up of nutrients from wood and waste It is also possible for antibiotics and growth hormones to be dispersed beyond the area of farm cages Genetic modification of farmed fish can also affect the local fish population through escapes All of these issues are capable of being managed and mitigated through good initial planning and design and subsequent maintenance and supervision It will therefore be necessary to develop additional regulations and guidelines specifically for the aquaculture sector 63 SUMMARY OF ENVIRONMENTAL RISKS AND OPPORTUNITIES Review of the full range of governance and development activities suggests that there are no high levels of risk to the marine or littoral environment Successful implementation of the Policy and plan should in fact result in very significant environmental gains Over a timespan of 5-20 years five activities in particular should result in significant improvements in the condition of the sea bed in coastal waters (to a depth of 30 metres) reestablishment of benthic flora and niche habitats increased fish stock and enriched biodiversity These interlinked activities are bull The exclusion of industrial vessels and trawling within coastal waters bull Regulation of fish catches through zonation seasonal control of fishing and standards for vessels
gear bull Stabilisation of the fishing fleet within sustainable harvesting yields bull The adoption of management plans formulated and agreed with full cooperation of local
communities bull The introduction of fishing rights through co-management agreements and bull Well planned consultation and information dissemination throughout the fisheries sector
52
Three components of the development plan have been identified where minor to moderate risk to the physical and biological environment could arise if proper design and implementation standards are not adhered to These relate to bull A potential risk of over-exploitation of new catch species in deep water off the continental shelf if
such development is not accompanied by through research to establish the sustainable yield of target species
bull Strictly localized effects on the physical environment from construction of landing wharves or jetties and other harbour facilities and
bull Infrastructure development at the existing ports of Tema and Takoradi All of these risks are capable of being fully managed by improved governance in the fishing sector and EIA procedures that are well-established in Ghana 64 SUMMARY OF SOCIO-ECONOMIC RISKS AND OPPORTUNITIES Implementation of the Plan Project will bring about substantial change in the fisheries sector and over time increased revenue reduction of post[harvest losses and added value to fish products will bring major economic returns At the same time there will be some individuals who do not participate in direct gains and whose livelihoods could be adversely affected if appropriate safeguarding measures are not put in place The level and extent of these socio-economic risks will be determined by 1 the level of commitment that is entered into by Government and its development partners to
deliver incentives to vulnerable and disadvantaged groups and 2 the speed with which the sector is transformed Rapid change could cause significant
displacement of less-efficient operators especially within the semi-industrial and canoe sector which would have serious ramifications for dependent communities However these effects can be marginalized if the development programme is carefully phased to ensure that alternative livelihood and employment incentives are available
The main risks to local livelihoods relate to the potential for bull loss of employment for crews of unseaworthy obsolete vessels ( from all sectors including
industrial semi-industrial and canoes) that are withdrawn from the fishing fleet because they no longer comply with license regulations
bull the inability of vulnerable and disadvantaged groups including artisanal fishers vendors and individual fish processors in small fishing villages to adjust to new market conditions at selected landing sites
53
CHAPTER 7 ASSESSMENT OF POLICY OPTIONS
71 INTRODUCTION
In order to place the significance of the environmental and social safeguards assessment in context this chapter examines the possible consequences of different policy responses to the existing challenges that face the fisheries sector in Ghana These different policy responses range from a continuation of the status ndashquo effectively a ldquodo-nothingrdquo option (A) to full-scale commitment by all stakeholders to achieving a sustainable fisheries future the ldquoOptimum Solutionrdquo option (C) Various less sustainable outcomes lie in between these two ends of a continuum of policy choices and these are represented by the ldquoWeak Solutionrdquo option (B) 72 OPTION A ndash DO NOTHING Background research and discussion with stakeholders indicates that practical capacity to deliver on clearly stated national goals for sustainable fisheries livelihoods and the reduction of poverty is weak This situation exists despite the fact that Ghana has a strong legal framework for management of its fisheries including the Law Policies and Regulations There is inertia and strong resistance on the part of the majority of players to accept that it is largely their own actions which are responsible for present conditions This in turn leads to the attitude that it is only the lsquoGovernmentrsquo that must act by providing increased subsidies and cushioning the industry against further deterioration in catches Unfortunately there is overwhelming evidence from around the world that where fish stocks are exploited beyond their natural capacity to regenerate this can lead to sudden and near-total collapse Ghana has historically been one of the strongest fisheries in West Africa but the signs are ominous that current levels of exploitation are leading to progressive decreases in annual catches for most species in both marine and inland waters As fishing effort intensifies with an increasing number of all types of vessel using illegal methods and inappropriate gear the distinction between the traditional lsquopeak season and lean season (linked to migration patterns breeding cycles and upwelling) is becoming blurred This is clearly illustrated by a statement from one of Elminarsquos fish mammies ldquowe use to smoke the herring in the peak but now the fishers bring them all the yearrdquo Use of monofilament nets light dynamite and chemicals to obtain fish in the lean season is aggravating a situation where too many boats are chasing too few fish Many fishers blame the reduction of catch on global warming for increasing water temperature the emergent oil and gas industry for restricting access to traditional fishing grounds and industry and urban development for increasing pollution leading to deterioration in water quality Each of these assertions warrants careful consideration but the industry is generally in denial when it comes to the primary fact ndash too many fish including juveniles are caught to allow regeneration of the stock In addition weak governance and lack of resources to ensure implementation of policy result in a situation where the law can be ignored with impunity If collective failure to recognize the seriousness of the current position and lack of commitment to taking hard decisions continues the omens for the future are not good Within a period of 10-15 years fish catches could fall by 50 or more from their present level Impacts on each species would vary and catches of some fish with regional or global migration patterns could remain viable (although this depends on the international conservation effort) On the other hand stocks of fish that provide the mainstay of local food resources herring and sardine could be decimated
54
Complete collapse of all fish species is unlikely but it is possible to envisage a situation where catches might fall below 300000 tonnes a year by 2025 (a reduction of more than 25 from present levels) The most serious consequences would be felt as a result of the social and local economic impact on fishing communities Perhaps 30000 men representing the crews of 3000 canoes and semi industrial boats and 15000 women engaged in marketing and processing would lose their present livelihoods Population migration away from the coast could follow and severe social pressures and local economic hardship This is clearly a ldquoworst caserdquo scenario and if conditions were to worsen gradually it might be possible to intervene but the fact has to be accepted that fish stocks are dynamic and subject to rapid decline (as in the case of the North Sea Herring and Atlantic Cod) 73 OPTION B THE lsquoWEAKrsquo SOLUTION The bleak future painted in Option A is unlikely to arise if the present policy and draft fisheries development plan is followed since these are specifically directed to addressing the major challenges However realization of the aims is dependent upon delivery across a wide range of initiatives by multiple stakeholders The following paragraphs illustrate some of the ways in which delivery of policy objectives might be thwarted These may be summarized as
bull Commitment to good governance and institutional reform bull Political resolve to implement unpopular measures bull Availability of adequate technical and financial resources bull Inertia to necessary changes in fishing practice
Good Governance and Institutional Reform Fundamental reforms are required to fully equip the national fisheries management effort at government level This includes introduction of change management clarification of responsibilities for senior staff rationalization of financial management systems provision of equipment expansion of staff numbers additional training and capacity building As an illustration of the extent of the effort required reference can be made to just one topic area the issue of monitoring control and surveillance At present the Fisheries Commissionrsquos MCS Unit has only 10 employees to oversee implementation of the fisheries regulations throughout Ghana This number will be increased as other institutions are engaged in joint monitoring initiatives but it is obvious that staff numbers and capacity will need to be expanded if regulations on fishing activities are to be affected Enforcement is only one part of the equation however Much greater emphasis will need to be placed on voluntary controls and self-policing at community level through Co-management schemes
Failure to press ahead with governance and institutional reform could delay the process of introducing and registering licenses which represents a crucial first step in moving from open access to managed access in the fisheries sector Given the urgency for action the five years allowed in the current plan for completing the registration process seems very generous Political resolve to implement unpopular measures Stakeholder meetings have confirmed the significance of party political influence as a constraint on achieving progress in the reform of the fisheries sector The offer of incentives like subsidies or the promise of new facilities and equipment are regularly employed by individual politicians to garner votes whether or not these form part of party manifestos Examples have been quoted to the consultants where enabling regulations that might restrict fishing access and prove unpopular amongst the fishing community are quietly ignored and officers may be discouraged from pursuing breaches of the law where the offender has political influence These issues arise with governments of all political
55
persuasions and can apply at all levels from District Assemblies through to regional and national committees
A serious issue with fisheries sector reform is that once actions have been taken to conserve fish stocks it may be years before the full benefits are felt and the results are evident in terms of increased catches This makes it harder for governments to institute unpopular reforms ndash even though these are in the best interests of the nation fishing communities and individuals Fishermen and their families are used to seeing an instant lsquosame day returnrsquo on their catch and are less willing or able than stakeholders in other economic sectors to wait for gradual improvements There is an urgent need to establish cross-party support for the fisheries sector in Ghana and to seek agreements between the main political parties to support established policy and regulations where these are in the interests of delivering sustainable fish stocks Availability of Technical and Financial Resources The process of moving from complete open access to restricted use rights for both marine and inland capture fisheries will take many years to complete Progress will be heavily influenced by the level of political will availability of technical assistance and financial support Existing subsidies (pre-mix fuel and import tariffs) are seen as a deterrent to the encouragement of more efficient business practices However in order to reduce dependencies on these forms of government aid there is also a need to underwrite new forms of economic enterprise by giving help to start-up businesses developing training centres and promoting alternative livelihoods for those individuals who are either displaced or voluntarily give up work in the fisheries sector Inertia to Change Traditional fishing practices are quite literally a way of life for many Ghanaians and have been handed down from generation to generation These traditions are closely interlinked with cultural practices and power and influence resides in specific families with hereditary authority In order to change attitudes and gain acceptance of new approaches to fishing there is a need for a major awareness building and communications strategy targeting in particular the traditional leaders of the fishing industry Without such a plan it will be difficult to break down the internal resistance and inertia towards change The constraints that have been outlined above in relation to the lsquoweakrsquo option are very real and in combination they present a serious barrier to progress It will require real political commitment on the part of Government and strong financial support from international partners to break down these barriers 74 OPTION C THE lsquoOPTIMUMrsquo SOLUTION
The new Draft Fisheries and Aquaculture Plan together with the Act and Policies provide a solid foundation for revitalising the fisheries sector in Ghana However for the reasons discussed in relation to options A and B above there are a number of impediments that need to be overcome In addition to the measures in Option B an ldquoOptimumrdquo solution would also include
A coherent mix of Incentives (carrots) and Regulation (sticks) A top priority in developing existing strategies and plans will be to ensure that measures are in place to offer encouragement and practical assistance to fishers to convert to more sustainable practices while at the same time introducing effective enforcement There are some real challenges with both of these goals
56
New forms of incentive need to be developed to convince boat owners and their crews that it is worth their while to drop illegal methods (dynamiting use of monofilament nets etc) and to reduce the level of fishing effort (through close seasons introduction of restricted zones etc) Without these incentives it is highly unlikely that there will be significant take-up of the fisheries stock management and conservation message Special attention needs to be given to the role of chief fishermen and local community councils in developing effective local policing since it is impractical to rely on a national MCS team to regulate canoe activity in either the marine or inland capture fisheries The national MCS team will have its own responsibilities for policing local and international waters in relation to industrial and semi-industrial sized vessels Integrated Coastal Development The long term success of the fisheries strategy depends upon reducing fishing effort to a level at which catches become both sustainable and profitable for those who remain in the business This in turn requires that those displaced from the industry are able to find gainful employment and livelihoods in other sectors of the economy The fisheries industry is often seen as a separate economic sector which attracts its own funding and support but in order for the necessary reforms to take place these attitudes will need to change A new approach is required to lsquointegrated coastal developmentrsquo following the lessons from integrated rural development Many fishing inland and marine fishing communities are almost wholly dependent on fishing with less than 10 of the local economy being devoted to other industries Reform of the fishing sector therefore requires that as much ndash if not more ndash effort is devoted by government and its international partners to building up complementary economic activities in construction transportation manufacturing food processing environmental conservation and tourism There is a need to explore new state industry partnerships to establish appropriate economic development agencies and to coordinate activities between relevant state institutions ministries and departments under the current decentralisation initiatives with district assemblies taking a prominent role If initiatives of this sort are taken forward it will make the task much easier in persuading conservatively ndashminded fishing communities that they need to simultaneously develop their own entrepreneurial flair and impose their own discipline
57
Chapter 8 DRAFT ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK (ESMF) 81 INTRODUCTION Previous chapters of this report have described the principal environmental and social impacts that are likely to arise from reform in the fisheries sector This chapter sets out the Framework (ESMF) for an Environmental and Social Management Plan (ESMP)The first step has been to outline specific objectives to be achieved through implementation of the ESMF These objectives relate specifically to the issues described in earlier chapters Subsequent sections of the chapter detail the measures which are required to respond to specific areas of environmental and social impact through mitigation and amelioration works They also describe the types and level of environmental monitoring required together with the institutional aspects which need to be improved in order to support the fisheries sector 82 STRATEGY AND OBJECTIVES The basic aim of the environmental and social management plan is to set out guidelines for participatory programs under which members of local fishing communities and civil society in general can become involved in the design and implementation of local fishery co-management maintaining sustainable local livelihoods and achieving local monitoring of fishery efforts The basic principle for future fisheries management is that both marine and inland waters will be demarcated as territories for use rights to fisheries (TURFs) The principal goal of government policy in the fisheries sector is to ensure that the fisheries industry plays an increasingly important role in supporting the growth of the economy as outlined in the Ghana poverty reduction strategy (GPRS II) and the Republic of Ghana fisheries and aquaculture policy This goal will be supported by implementation of the fisheries and aquaculture sector development plan over the next five years In this timescale the aim will be to bull improve management of fisheries the conservation of aquatic resources and protection of the
natural environment bull promote value addition in the fisheries sector and the improvement of livelihoods in fisheries
communities bull encourage sustainable development of aquaculture bull improve the services provided to the fisheries sector by the fisheries commission and supporting
institutions The overall consequences of this strategy and the investments that are being made by the government and its aid partners will be stabilisation of fish stocks and sustainable catch levels a strengthening of the national economy and creation of a more robust fisheries industry with consequent benefits for fishing communities Impact assessment confirms that the result will be significant benefits for the marine environment and local economy However depending on the rate of transition from an open access to a fully regulated market a number of adverse effects could arise unless appropriate mitigation measures are put in place Specific issues which require attention in this plan are listed below bull potential risks of environmental degradation through development of new fishing targets in
deep water
58
bull localised environmental impacts at construction sites bull loss of resources for individual operators due to restricted or controlled access to fishing
grounds bull displacement of labour from crews of vessels that are withdrawn from the industrial and semi-
industrial fleet bull Decommissioning of obsolete industrial vessels may not necessarily lead to recovery of fish
stocks Catch Per Unit Effort (CPUE) may increase This could lead to loss of livelihoods to crew members and the owners of the decommissioned vessels it could increase catch for the few vessels remaining in the system
bull increase production costs due to idling time in closed seasons for fishing bull exclusion of some groups and individuals seeking entrance to the industry following completion
of licensing bull concentration of processing and marketing at selected landing sites leaving Fish Mammies and
their dependents in other smaller fishing communities at an economic disadvantage bull displacement of traditional canoe building and other ancillary support industries by more
efficient and modern methods of construction and the inability of some workers in these trades to train and re-skill in the use of modern materials
bull lack of employment opportunities in alternative sectors The ESMF will set out specific actions to address these concerns through a coordinated set of interlinked proposals as follows 1) Preparation of local management plans and close surveillance of all new fishing enterprises in
deep waters
2) Preparation of environmental protection clauses to be included in all contracts and agreements for physical development work
3) Regular inspection by environmental protection officers of construction work at harbours and landing sites
4) Establishment of community management plans to provide support to those groups and individuals who are adversely affected by any of the measures listed above
5) Creation of community liaison groups to actively support community development alternative livelihoods and conversion to new areas of economic activity for those Fisher families or individual fishers who are adversely impacted
6) Introduction of skills training centres and business advice for small and medium enterprise development
7) Establishment of a coastal development agency drawing on the resources of the ministry of local government agriculture and tourism (others to be added) to coordinate integrated projects and initiatives for economic development linked with the existing coastal zone management plans
8) Creation of a liaison group between the government of Ghana and its international development partners to ensure that investment in the fisheries sector is targeted in the most effective way to deliver plan objectives and avoid duplication of effort
59
83 COMPONENTS OF THE ESMF The following paragraphs provide a summary of the draft ESMF 831 Local Management Plans these plans will be prepared for discrete zones of influence around specified fishing settlements Each plan will contain the same standard list of relevant activities that are to be monitored 832 Environmental Protection In relation to construction activity a checklist will be prepared identifying precisely what level of environmental scrutiny is required for specific types of development This checklist will be prepared by the Fisheries Commission with the support and advice of the Environmental Protection Agency 833 Small-Scale Project Development and Livelihood Restoration a list of potential micro-projects will be prepared by the Fisheries Commission which are regarded as suitable for support funding Demand for these micro-projects will be determined at the local level (ie in villages and fishing communities) Applications for funding of micro-projects will be submitted to the community liaison group for vetting and recommendation based on pre-established eligibility criteria Recommended projects will be referred for formal approval at national level (or through the Coastal Development Agency) 84 POTENTIAL PROJECT IMPACTS ON ASSETS AND LIVELIHOODS The project will have some adverse impacts on assets and livelihoods Therefore provisions will be made under the ESMF to minimize all such impacts including those of socio- economic significance and on any environmentally sensitive sites Provisions are also made in the RPF to accommodate all potential situations including cases that may entail actual displacement and livelihood restoration assistance in accordance with the Governmentrsquos policy and World Bank Policy on Involuntary Resettlement OP412 (see Chapters 9 and 10) The potential social and environmental impacts associated with the project (see Chapters 5 and 6) are summarised in Table 81 and the approach to related mitigation measures is defined in section 85 and Table 82 below
Table 81 Potential Environmental impacts and Social issues
Type of Activity Description Environmental Significance
Social Significance
Decommissioning of obsolete industrial vessels
Scrapping of vessels may release toxic waste (contaminated oils asbestos pipe wrapping and insulation etc)
Contamination of landfill dumps
Related health hazards
Laying off of work force Recovery of fish stocks in areas currently over-fished by trawling
Decommissioning of excessovercapacity would result in loss of livelihoods for crew members
60
Plan for fishing capacity reduction
introduction of licensing system for canoes and enforcement of licensing system for semi industrial vessels
Reduced catch from the decline in the use of prohibited fishing methods (activities) as stipulated in the Fisheries Regulation 2010 (LI1968) eg use of light dynamite etc
Reduction in fishing capacity should lead to significant recovery of fish stocks with long term benefits for all
Short term reduction in fishing effort and increased regulation may prejudice vulnerable sectors (illiterate elderly fishers) Capping on new entrants may remove the safety net opportunity offered by fisheries to would-be fishers who may be without alternative livelihoods
Harbour development and landing site improvements
Construction of access road improvements Erection of fish processing and ice making plant The Project could give rise to a small level of physical displacement for some sectors of individual communities
Removal of shelters homes Displacement of boat repair and trading sites for local community
Possible non-voluntary resettlement including vulnerable groups (women children and the elderly)
Adaptation Strategies to climate change
Introduction over time of regulations relating to fishing activity in rivers lakes estuaries lagoons and lsquoareas of upwelling affected by climate change
Measures to combat tackle rising temperature and other climate induced changes should ameliorate environmental impacts
Both beneficial and adverse effects may result from changes in climate (eg faster growth rates from higher water temperature spread of invasive species)
Establishment of exclusion zones ndash oil production and marine protection areas
Restrictions on fishing in oil production areas and marine protection areas
Positive ndash recovery of fish stocks but also potential risks of pollution from oil leaks and human waste
Temporary loss of livelihood for those fishers displaced from lsquotraditionalrsquo fishing grounds
Development of Co-Management System
Creation of 4 pilot Stakeholder ndashbased Fisheries Management Initiatives
Demonstration of practical benefits for the marine environment resulting from elimination of damaging practices
Greater social cohesion and sense of purpose established
61
Type of Activity Description Environmental Significance
Social Significance
Support for PAPs Establishment of enterprise training programmes
Development of criteria for defining Project Affected Persons (PAP) Development of skills training schemes enterprise allowances alternative livelihoods fund
Major benefits for PAPs ndash but scope for misinterpretation mismanagement of programme at local level Jobs created under social significance should be familiar to the fishers ie things they will be willing to do
Developing Compliance Systems
Establishment of enforcement unit and development of facilities and training for participatory coastal surveillance of small-scale fisheries
This component will greatly improve controls over environmentally unfriendly damaging activities
A number of new jobs should be created under this programme
Improvements in fish processing technology
Development of more efficient fish processing plant
This measure should reduce significantly the proportion of fish lost or degraded post harvest Improved fish processing technology will also reduce wood used from the forest as firewood for fish smoking
Potential displacement of vulnerable groups (women children and the elderly)who currently participate in fish drying curing using basic equipment
Construction of fish ponds
Expanding areas of dug-outs and other farm ponds
Small scale impacts on vegetation stream flow
Displacement of existing land users
Catalysing aquaculture development
Encouragement of larger fish farming enterprises Installation of fish cage aquaculture
Localised deterioration in water quality increased nutrients leading to eutrophication potential spread of fish parasites disease
Potential competition with free capture fisheries displacing vulnerable groups in existing fishing villages
62
85 PROPOSED MITIGATION MEASURES AND COST ESTIMATES Mitigation measures The potential environmental and social impacts to be addressed within the context of preparing this Environmental and Social Management Framework are generalized as shown in Table 82 below It is not possible at this time to prepare specific mitigation measures It is expected though that environmental and social assessment studies will be carried out within specific localities as and when required The framework for compensationresettlement (See Chapters 9 and 10) will then be applied incorporating (1) specific institutional arrangements (2) resettlementcompensation eligibility criteria (3) implementation procedures (4) financial responsibilities and (5) monitoring and evaluation plan Livelihood restoration measures Furthermore the livelihood restoration measures will consider issues such as
(1) income levels of affected persons
(2) other non-monetary sources of livelihood
(3) constraints and opportunities for income generation
(4) number of persons not able to revert to previous occupation and
(5) existing skills of affected persons
Table 82 Proposed mitigation measures for some potential impacts
Type of Impact Description of mitigation measures
1 Decommissioning of obsolete industrial vessels
a) A register will be prepared of all industrial vessels that are due to be decommissioned recording the owner and location of each vessel b) A system will be introduced for tracking progress on decommissioning including the means of disposal and measures taken to dispose of all potentially toxic or hazardous materials c) Persons who lose their job or livelihood as a result of a decision to decommission any particular vessel will be entitled to benefit from the skills training schemes enterprise allowances alternative livelihoods fund being developed
2 Plan for fishing capacity reduction
a) A full Social and Environmental Impact Assessment will be carried out on the Plan for fishing capacity reduction and appropriate measures for ameliorating and mitigating adverse effects on affected sectors of the community and PAPs will be incorporated in a revised edition of this Fisheries Environmental and Social Management Framework
63
3 Harbour development and landing site improvements
a) All harbour development proposals will be subject to Environmental and Social Impact Assessment (ESSA) in accordance with EPA Regulations b) Proposals for improvement of individual landing sites will be assessed in accordance with the checklist (832) and submitted to EPA for a ruling on the level of environmental assessment that is required which will depend on the nature of the intended works
4 Adaptation Strategies to climate change
a) An adaptation Strategy shall include proposals for mitigating any impacts on the environment or social welfare of local communities
b) Any strategy for responding to potential effects of climate change on the fisheries sector will be submitted to EPA for review to determine whether an SEA or EIA is required
5 Establishment of exclusion zones ndash oil production and marine protection areas
a) Proposals for restricting access of fishing vessels to oil production areas and marine production areas shall be subject to an Environmental and Social Assessment which shall be submitted for approval to EPA b) In the event that restrictions are likely to adversely affect fishersrsquo livelihoods the provisions set out in 7 below will apply
6 Development of Co-Management System
a) Development of co-management systems will require full cooperation and engagement of all stakeholders In the unlikely event that the provisions of any scheme are challenged by local communities there shall be a right of appeal to the Minister of Food and Agriculture and the Fisheries Commission acting jointly
7 Support for PAPs
Establishment of enterprise training programmes
a) Identification of vulnerable people including women children and the elderly and identification of the cause and impacts of their vulnerability shall be established through direct interviews and procedures to be developed as part of 6 above b) A high priority within the Fisheries and Aquaculture Sector Development Plansrsquo first five year programme will be the development of specific proposals for the establishment of skills training programmes and the establishment of enterprise allowances and an alternative livelihoods fund c) The measures outlined in 7b) above will be targeted specifically at PAPs and vulnerable sectors of the community
8 Developing Compliance Systems
a) All proposals for securing compliance with fisheries regulations shall be subject to review by a fisheries stakeholder committee to be established by the Fisheries Commission with the remit of ensuring that the measures themselves and penalties for failure to comply are commensurate with the ability of offenders to make restitution and do not unfairly penalize vulnerable sectors of the community
9 Improvements in fish processing technology
a) All plans and proposals for the introduction of new fish processing technology shall be published and shall include a statement on the likely impact of the project on existing processors within the local community
64
b) Any members of the public who consider they are unfairly disadvantaged by proposals for the introduction of new technology may apply to the local co-management committee to determine whether or not they fall within the category of PAP (see 6 and 7 above)
10 Construction of fish ponds Proposals for the construction of new fish ponds shall be assessed in accordance with the checklist (see section 832)
11 Catalysing aquaculture development
a) All proposals for aquaculture development shall be in accordance with the provisions laid down in Local Management Plans applying to specific TURFs
65
ii
PROJECT TEAM
Terry Green - Project Director
Peter Jon Nelson ndash Team Leader - Environmental and Social Assessment Consultant
Victoria Wiafe - Project Manager ndash IDF Group Ghana
Dr Andrew Baio ndash International Fisheries Consultant ndash Sierra Leone
Dr Edward Kofi Abban National Fisheries Consultant ndash Ghana CSIR
Audrey Allotey Research Assistant
iii
ACRONYMS
AF Affected Fisheries
CMA Co-management Associations
EIA Environmental Impact Assessment
ESMF Environmental and Social Management Framework
ESIA Environmental and Social Impact Assessment
FC Fisheries Commission
MCF Monitoring Control and Surveillance
MOFA Ministry of Food and Agriculture
MPA Marine Protected Area
NPF National Process Framework
NGO Non-governmental organisation
PAP Person affected by the project
PC Participating Communities
RAP Resettlement Action Plan
RPF Resettlement Policy Framework
TURF Territorial User Rights to Fisheries
WARFP West Africa Regional Fisheries Programme
WB World Bank
ZMGFR Zoning Map of Ghanarsquos Fishery Resources
v
TABLE OF CONTENTS EXECUTIVE SUMMARY 1 PART A ndash ENVIRONMENTAL AND SOCIAL SAFEGUARDS ASSESSMENT AND DRAFT ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK 1 INTRODUCTION 7
2 PLAN AND PROGRAMME DESCRIPTION 11
Part 1 The Draft Fisheries and Aquaculture Sector Development Plan 11 Part 2 The World Bankrsquo Contribution to the Ghana Fisheries Plan 11
3 BASELINE CONDITIONS 15 31 Profile of the Fisheries Industry 15 32 Environmental Conditions 20
4 POLICY AND LEGAL FRAMEWORK FOR ENVIRONMENTAL ISSUES 25 41 World Bank and Other Donorsrsquo Safeguard Policies 25 42 Governance Framework in Ghana 28
5 WORLD BANK SAFEGUARD ISSUES 37
6 ENVIRONMENTAL AND SOCIAL ASSESSMENT OF DRAFT FISHERIES AND AQUACULTURE SECTOR DEVELOPMENT PLAN (FASDP) 45 61 Positive Environmental and Social Impacts 62 Adverse Environmental and Social Impacts 7 ASSESSMENT OF POLICY OPTIONS 53 8 DRAFT ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK 57 PART B NATIONAL PROCESS FRAMEWORK AND DRAFT NATIONAL RESETTLEMENT POLICY 9 DRAFT NATIONAL PROCESS FRAMEWORK 67 10 DRAFT RESETTLEMENT POLICY FRAMEWORK 71 BIBLIOGRAPHY ANNEXES 1 Annex 1 to the Terms of Reference 2 Environmental and Social Evaluation Matrix
1
EXECUTIVE SUMMARY
This report draws together the contents of two separate documents which examine a number of interrelated issues concerned with environmental and social safeguards for the development of the fisheries sector in Ghana
The first document (Part A) contains the Environmental and Social Assessment (ESA) of the Ghana Fisheries and Aquaculture Sector Development Plan (FASDP) together with a draft of the Environmental and Social Management Framework (ESMF) that will be adopted by the Government of Ghana This document is reproduced in Chapters 1-8 of the Composite Report
The second document (Part B) contains the outline structure of Ghanarsquos National Process Framework (NPF) for implementing the design and implementation of local fishery co-managementmaintaining sustainability of local livelihoods and local monitoring of fisheries efforts together with an outline Resettlement Policy Framework (RPF) These elements are covered in Chapters 9-10 of the Composite Report
This Composite Report and its individual components have been prepared on behalf of the Government of Ghana and the World Bank Following review by both parties it will be adopted as part of the framework leading to promotion of the Ghana Fisheries and Aquaculture Sector Development Plan
Chapter 1 of the Report describes the need for environmental and social safeguards in the fisheries sector It notes that the overall aim of FASDP is to improve fish stocks and increase the sustainability of fishing activity which will have long term environmental and social benefits for the Country
Chapter 2 summarises the basic aims of the Ghana Fisheries and Aquaculture Sector Development Plan and proposals for financial and technical aid which are being developed by the World Bank A decision on funding support will be taken by the World Bank in 2011 The World Bank is proposing to support FASDP under four key components These are Good Governance and Sustainable management of the fisheries reduction of illegal fishing increasing the contribution of the marine fish resources to the local economies and assisting with coordination monitoring evaluation and programme management
Chapter 3 provides a baseline description of the current nature and importance of Ghanarsquos marine and inland fisheries which provide 65 of the countries protein requirements and sustain the livelihoods of almost 10 of the Ghanarsquos population Unfortunately however fishing is approaching a crisis In recent years the annual volume of catch has fallen (from in excess of 500000 to under 400000 tonnes) but at the same time fishing effort has increased If it were not for government subsidy the economic returns could no longer be justified since it costs more to catch and land fish than they are actually worth in the market place Fishing activity (principally trawling) is causing substantial damage to the marine environment while illegal methods in the canoe sector including dynamiting and use of chemicals threaten fish stocks and human health
Chapter 4 examines the governance legislative and policy framework under which reforms in the fisheries sector will take place The chapter identifies five World Bank safeguard policies that are potentially triggered by FASDP These are OP 401 Environmental Assessment OP404 Natural Habitats OP 409 Pest Management and OP 411 Physical and Cultural Resources and OP 412 Involuntary Resettlement In most cases the range of projects proposed under FASDP would have minimal impacts under these safeguards but there is nevertheless a need to ensure that adequate
2
protection and mitigation is provided through implementation of an Environmental and Social Management Plan
Chapter 5 considers the four funding components under which the World Bank is proposing to support the Ghana Fisheries and Aquaculture Sector Development Plan These cover
1 Good governance and sustainable management of the fisheries 2 Reduction of illegal fishing 3 Increasing the contribution of the marine fish resources to the local economy and 4 Coordination Monitoring and Evaluation and Program Management The potential for investment to give rise to adverse effects on the environment andor social conditions is reviewed It is concluded that that there are unlikely to be any significant adverse environmental or social effects as a result of the planned investments The only possible exception relates to the effectiveness of measures that are put in place under Sub-Component 12 to support pilot stakeholder-based fishery initiatives The outcome of the overall program will depend heavily on the success of these pilots For this reason it is essential that planning of the pilot initiatives is linked closely with measures for supporting alternative livelihoods and strengthening processing and marketing initiatives under Sub-Components 13 and 14
Chapter 6 provides an analysis of the environmental and social issues raised by the wider fisheries and aquaculture programme and as such it constitutes the Environmental and Social Assessment (ESA) A matrix is used to identify potential interactions between elements of marine and inland fishery capture operations and the natural environment together with possible socio-economic effects A similar matrix is also used to examine the potential for aquaculture development The overall effects of the planned interventions are positive in terms of both environmental and socio-economic gains but there are potentially some adverse social and economic consequences for a limited number of individuals whose livelihoods will be affected by restrictions on access to fishing or from changes in economic conditions affecting the purchase processing and marketing of fish Mitigation measures are considered subsequently in Chapter 8
Chapter 7 briefly considers the possible consequences of taking no action to deal with the declining stocks and profitability of fishing (the do-nothing option A) This is a standard part of the methodology for conducting an Environmental and Social Assessment The conclusions are compared with the alternatives of taking limited action (a lsquoweakrsquo option B) or of implementing the full set of plans and proposals (the lsquooptimumrsquo option C) The comparison includes the conclusion that the fisheries industry is often studied and dealt with in isolation from other parts of the economy However in order for the planned reforms to have maximum beneficial impact a new approach is required to integrated coastal development in which a range of ministries and agencies should be involved
Chapter 8 sets out a draft Environmental and Social Management Framework (ESMF) This picks up areas of risk identified in the ESA Report and proposes remedial action The ESMF notes that the principal goals of government policy are to
bull Improve management of fisheries the conservation of aquatic resources and protection of the natural environment
bull Promote value addition in the fisheries sector and the improvement of livelihoods in fisheries communities
bull Encourage sustainable development of aquaculture
3
bull Improve the services provided to the fisheries sector by the Fisheries Commission and supporting institutions
The Draft ESMF sets out eight specific interlinked actions namely
1) Preparation of local management plans and close surveillance of all new fishing enterprises in deep waters
2) Preparation of environmental protection clauses to be included in all contracts and agreements for physical development work
3) Regular inspection by environmental protection officers of construction work at harbours and landing sites
4) Establishment of community management plans to provide support to those groups and individuals who are adversely affected by any of the measures listed above
5) Creation of community liaison groups to actively support community development alternative livelihoods and conversion to new areas of economic activity for those Fisher families or individual fishers who are adversely impacted
6) Introduction of skills training centres and business advice for small and medium enterprise development
7) Establishment of a coastal development approach drawing on the resources of the ministry of local government agriculture and tourism (others to be added) to coordinate integrated projects and initiatives for economic development linked with the existing coastal zone management plans
8) Creation of a liaison group between the government of Ghana and its international development partners to ensure that investment in the fisheries sector is targeted in the most effective way to deliver plan objectives and avoid duplication of effort
Chapter 9 provides a draft National Process Framework (NPF)) to implement the recommended process framework laid down by the West Africa Regional Fisheries Program (WARFP) which Ghana will become part of This framework explains how eligibility criteria will be employed to determine which settlements qualify as participating communities and what the responsibilities of these communities will be in terms of setting up Co-management Committees (CMCs) and selecting classes of Project Affected People (PAPs) who will be eligible for assistance under national guidelines to be prepared by the Fisheries Commission The ESMP also outlines proposals for income restoration measures in accordance with World Bank guidance as interpreted through the West Africa Regional Fisheries process framework that where open access to fishery resources is restricted for the common good any adversely affected individuals should not be penalized but should receive assistance to restore their livelihoods at least to the extent that they are impacted by the project activities and preferably to an improved state1
1 Extract from Executive Summary Process Framework West African Regionl Fisheries Program (P106063) Cape Verde Liberia Sierra Leone Senegal Commission sous Regionale des Peche Dakar Senegal
Measures are also outlined for conflicts or grievance resolution administrative and legal procedures and monitoring arrangements
ldquoSection V Livelihood Restoration Measures World Bank policy requires that livelihoods be restored at least to the extent that they are impacted directly by project activities and preferably inproved This policy prescription is based on the principle that people who give up most for the public good ndash the PAPs- should not be penalised and impoverished as a result of their loss for the greater good The aim thereopfre is to improve the public good (in this instance marine resources) while also ensuring that those who lose access to resources and income because of restrictions on marine resources are assisted effectively to restore that part of their income that is affected through alternative livelihood measuresrdquo
4
Chapter 10 looks in more detail at specific safeguards relating to possible involuntary relocation of people as a result of the long term fisheries programme It constitutes the Resettlement Policy Framework (RPF) which while not a formal legal requirement of the World Bankrsquos lending policy is nevertheless recommended as good practice
5
PART A ENVIRONMENTAL AND SOCIAL SAFEGUARDS ASSESSMENT
The Environmental and Social Safeguard Assessment comprises bull Three background chapters (1-3) bull Two chapters which deal with assessment of the potential effects of the World Bankrsquos financial
and technical support for the Ghana Fisheries Programme over the initial five years (Chapter 4) and the longer term effects of the overall Fisheries Programme which is expected to run for 10-15 years (Chapter 5)
bull Analysis of the consequences of taking no action (the do-nothing option) in Chapter 7 and bull A draft Environmental and Social Management Framework (Chapter 8)
7
CHAPTER 1 INTRODUCTION
11 INTRODUCTION The government of Ghana is embarking on a Fisheries and Aquaculture Sector Development Plan (FASDP) for restructuring its coastal and inland fisheries The aim is to reverse the current trend whereby fish stocks are increasingly diminishing and the current rate of fishing is unsustainable resulting in less productive fisheries increased costs with declining profitability and the risk of exacerbating nutritional deficiencies and poverty within fishing communities To date the government has enacted legislation (Fisheries Act 2002) prepared policies (2008 updated in 2010) and published regulations (August 2010) but the Ministry of Food and Agriculture and the Fisheries Commission lack the capacity and financial resources to implement all of these initiatives The World Bank is therefore considering a supporting programme of technical assistance and finance which will assist with governance reforms the introduction of licensing for all vessels a reduction in the size of the industrial and semi-industrial fishing fleets and the progressive transfer of fishing activity to the canoe sector International support for Ghanas fishing industry is being coordinated under the West Africa Regional Fisheries Programme (WARFP) This initiative began with four countries Cape Verde Liberia Sierra Leone and Senegal It is now being extended to the following countries Ghana Guinea Guinea Bissau and Gambia A process framework has been developed by the Commission sous Regionale des Peche (Based in Dakar Senegal) to assist member countries of WARFP to prepare their own national process frameworks together with accompanying environmental and social safeguards assessment an environmental management plan and resettlement policy This report has been designed to provide the outline structure and contents for these documents on behalf of the Government of Ghana Another important function of the report is to review the application of the World Banks own Environmental and Social Safeguard policy to the planned investment Both the governments development plan (FASDP) and preparation of the World Banks financial assistance package are at an early stage Consequently this report covers (and can only cover) the broad principles and sets out initial conclusions It will be necessary for further reviews to be undertaken when the Government of Ghanarsquos programme has been developed in more detail Objectives of the Environmental and Social Assessment (ESA) The overall aims of planned interventions in the fisheries industry of Ghana are to improve fish stocks and increase the sustainability of fishing activity which will have long-term environmental and social benefits for the country However the process of introducing change is likely to have some short-term adverse effects on individuals and particularly those who are vulnerable or disadvantaged within poorer fishing communities unless appropriate mitigation measures are taken The purpose of the environmental and social assessment set out in chapter 6 is to identify potential environmental and social impacts both individually and cumulatively and to assess their relative magnitude duration reversibility and importance Based on these findings the draft management framework (see chapter 8) sets out proposals for avoiding or mitigating unacceptable change The process of reforming the fisheries sector will take a number of years and the existing FASDP covers only the first five years With the exception of proposals to scale down the size of the industrial and semi-industrial fishing fleets it is unlikely that major changes will take effect in terms of fishing activity during this five-year period Consequently from the standpoint of the World Banks investment there are likely to be relatively few issues in terms of potential conflict with safeguarding policies Later
8
however significant change is within the fishing industry and particularly onshore processing and marketing of fish products An important element in this report has therefore been the need to define the point at which the banksrsquo responsibilities are seen to terminate and all liabilities are transferred to other supporting donors and the government of Ghana In the short term a reduction in the industrial fleet may lead to the loss of 1000 to 3000 jobs for crew members although in practice most of this work is only part time and many of the vessels that are due to be withdrawn are no longer seaworthy In the longer term it is intended to encourage more selective fishing by limiting open and unfettered access to fish stocks eliminating illegal and damaging processes including dynamiting uncontrolled light fishing and the use of small size monofilament nets and introducing seasonal restrictions to protect breeding cycles The intention is that these measures will be managed jointly by the government and communities through co-management systems At the same time major efforts will be made to reduce the level of post-harvest losses and to increase the value of fish products The expectation is that the number of industrial semi-industrial vessels and canoes will be stabilised at a fixed lower level within five years Once this point is reached and no further licences are granted individual licences will acquire higher values especially as fish stocks recover and the size and value of fish catches starts to increase Subsequently licenses are likely to be sold and traded as less efficient owners drop out of the market and sell on to stronger individuals and companies In terms of onshore activities fish landing processing and marketing will become more efficient and losses will be reduced through use of better smokers freezing and drying equipment Previous studies in West Africa and elsewhere (Bennett et al 2001) have shown that the transition away from open access to a more regulated system of access management can give rise to social risks Specifically older men are likely to be displaced when they are no longer fit enough to withstand the rigours of fishing while a rising number of young men may find it harder to enter a career in fishing Women who currently manage or assist with all areas of buying processing and marketing using traditional clay ovens may also experience competition as new companies and enterprises are established to take advantage of higher profitability in the fishing sector perhaps using better equipment newer technologies and different logistics arrangements or their own transportation Methodology This study has followed the methodology developed within the process framework for the West Africa regional fisheries programme (WARFP) Figure 1 sets out both sequence and timescale for the work
The range of jobs at risk is based on assumptions about the number of vessels and average crew size and cannot be determined with any degree of accuracy until the necessary surveys are undertaken
9
The report is based on three major areas of activity 1 documentary analysis and utilisation of the studies already carried out by the fisheries commission 2 meetings with institutional stakeholders principally affected by the project and 3 Consultations and visits to some of the key fishing villages and communities The planned presentation of findings to Stakeholders has been postponed at the Clientrsquos request due to other pressing commitments in the agriculture and fisheries sectors This presentation will however need to be subsequently undertaken by the Ministry and the Fisheries Commission
11
CHAPTER 2 PLAN AND PROGRAMME DESCRIPTION
INTRODUCTION This chapter is divided into two parts Part 1 sets out the progress which the government Ghana is making in giving effect to the legislation policy and regulations Part 2 describes the proposed programme of assistance being offered by the World Bank with the specific aims of strengthening governance and enforcement systems (Components 1 and 2) and in promoting value addition and reduction of post-harvest losses
PART 1- THE DRAFT FISHERIES AND AQUACULTURE SECTOR DEVELOPMENT PLAN (FASDP) This plan (FASDP) covers the period 2010-2015 It recognises the importance of Ghanarsquos fisheries which generate in the order of US$ 1 billion a year contribute 45 to GDP and indirectly support the livelihoods of 22 million people However through over-fishing and lack of investment in management and value addition the average income per canoe has dropped by up to 40 over the last ten years to the point where it costs as much to fish as the catch is worth By comparison well managed fisheries in other parts of the world are capable of generating economic returns of 30-60 on investment (equivalent to a potential income of US$ 300 million a year for Ghanarsquos fisheries) The Draft FASDP acknowledges that the fishing sector is expected to make a substantial contribution towards doubling the size of the Ghanaian economy by 2015 (GPRS II) as part of the Republic of Ghana Fisheries and Aquaculture Policy Seven targets are set in the draft FASDP 1 Maintaining capture fisheries production at current levels 2amp3 Increasing revenue and profitability in capture fisheries by at least US$ 50 million a year after
five years 4 Increasing aquaculture production to 35000 tonnes a year after five years 5 Retaining Ghana as a landing and processing hub for the West Africa tuna industry 6 Developing fisheries management to allow effective control of all commercial fishing effort in
Ghanaian waters and 7 Ensuring fisheries management costs are sustainable and that the fisheries sector overall make a
fiscal contribution to Government revenues There is an underlying presumption that the canoe sector will remain at the heart of Ghanarsquos fishing industry but the plan is not prescriptive and leaves open the ways of achieving the overall goals At the same time there is an underlying assumption that the long term sustainability of Ghanarsquos fisheries will depend upon discouraging further entry by new operators
PART 2 THE WORLD BANKrsquos CONTRIBUTION TO GHANA FISHERIESPLAN (FASDP)
The essential aim of the World Bankrsquos contribution to FASDP is to provide investment which will build the necessary policy and capacity for effective fisheries management designed to reduce fishing effort while maintaining approximately the same catch levels and to address the impacts of change for fishers
12
and the communities in which they live Based on the currently available draft Project Appraisal Document (PAD) each of the components is now described in turn Component 1 - Good governance and sustainable management of the fisheries This component on good governance comprises four subcomponents which are broken down in turn into a number of separate activities Sub-component 11 developing the capacity rules procedures and practices for good governance of the fisheries Activity 111 reviewing the Fisheries Act and developing regulations to support the Sector Policy and the Fisheries and Aquaculture Sector Development Plan Activity 112 Developing an operational policy to enable implementation of the aquaculture and fisheries sector development plan Activity 11 3 strengthening fisheries management systems and capability (fisheries management plan development aquaculture implementation technical support and training) Activity 114 strengthening fisheries Information Systems (catch recording and monitoring systems statistical analysis and training)
Sub-component 12 introducing fishing rights
Activity 121 developing pilot stakeholder-based fisheries management initiatives around defined fisheries units (ie local management initiatives tighter defining fisheries resources in up to 6 selected Fisher communities) Activity 122 introducing and administering a licensing regime
Subcomponent 13 Adjusting fishing effort and capacity to more sustainable levels marine resource conservation and supporting alternative livelihood opportunities when needed Activity 131 vessel decommissioning Activity 132 compensation packages for crew of decommissioned industrialsemi-industrial vessels Activity 133 alternative livelihood development to incentivise voluntary capacity reduction in the canoe sector Activity 134 marine resources management and conservation
Subcomponent 14 social marketing communication and transparency Activity 141 communications stakeholder consultations and awareness raising programmes to support fishery development Component 2 reduction of illegal fishing Under the West Africa regional fisheries programme subcomponent 21 allows for enabling environment for reduction of illegal fishing These provisions already exist within Ghana and this subcomponent is therefore omitted Subcomponent 22 monitoring control and surveillance (MCS) systems Activity 221 developing compliant systems and capability
13
Component 3 increasing the contribution of the marine fish resources to the local economies Subcomponent 31 product diversificationvalue chain development (freshfrozen producttrade facilitation) Activity 311 landing site development Activity 312 Port development Subcomponent 32 fish product trade infrastructure information and systems - regional minimum integrated trade expansion platform (MITEP) Activity 321 export certification centre development Activity 322 fish processing technology improvements Activity 323 national fisheries advisory group Subcomponent 33 marine and inland aquaculture development Activity 331 space developing aquaculture policy and legal framework Activity 332 improving genetic policy of tilapia fingerlings and breedstock Activity 333 catalysing aquaculture development Component 4 Coordination monitoring and evaluation and program management Subcomponent 41 national implementation subcomponent 42 regional coordination Each of the components sub-components and activities are described in more detail in Chapter 5 which assesses the nature of environmental and social safeguards issues in terms of the World Bankrsquos planned investment
15
CHAPTER 3 BASELINE CONDITIONS
INTRODUCTION This chapter discusses the existing fishery resources of Ghana and describes recent environmental and social trends It identifies some of the pressures that led to the reduction in value of fishing activity and indicates the threats that could be posed if no action is taken in accordance with the planned fisheries and aquaculture program to deal with them FISHERY RESOURCES The continental and coastal waters of Ghana are potentially very rich due to a combination of warm waters and nutrients carried in ocean currents which up-well seasonally on the continental shelf The tonnage of fish caught in marine waters peaked in the mid-1990s around 500000 tonnes and currently averages around 400000 t(See Figure 1) Figure 1 Wild Capture Production in Ghana 1950-2005
2
Table31 Top 10 Species Exported (by value)
1 Canned tuna ($72000000) 2 Fresh tuna ($7200000) 3 Tilapia (no figure available) 4 Miscellaneous dried fish ($1000000) 5 Salmonids frozen ($900000) 6 Marine fish frozen ($600000) 7 Cuttlefish and squid ($600000) 8 Shrimps and prawns ($90000) 9 Sardines ($80000) 10 Crustaceans frozen ($50000) Source FAO Fishstat
The principal catch from deep waters is tuna Industrial vessels registered in Ghana target these species in international waters but also illegally in coastal waters Herring sardine and anchovies are fished in coastal waters by semi-industrial vessels and canoes Table 31 shows the top 10 species of fish exported from Ghana in 2005 PROFILE OF THE FISHING INDUSTRY Fishing is of vital importance in Ghana not only in terms of its contribution to gross domestic product (45 per annum) but because fish provides 65 of the countrys protein In recent years (between 2003-2008) and more specifically in 2004 the countryrsquos annual fish requirement has been estimated to be 882000 tonnes of which the country produces just about half (Tetteh 2007) Of the total population of 22 million people it has been estimated that between 15 and 22 million people are employed or gain their livelihoods from fishing (8-10) Of these there are 210000 men who are directly employed as
2 This figure is the Fisheries Departmentrsquos estimate for 2008
16
fishers The total export of seafood was valued US$824 billion in 2005 Ghanas fishing industry can be divided into three sections marine capture inland capture and aquaculture It can be further analysed by scale of operations distinguishing between industrial semi-industrial and artisanal sectors Marine fisheries Industrial sector Commercial fishing for tuna began in 1962 In the early 1980s Ghana sought to develop an industrial fishing fleet and there are currently 90 industrial trawlers and other vessels which are located in Tema and Takoradi Sekondi The port of Tema was expanded from 1962 to create four main areas the Inner Harbour Outer Harbour Canoe Basin and Commercial Area In 1999 fish landing facilities were improved at the Albert Bosumtwi Sam Fishing Harbour built in Sekondi This harbour is equipped with a cold store an ice-making plant offices a berthing bay for inshore vessels a jetty for canoes and a net drying area Under Ghanaian law more than 50 of the ownership of industrial vessels must be registered with a Ghanaian company or individuals However in practice many vessels are owned by foreign nationals with token Ghanaian ownership Relatively few of these large vessels regularly put to sea and a number are in poor condition or obsolete Nevertheless the impact of trawling activities by Ghanaian registered and foreign owned vessels has been very considerable in coastal waters in recent years Fish landed from industrial vessels is usually transferred directly to Canning factories in Tema and Takoradi Ghana has the largest canning industry in West Africa In the region of 30000 tonnes of tuna are landed In addition to trawling some industrial vessels are engaged in shrimping the use of tuna lines and polls purse seining and demersal trawling Semi-industrial sector in addition to deep sea trawlers there are around 230 large semi-industrial ships propelled by inboard motors which are used for trawling in shallow waters during the off-season and purse seining during upwelling seasons There are currently reported to be 48 bottom trawlers 14 pair trawlers 2 shrimpers 33 pole and line vessels and 10 tuna purse seiners operating from 2 of the 7 landing sites Canoe sector Ghanas artisanal fishing sector is based on between 10000 and 12000 wooden canoes Fifty seven per cent of the fleet is powered by outboard motors supported by paddle and occasionally sail Each Canoe carries a crew of between three and 20 men depending on size and length There are over 334 landing sites along the 550 km coast of Ghana and the majority of fish caught by canoe (180000 tonnes) is returned to these sites accounting for 70 of Ghanarsquos fish production The principal landing sites are at Teshie Jamestown Chorkor Shama Axim Elmina Winneba Mumford Akplabonya Adina Atiteti Abutiakope and more Fishing is undertaken by men but the majority of canoes are owned by women who pre-finance fishing trips (purchasing gear and premixed fuel) and purchase the catch Women also predominate in processing and marketing fish and fish products Only about 20 of fish sold fresh a further 20 is salted and the majority (60) is smoked It is estimated that up to 30 of the catch is spoilt through lack of ice for storage or alternative processing facilities
17
Inland fisheries Water Resources Ghanarsquos inland fishery resources consist of a natural lake( Lake Bosomtwe) and nine major river basins which from east to west of the country are
bull the Volta bull Densu bull Ayensu bull Ochi bull Kakum bull Pra bull Ankobra and bull the Tano
The River Tano forms the border between Ghana and Cote drsquo Ivoire The largest of the rivers is the Volta which drains more than two-thirds of the country through several large tributaries in virtually all regions of the country The Volta river system also incorporates the Volta reservoir generally known as the Volta Lake which has a surface area of around 8400 km2 The Volta lake discharges through the Akosombo dam before flowing through a delta into the Atlantic Ocean The eight other river systems are relatively smaller simpler and open more directly into the Atlantic There are also several reservoirs created on the smaller river systems mainly for potable water production irrigation and flood control These reservoirs irrespective of their primary purposes enhance availability of more permanent aquatic habitable space for fish and therefore support some fisheries Finally with all the river systems opening into the Atlantic there are a series of lagoons and estuaries which act as interfaces between the rivers and the sea These water areas constitute another type of inland water resource for salt and brackish water fishes Inland Fish resources Within the inland water resources of Ghana there are over 150 fish species more than 90 of which are fished for food
In commenting on inland fisheries in Ghana it must be noted that virtually all available information on inland fisheries is obtained from the Volta Lake No national fish production records have been kept on the fisheries of the eight smaller river systems and the lagoons and estuaries Thus the usual statement that inland fish production constitutes about 20 of what the country produces should refer to fish production from the Volta Lake In practice the total inland fish contribution could more realistically be estimated at about 30-35 of national fish production This is a very considerable but understated contribution to national food security and nutrition
Fishing vessels The dominant fishing vessel on the Volta Lake is the canoe the majority of which are built from wooden planks On some other river systems while plank canoes predominate a small number are carved as dug-outs from single tree trunks There is some variety in sizes of the canoes depending on how many planks are used to build the boat and the size of tree trunk used in building a canoe The total number of canoes estimated on the Volta Lake during a survey in 2000 was 24035 On the tributary rivers of the Volta Lake and other river systems in the country the planked canoe is the main vessel used in fishing
18
Fishing gear There are about eleven main kinds of gear used for fishing on the Volta Lake They are Gill Nets Cast Nets Hook and Line Basket and wire mesh traps Winch net Beach seine Bamboo Nifa-nifa Wangara Spears and Atidzas On other rivers in the country Gill nets Cast nets Hook and Line and traps are the fishing gear used On both the lake and rivers the Gill net is the main gear
People Involved In the 2000 frame survey of the Volta Lake conducted by the Fisheries Directorate of Ghana the estimate of fishers on the Volta Lake was put at 71861 Fishers on the lake work in collaboration with a host of fishmongers or handlers who also function as wholesalers for individual fishing groups Assuming that the fisher population on the lake has increased by a modest 3 in the ten years from 1998 to 2010 a fisher population of about 93500 could be considered to be on the Volta Lake now If again it is estimated that number of fishers on rivers in the country were to be a tenth of those on the lake this would put the fisher population on inland waters (apart from the Volta Lake) at about 9350 fishers A very conservative estimate therefore puts the total number of individuals who are directly engaged in inland fishing at over 100000 This excludes all directly associated groups such as fish handlers processors and traders An estimate of secondary fisheries operators such as boat builders out-board motor operators and mechanics as well as bulk salt and fuel wood sellers and those engaged in buying selling and distributing fish would have to be considered in developing estimates for both direct and indirect employment in inland fisheries but the number can be assumed to lie between 125000 and 150000 people
Aquaculture Under Ghanarsquos legal framework aquaculture is defined as ldquoany activity designed to cultivate or farm fish and other aquatic living resourcesrdquo Currently only fin fishes are involved in aquaculture in Ghana
Current culture media and environment Currently fish culture takes place almost exclusively in fresh water in Ghana either in cages brush parks or dugouts Dug-outs are excavations made in floodplains in the savannah parts of the country were water scarcity has been a major hindrance to development in general and food security in particular Dug-outs get filled with flood waters and whatever the water carries during major wet periods of a year in the savannah areas Waters that fill Dug-outs invariably contain fish which are trapped in the Dug-out after the wet period These water bodies are managed until the end of the dry period and the fish are harvested before the next flood period Since the 1960rsquos various strategies to augment fish production from Dug-outs have been developed and tested These involve adding fingerlings of selected fish species to those which are lsquonaturally stockedrsquo in Dug-outs by floods Dug-outs are the major fish culture production approach in the savannah parts of the country which accounts for a little more than half the area of the country The Environment of fish culture Currently fish culture is taking place mainly in freshwater environments Brackish water fish culture and mari-culture activities which will bring lagoons estuaries and the sea into fish culture production have long term potential for development Fishes in culture Fishes being cultivated in Ghana In order of importance are Nile tilapia Oreochromis niloticus the African catfish Clarias gariepinus species of the catfish Heterobranchus and the Bony tongue Heterotis niloticus Scale of Culture Based on level of production fish culture operations can be categorized as follows
bull Large scale commercial where an enterprise produces up to 10000 tonnes per year
19
bull Medium scale commercial where a single enterprise produces between 50 and 500 tonnes bull Small scale commercial where an enterprise produces between one and 20 tonnes and bull Very small scale commercial with productions below 20 tonnes
Fish culture production Cultured fish contribution to national production was officially stated as 9000 tonnes for the year 2009 However informed opinion amongst fish farmers indicates that a figure of between 16000 and 20000 tonnes in 2010 would be closer to reality This statement is based on the facts that most producersrsquo published figures are underestimates several small to medium scale producers are not recorded in official lists and the recording of newly established fish farms has lagged actual establishment especially since 2009 Although cultured production up till 2009 may not have been significant considering a shortfall of about 460000 mt (as recorded in 2004) between captured fish production and national demand this reflected the fact that there were only two large scale commercial producers in the country each of which had had less than ten years of operation Anticipated growth in fish culture production within the next five years is expected to be dramatic as some of the critical challenges of the industry are resolved
CHALLENGES AND PROSPECTS Marine Fisheries The fishing sector is vital for food security and job creation to help alleviate rural poverty in Ghana However the levels of fisheries harvests are generally considered to be close to or to have exceeded the maximum sustained yield Future sustainability in the industry will depend upon the restriction of open access to fisheries and the introduction of management systems which allow fish stocks to recover and the establishment of consistent yields in both marine and inland waters Inland Fisheries Environmental conditions on the Volta Lake constitute the major environmental and social challenges for fisheries its sustainability and profitability In terms of future prospects success will depend heavily on implementation of the lsquoGhana Fisheries and Aquaculture Sector Development Planrsquo and the capacity of the system in Ghana to enforce the Fisheries Regulations passed by parliament in August 2010 Aspects of the Development plan that offers great prospects for the lakes fisheries include the provisions for eventually licensing boats (although the scale of this task should not be underestimated) and measures to involve communities in management of fisheries resources of the Lake
Aquaculture The main challenges facing aquaculture development in Ghana relate to bull The high cost of fish feed (significantly due to its importation from other countries) bull None availability of commercial fish hatcheries as enterprises bull Lack of a nation-wide distribution network for fish seed and cultured fish producers Most
sources of fingerlings are concentrated in one part of the country and since farms all over Ghana obtain their fingerlings individually transportation costs add significantly to overall production costs
bull Now emerging certification and monitoring to check the health and safety of aquaculture processes and products
bull The absence of adequate regulations regarding establishment of an aquaculture enterprise until August 2010 (In the absence of regulations only the large and medium scale commercial farms worked towards conforming to international performance Standards and operational regulations for certification of farms and their products still remain in a draft state)
bull Low national support for research to support expansion and systematic development of aquaculture
20
The prospects for development of aquaculture as an industry in Ghana are good since a number of practical policy and legal frameworks have been put in place to resolve the basic challenges to the industry listed above These include
bull Construction of the first local fish feed plant by an international fish feed company with the expectation of having initial products on the Ghanaian market during 2011
bull A lsquoLarge scale commercial fish farmrsquo with great capacity for fingerling production is shifting emphasis to fish seed production And several localized fish seed producers are expanding operations
bull Distribution strategies by cultured fish producers have started to emerge on a limited scale and are expected to evolve with increasing production as existing commercial farms expand and new ones join in
Now that regulations regarding establishment of aquaculture enterprises have been gazetted there is likely to be a positive response amongst fish farmers of all size categories New operational standards are being prepared which will introduce minimum standards for local certification This should set the stage for preparation of fish culture products and the broadening of choice for consumers while also qualifying Ghanaian producers to enter external markets
ENVIRONMENTAL CONDITIONS The coastal and marine environment a critical zone of influence for this study comprises a 550 km coastline a coastal belt ranging from 1 to 20 km in width and coastal waters extending to 200 nautical mile limit which was established in 1977(under the territorial waters and continental shelf act 1973 as amended by the territorial waters and continental shelf amendment decree 1977) The Coastal Belt The coastal belt accounts for only 65 of the land mass of Ghana but it is one of the most densely settled areas accounting for 25 of the population and80 of the industrial establishments in Ghana Historically the coastal zone was cultivated for coconut (copra) but this industry is in decline Vegetables and other agricultural produce are grown on better soils but the principal economic activities are fishing transportation salt production and sand and stone winning Tourism also offers great potential There is considerable expectation that the discovery of offshore oil and gas deposits will bring new wealth to parts of the coastal corridor However present plans to transfer crude products to tankers at sea and then export them directly will limit industrial activity to a support role A high percentage of industrial and municipal wastes is dumped at landfill sites within the coastal zone which creates pollution risks The coastal belt is generally a low-lying area less than 200 m above sea level Vegetation types reflect the rainfall gradient and consist of coastal shrub and Savannah to Winneba southern marginal forest to the east of Sekondi dry semi-deciduous and moist semi-deciduous forest to the east of Cape Three Points estuary and wet evergreen forest in the extreme south Soils are variable within this area ranging from fertile pockets river valleys to Sandy poorer quality soils close to the sea The Coast The coast line divides into three sections (Ly 1980)
bull West of Cape Three Points this area has a wide and flat beaches backed by coastal lagoons and
21
wave heights are generally low bull Between Cape three points and Tema the coast consists of a series of rock headlands enclosing
shallow bays together with sandbars or spits enclosing coastal lagoons The surf zone is a medium to high energy environment with wave heights often exceeding 1 m South-westerly prevailing winds give rise to longshore drift in an easterly direction
bull Between Tema and Aflao most of the shore is sandy although there are rocky outlets The coastal zone is important internationally in providing feeding roosting and nesting sites for thousands of migratory birds Environmental degradation is significant in Ghana and is recognized in the countryrsquos environmental action plan It contributes to rising poverty levels coupled with poor human health and inadequately planned urbanization which fuel a vicious cycle inhibiting human development The core issues include
bull Domestic sanitation bull Increased urbanization without appropriate infrastructure bull Wetlands and mangrove degradation bull Coastal erosion and bull General biodiversity loss
Briefly each of the above could directly or indirectly adversely influence fisheries and aquaculture separately or together For example in a recently completed study of water quality scenarios of the Volta Lake in relation to fish production as a component of a comprehensive study (The Challenge Program Project of Water amp Food) it was concluded among others that poor sanitation in highly populated fisheries communities adversely influenced water quality to the detriment of fish life and thus fish production With reference to aquaculture the same unsanitary conditions in highly populated shore communities adversely influenced water quality especially in terms of oxygen depletion when lake waters extend to the shore in high water periods This is a situation which has caused fish kills in cages because caged fish cannot escape lsquopollutedrsquo waters Degradation of wetlands and mangroves leads directly to a reduction in their capacities as spawning and nursery zones for both marine and inland water fishes which reduce fish production in both environments The situation outlined above is often contributed to by anthropogenic and industrial pollution due to urbanization without appropriate infrastructure Another issue linking human activity to a deteriorating environment is demonstrated by the encroachment of aquatic weeds on inland waters such as the Volta Lake Weed growth is accelerated by farming reservoir catchments which increases nutrient levels and the building of dams which reduce or cut off intrusion of sea water into rivers Currently as climatic change observable impacts such as floods seem to escape predictions The project could possibly contribute to mitigating against direct and indirect effects of climate change on fishing and aquaculture through investment into climate change orientation and education of fishers and fish farmers to mainly influence reasonable precautions they take Marine waters The continental shelf is relatively narrow projecting out to 25-35 km except in the area of Cape Coast to Salt Pond where it extends to almost 80 kms Sandy and rocky substrates which previously supported coral and seaweeds have been severely affected by former trawling activity which indiscriminately
22
dredges material from the seabed Coastal waters are enriched by freshwater discharges from the relatively small number of rivers and by two seasonal up-wellings which occur between late June and early October (the main upwelling) and January and March (the minor upwelling) The origin and driving mechanisms of these up-wellings are not fully understood and both their location and strength varies from year to year
Lake Volta and other inland water
Major environmental issues on the Volta Lake which might also be considered as challenges to sustainable fisheries on the major inland fisheries resource can be summarised as follows
bull The Volta Lake is known to be low in nutrients It therefore has low standing crops of phytoplankton and zoo plankton to support high fish production
bull The northern segment of the lake together with tributary rivers constitute the spawning and feeding grounds for majority of fish species in the lake during the wet season however these segments are intensely fished during the same period
bull The Volta Lake is divided into eight unequal strata with different distribution of boats per Km2 At the last estimation of carrying capacity in 2000 stratum V and II had the highest (527) and lowest(157) number of boatsKm2 respectively
bull The rate of siltation in the lake is considered to be increasing due to erosion associated with high rates of deforestation
bull A major challenge exists in getting fishers fishing communities and fishing entrepreneurs to understand and comply with fishing regulations aimed at conserving fish and fisheries resources
bull There is a lack of resources studies and research to support fisheries management of the Lake
bull High illiteracy exists amongst lake shore communities
bull Open access to the fish resources of the Lake has been in operation since its formation
bull Declining fish yields are occurring in the lake (468 Kgha in 1976 to 320 Kgha in 2003-MOFA) brought about by the constraints listed above
bull The commonly assumed estimate of potential fish production from the lake of around 75500 mtyr) is considered to be a serious underestimate since Stratum VII alone was estimated to produce 33800mtyr in 1996
bull The policy environment for aquaculture is currently strongly supportive of the industry and related enterprises
bull There is good quality and more than sufficient water to allow some kind of aquaculture to be developed in every region of the country with the Volta lake (about 8400 Km2) as the single most important water unit for fish culture Currently it appears that the free access to the fish resources of the lake has to some extent been applied to establishment of small scale caged fish culture enterprises a situation constituting environmental risk to investments of large scale commercial fish culture establishments in the lake
bull The Volta Lake is low in nutrients (Obeng 1964) resulting in a situation where higher fish yields could be sustained if greater quantities of fish feed were available
23
bull In Ghana the Nile tilapia O niloticus occurred naturally only in the Volta system Due to positive culture characteristics of the fish it has been moved into virtually all other river basins in the country The situation provides opportunities for hybridization of the Nile tilapia with other tilapia species native to the river basin into which the Nile tilapia has been moved
25
CHAPTER 4 POLICY AND LEGAL FRAMEWORK FOR ENVIRONMENTAL AND SOCIAL ISSUES
41 INTRODUCTION
Development and implementation of the Ghana Fisheries and Aquaculture Sector Development Plan and the World Bankrsquos supporting program need to be developed with full regard to existing international conventions national legislation policies and regulations This chapter highlights the main legislative and policy considerations for the protection of the environment natural resources fisheries and social and economic development It begins with reference to the World Bankrsquos safeguard framework and those of other donors This is followed by a section on the governance framework in Ghana
42 WORLD BANK AND OTHER DONORSrsquo SAFEGUARDS POLICIES
The World Bankrsquos safeguard policies exist to ensure that all projects which it finances are developed and implemented on environmentally and socially sound principles A range of different policies exist and these have been carefully considered to ensure that the Ghana Fisheries and Aquaculture Development Sector Development Plan complies with these safeguards All policies have been screened and those that have no bearing on the fisheries programme have been excluded from Table 41 below Table 41 lists policies which could have some applicability to the FASDP even if this interaction might be very slight It is important to stress that the comments in the third column of Table 41 relate to the entirety of the Fisheries and Aquaculture Sector Development Plan whose effects will continue to be experienced long after the World Bankrsquos financial support has been expended Most of the activities in the FASDP will have no effect in relation to safeguard objectives and where there are implications these are likely to occur at precise locations (for example at fish landing sites) rather than throughout the industry Where potential interactions have been noted the necessary mitigating measures are incorporated in the Draft Process Framework
Table 41 World Bank Safeguard Policies in Context
Safeguard Policy
Safeguard Policy Objective Brief Description and relevance to FASDP
OP 401 Environmental Assessment
This policy aims to ensure that Bank-financed projects are environmentally sound and sustainable and that the decision-making process is improved through appropriate analysis of actions and mitigation of their likely environmental impacts This policy is triggered if a project is likely to carry potentially adverse environmental risks and impacts on its area of influence OP 401 covers impacts on the natural environment (air water and land)
The majority of actions planned under FASDP will be beneficial to the marine environment and to inland waters However new construction activities could have impacts and depending on the project and the nature of impacts a range of instruments can be used to ameliorate and mitigate adverse effects while enhancing beneficial effects These include EIA environmental audit risk assessment and environmental management plans (EMP) The need for EIA and EMP is considered in this report
26
OP 404 Natural Habitats
This policy recognizes that conservation of natural habitats is essential to safeguard their unique biodiversity and to maintain environmental services and goods for human society and for long-term sustainable development The Bank therefore supports the protection management and restoration of natural habitats in its project financing as well as policy dialogue and economic and sectoral work Natural habitats comprise many types of terrestrial freshwater coastal and marine ecosystems They include areas lightly modified by human activities but retaining their ecological functions and most native species
This policy is triggered by any project (including any sub-project under a sector investment or financial intermediary) with the potential to cause significant conversion (loss) or degradation of natural habitats whether directly (through construction) or indirectly (through human activities induced by the project) This policy is applicable to the Ghana Fisheries Programme because the project focuses on the integrated management of natural habitats However by screening all proposals under the ESMF any sub-projects that might impact these habitats will not be funded
OP 409 Pest Management
The objective of this project is to (i) promote the use of biological or environmental control and reduce reliance on synthetic chemical pesticides and (ii) strengthen the capacity of the countryrsquos regulatory framework and institutions to promote and support safe effective and environmentally sound pest management
The policy is triggered if (i) procurement of pesticides or pesticide application equipment is envisaged either directly through the project or indirectly through on-lending co-financing or government counterpart funding (ii) the project supports an activity requiring the use of pesticides that may have negative effects on the environment The only instance in which this policy might be triggered by the Ghana Fisheries Programme is if aquatic herbicides or antibiotics were to be used in connection with aquaculture This is most unlikely but can be monitored through the implementation programme
OP 411 Physical Cultural Resources
The policy objective is to assist countries in avoiding or mitigating adverse impacts of development projects on physical cultural resources For the purposes of this policy ldquophysical cultural resourcesrdquo are defined as movable or immovable objects sites structures groups of structures natural features and landscapes that have
Under the Ghana Fisheries Programme construction and rehabilitation activities that could have negative impacts on cultural property will be avoided In the case of discovery of remains national procedures will be applied
27
archaeological paleontological historical architectural religious aesthetic or other cultural significance
OP 412 Involuntary Resettlement
The objective of this policy is to (i) avoid or minimize involuntary resettlement where feasible while exploring all viable alternative project designs (ii) to assist displaced persons in raising their former living standards income-earning capacity and production levels or at least in restoring them (iii) encourage community participation in planning and implementing resettlement and (iv) provide assistance to affected people regardless of the legality of land tenure
The policy covers not only physical relocation but any loss of land or other assets resulting in (i) relocation or loss of shelter (ii) loss of assets or access to assets (iii) loss of income sources or means of livelihood whether or not the affected people must move to another location The activities of the Ghana Fisheries Programme are likely to result in loss of assets or access to assets and loss of income sources or means of livelihood for some groups and individuals The potential for such losses will be carefully scrutinised and compensated for through the National Process Framework and Resettlement Policy Framework described in this report and appropriate procedures will be followed where necessary
Other donors and aid agencies including International and National NGOs play an active role within the fisheries sector in Ghana and their safeguards standards will be observed through operation of the Environmental and Social Safeguards Management Plan
28
43 THE GOVERNANCE FRAMEWORK IN GHANA
The Ministry of Food and Agriculture (MOFA) Preparation of Fisheries laws and policies fall under the responsibilities of the Minister of Food and Agriculture who in turn delegates functions including implementation to a semi-autonomous body the Fisheries Commission
The Fisheries Commission (FC) was established under the Fisheries Commission Act (625 2002) It oversees management regulation and utilisation of the fisheries resources of Ghana drawing on powers set out in the Fisheries Law (PNDC 256 1991) Fisheries Act 625 provided for the establishment of a more robust Fisheries Commission (FC) which is an amalgamation of the erstwhile FC and Department of Fisheries
Ten individuals constitute the Board which is led by a chairman (appointed by the President of Ghana in consultation with the Council of State) supported by three members drawn from the ministries of transport defence and environment There are three representatives from the following parastatal organizations - the Ghana Marine Fishing Officers Association Water Research Institute and Ghana Irrigation Development Authority- and two representatives (one from the artisanal and one from the industrial sections )of the National Fisheries Association of Ghana Finally the tenth member is a person with requisite knowledge of the fishing industry or natural resources renewal management
The day to day work of the Fisheries Commission is undertaken by the Department of Fisheries (DOF) which serves as the implementation secretariat of the Fisheries Commission as stipulated by the Fisheries Act 625 of 2002 Specific tasks that are undertaken by the Department of Fisheries include
bull preparing fishery resource management plans bull developing regulations for the fishing industry bull organizing monitoring surveillance and enforcement for the national fishery resources and
ensuring compliance with national fisheries law and institutionalizing co-management concepts
The MCS Division of the DoF (established under the Fisheries Sub sector Capacity Building project) works in conjunction with the Ghana Navy and undertakes sea patrols to exclude industrial fishing vessels from the 30-metre depth IEZ reserved for artisanal fisheries The MCS also conducts inspection of industrial vessels at the fishing ports of Tema and Takoradi for
bull valid fishing licences bull legality of fishing gear bull skipperrsquos certificate bull log book and crew composition
The MCS undertakes similar functions for inland fisheries on Lake Volta
The Ministry of Local Government and Rural Development (MLGRD) is responsible for managing fishers fish processors and fishery resources at district and sub-district levels which it undertakes through the District Assemblies In 2002 the District Assemblies in collaboration with DoF were mandated to facilitate fishery resource management by
bull helping to form and sustain Community Based Fisheries Management Committees (CBFMCs) bull cooperating with the DoF MCS units bull providing legal and financial support to the CBFMCs and bull approving levies proposed by the CBFMCs
29
Community-Based Fisheries Management Committees are charged with the responsibility of enforcing national fisheries laws at community level as well as initiating and enforcing their own by-laws
44 THE LEGAL FRAMEWORK
441 International Conventions
Ghana has ratified a number of international conventions and treaties which have an important bearing on the state of its marine and inland waters and the condition of the fisheries These are listed in Box 1 below
Box 1 International Conventions treaties and agreements to which Ghana is a signatory 1 International Convention for the Prevention of Pollution of the sea by Oil 21 October 1962 2 Convention on the Africa Migratory Locust 25 May 1962 3 Treaty Banning Nuclear Weapon Tests in the Atmosphere in Outer Space and Under Water 5th August 1963 4 International Convention for the Conservation of Atlantic Tunas 4 May 1966 5 Africa Convention on the Conservation of Nature and Natural Resources 15 September 1968 6 International Convention on Civil Liability for Oil Pollution Damage 29 November 1969 7 International Convention Relating to Intervention on the High Seas in Cases of Oil Pollution Causalities 8 Convention on Wetlands of International Importance Especially as Waterfowl Habitats 2 February 1971 9 Treaty and Prohibition of the Emplacement of Nuclear Weapons of Mass Destruction on the Seabed and the Ocean Floor and in the Subsoil Thereof 11 January 1971 10 International Convention on the Establishment of an International Fund for Compensation of Oil Pollution Damage 18th December 1971 11 Convention Concerning the Protection of World Cultural and Natural Heritage 16 November 1972 12 Convention on International Trade on Endangered Species of Wild Fauna and For a 3 March 1973 13 Convention on the Military or Any other Hostile Use of the Environmental Modification Techniques 10 December 1976 14 Convention on the Conservation of Migratory Species of Wild Animals 23 June 1979 15 Convention for the Cooperation in the Protection and Development of the Marine and Coastal Environment of the West and Central African Region1981(Abidjan Convention) 16 United Nation Convention on the Law of the Sea 10 December 1982 17 Montreal Protocol on Substances that Deplete the Ozone Layer 24 July 1989 18 Convention to Combat Drought and Desertification 19 Framework Convention on Climate Change June 1992 20 Convention on Biological Diversity1992 442 Environmental-Related Conventions Environmentally related conventions ratified by Ghana include
bull International Convention for the Prevention of Pollution of the sea by Oil 21 October 1962
bull Convention on the Africa Migratory Locust 25 May 1962 Treaty Banning Nuclear Weapon Tests in the Atmosphere in Outer Space and Under Water 5th August 1963
bull International Convention for the Conservation of Atlantic Tunas 4 May 1966 bull Africa Convention on the Conservation of Nature and Natural Resources 15 September 1968 bull 992256International Convention on Civil Liability for Oil Pollution Damage 29 November
1969 bull International Convention Relating to Intervention on the High Seas in Cases of Oil
30
Pollution Causalities bull Convention on Wetlands of International Importance Especially as Waterfowl Habitats
2 February 1971 bull Treaty and Prohibition of the Emplacement of Nuclear Weapons of Mass Destruction
on the Seabed and the Ocean Floor and in the Subsoil Thereof 11 January 1971 bull International Convention on the Establishment of an International Fund for
Compensation of Oil Pollution Damage 18th December 1971 bull Convention Concerning the Protection of World Cultural and Natural Heritage 16
November 1972 bull Convention on International Trade on Endangered Species of Wild Fauna and For a 3
March 1973 bull Convention on the Military or Any other Hostile Use of the Environmental
Modification Techniques 10 December 1976 bull Convention on the Conservation of Migratory Species of Wild Animals 23 June 1979 bull Convention for the Cooperation in the Protection and Development of the Marine and
Coastal Environment of the West and Central African Region1981(Abidjan Convention)
bull United Nation Convention on the Law of the Sea 10 December 1982 bull Montreal Protocol on Substances that Deplete the Ozone Layer 24 July 1989 bull Convention to Combat Drought and Desertification bull Framework Convention on Climate Change June 1992 bull Convention on Biological Diversity1992
443 National Legislation
The principal national legislation that affects fisheries in Ghana is listed below
1 Fisheries Regulation 1984 LI 1294 2 Fisheries (Amendment) Regulation 1977 3 Maritime Zones (Delimitation) Law 1986 4 PNDC Law 256 of 1991 5 Fisheries Commission Act of 1993 and 6 Fisheries Act 625 of 2002 7 Fisheries Regulations passed in 2010 LI 1968
Other laws that have relevance to the fisheries sector include
1 Wild Animals Preservation Act 1961 (Act 43) 2 Volta River Development Act 1961 (Act 46) 3 Ghana Water and Sewerage Corporation Act 1965 (Act 310) 4 Oil in Navigable Waters Act 1964 (Act 235) 5 Irrigation Development Authority Decree 1977 (SMCD 85) 6 Minerals and Mining Law 1986 (PNDCL 153) 7 Environmental Protection Agency Act 1994 (Act 490) 8 Ghana Highway Authority Act 1997 (Act 540) 9 Timber Resources Management Act 1998 (Act 547) and 10 Minerals and Mining Act 2006 (Act 703
31
434 Policies A number of Environmental related Policies exist in Ghana however there is no specific policy on the coastal zone These include
bull The National Environment Policy bull National Wetlands Policy bull Agricultural Policy bull Tourism Development Policy bull Land Management Policy bull National Health Policy bull Energy Policy bull Minerals Policy bull Wildlife Conservation Policy
The main thrust and orientation of national policies on the protection management and development of the marine and coastal environment focuses on the following three major areas
bull Integrated coastal zone management and sustainable development bull Marine environmental protection both from land-based activities and from sea-based
activities and bull Sustainable use and conservation of marine living resources (both of the high seas and
under national jurisdiction) Specific plans have been developed to ensure the realization of prudent management of the marine and coastal environment These include
bull Coastal Zone Management Indicative Plan 1990 bull National Environmental Action Plan 1994 bull Draft Integrated Coastal Zone Plan 1998 bull Coastal Zone Profile of Ghana 1998 bull National Oil Spill Contingency Plan with specific reference to the marine environment
2002 bull Environmental sensitivity map of the coastal areas of Ghana 1999 and 2004
Despite the existence of these plans active integration and coordination has been lacking in practice at local level 434 Regulations Though several legislations exist on coastal protection and sustainable development there is no omnibus legislation on the environment Legislation relating to the area include the following
bull Beaches Obstruction Ordinance 1897 (Cap 240) bull The Mineral and Mining Law 1986 (PNDC 153) bull Rivers Ordinance 1903 (Cap 226) bull Land Planning and Soil Conservation Ordinance No 32 of 1953 as Amended by the bull Land Planning and Soil Conservation (Amendment) Act 1957 (No 35 of 1957) bull Maritime Zones (Delimitation) Law 1986 (PNDCL 159) urban planning and
32
bull development bull Town and Country Planning Ordinance (Cap 84) bull Wild Animals Preservation Act Act 235 1964 bull The Towns Ordinance (Cap 86) bull National Building Regulations 1996 (LI 1630) bull Volta River Development Act 1961 bull Fisheries Act 2002 Act 625 bull Fisheries Law 1991 (PNDC 256) bull Fisheries (Amended) Regulations 1977 and 1984
The sustainable use and conservation of marine resources is encouraged through legislation regulations education and awareness creation programmes as well as the enforcement of existing regulations and legislation The legal framework for coastal zones issues and management in the country are contained in the following documents
bull The 1992 constitution bull EPA Act 1994 (Act 490) bull Environmental Assessment Regulations 1999 (LI 1652) bull Local Government Act 1993 (Act 462) bull Environmental Standards and Guidelines bull
In addition there are other specific legal frameworks which include a) The legal framework for Ecosystem Protection which are
bull Wild Animals Preservation Act 1961 (Act 43) bull Wildlife Conservation Regulations 1971 (LI685) bull Wild Reserves Regulations 1971 (LI 740) bull The Wetland Management (Ramsar sites) Regulation 1999 bull Oil in Navigable Waters Act 1964 (Act 235)
b) The legal framework for Fisheries Resources which are bull Fisheries Law 1971 (PNDCL 256) bull Fisheries Act 2000
c) The legal framework for Oil and Gas Industry bull Petroleum (Exploration and production) Law 1984 (PNDCL 84) bull Mineral (Offshore) Regulations 1963 (LI 257) bull Mineral (Oil and Gas) Regulations 1963 (LI 256) bull Oil and Mining Regulations 1957 (LI 221)
d) The legal framework for Tourism Promotion (including coastal tourism) bull Ghana investment Promotion Centre Act 1994 (Act 478) bull Companies Code 1963 (Act 179) bull Free Zone Act 1995 (Act 504) bull Ghana Tourism Board bull Ghana Commission on Culture
44 ACTIVITIES RELATING TO FISHERIES INTERESTS
33
Over the years several activities have been undertaken which are of relevance to protection of the marine environment and fisheries These include
bull Ghana Environmental Resource Management Project in Coastal Wetlands Management Component
bull Gulf of Guinea Large Marine Ecosystem Project bull Fisheries Sub-sector Capacity Building Project bull Establishment of a Protected Wetland Ecosystem on the coast bull Development and Implementation of Oil Spill Contingency Plan bull Monitoring of fish stock levels and associated oceanographic parameters bull Institution of a programme of Monitoring Compliance and Surveillance of the marine
environment bull Development of industrial pollution standards bull Development of University course on Coastal Zone Management bull Increased public education on sound coastal and marine environmental practices
45 RELEVANT INSTITUTIONS With regards to protection management and development of the marine and coastal environment a number of ministries and agencies have been identified as potential stakeholders Those shown with an asterisk are likely to have a particularly active role
bull Ministry of Environment and Science bull The Environmental Protection Agency bull Ministry of Tourism bull Ministry of Local Government and Rural Development bull Ministry of Ports bull District Assemblies bull Ghana Ports and Harbours Authority bull Hydrological Services Department bull Ministry of Food and Agriculture bull Ghana Tourist Board bull Ghana Investment Promotion Centre bull Fisheries Commission Ministry of trade Industries and PSI bull Ministry of Lands and Natural Resources Forestry and Mines bull Ministry of Energy bull Ministry of Health bull Ministry of Education Youth and Sports bull Ministry of Defence bull Ghana Navy bull Ministry of Works and Housing bull Ministry of Women and Childrenrsquos Affairs bull Ministry of Roads and Transport bull National Development Planning Commission bull Council for Scientific and Industrial Research bull Universities and Research Institutions bull Ghana Meteorological Agency bull Town and Country Planning Department bull Water Resources Commission
34
bull Ghana National Petroleum Corporation bull Volta River Authority bull Geological Survey Department bull Forestry Commission (Forestry and Wildlife Division) bull Traditional Rulers and their analogous ministry and laws
Non-Governmental Organisations including Resource Development amp Environmental Oriented Development Organisation
bull Friends of the Earth bull Green Earth bull Wildlife Society bull Recerca e Cooperazione bull Centre for African Wetlands bull And many others
46 PARTNERSHIPS Few formal partnerships exist However support for coastal conservation activities has been received from the private sector as well as from Government Regional and sub-regional collaboration efforts occur at various levels although the level of practical intervention is sometimes limited The science and technology unit of ECOWAS is engaged on issues relating to the management of the Gulf of Guinea In addition a bilateral arrangement exists between Ghana and Cote drsquoIvoire for the management of and datasharing on Sardinella stocks which migrate between the two countries The NEPAD framework among the coastal states of Africa is also developing an interest in marine and coastal management 461 Technical and financial support Ghana receives technical support in the form of training research and project implementation from national bilateral and multi-lateral sources Financing of activities in the sector is primarily supported from the national budget However donor support from both bilateral and multilateral sources has also been obtained for specific programmes such as the World Bank sponsored Fisheries Sub-sector Capacity Building Project UNOPS sponsored Environmental Sensitivity Map for Coastal Areas The Ghana Coastal Wetland Project of the World Bank UNEPrsquos WACAF Programmes and The Darwin Marine Biodiversity of West Africa Project by DFID implemented by the University of Ghana 47 ACTIVITIES Activities undertaken in the country with importance to the marine and coastal area are outlined in the following sections 471 Environment-related activities
bull Ecological Baseline studies of Korle Lagoon (1990-2000) This was carried out to satisfy EIA requirement and as a result pollution status of the lagoon was established
bull Lower Volta Mangrove Project (1996-1998) The objective is to ensure sustainable management of mangrove stands and as such baseline information was documented
bull Save the Seashore Birds Project (1985-1995) This was to protect the seashore birds and as a result conservation awareness of seashore birds was achieved
bull Ghana coastal wetlands management project (1996-1999) In this management of the five coastal wetlands designated as Ramsar Site was put in place
bull Darwin Marine Biodiversity of West Africa Project It is a training project in marine biodiversity assessment
35
472 Social-related activities bull A considerable amount of attention is currently being given to the potential impact of oil-related
development in coastal regions following the publication of Environmental and Social Impact Assessments and Management Plans relating to the Jubilee Oil Field discoveries
473 Coastal area management bull Climate and vulnerability and adaptation assessment on water resources agriculture and the
coastal zone Projects (1997-1999) The projects assessed the vulnerability of the coastal zone to climate change
bull Coastal area management plan for Princess Town (1998-2000) which aimed at providing a plan for the management of Princess Town
bull Keta Sea Defence Project Work (2000-2004) The project aimed at protecting the Keta and its environs from the episodes of erosion faced in the area and also to ensure improvement in environmental and socio-economic conditions at Keta and its immediate surroundings
474 Regional Programmes bull Gulf of Guinea Large Marine Ecosystems Project (1996-1999) The project developed an
effective approach to prevent and control pollution in the Gulf of Guinea and conserve its biodiversity As a result regional institutional capacities were strengthened and also a coastal zone management profile and plans produced
bull UNEP WACAF Projects 1 amp 2 This aims at institutionalising and coordination of national contingency plans monitoring of pollution in the marine environment and control of coastal erosion
475 Other major programmes Other recent programmes and activities in the marine and coastal environments have included
bull Ghana Environmental Resources Management Project in Coastal Wetlands bull Fisheries sub-sector Capacity Building Project bull Establishment of a Protected Wetland Ecosystem on the coast bull Development and Implementation of Oil Spill Contingency Plan bull
48 ONGOING PROJECTS Ghana is currently implementing several projects in the marine and coastal area Some of these projects are linked to developmental projects for which impact assessments are required under the Environmental Assessment Regulations of 1999 Some of the projects are large scale in nature with extensive baseline and monitoring studies like the Keta Sea Defence Project and the West Africa Gas Pipeline project Others are projects being implemented under the auspices of the United Nations agencies and non-governmental organisations include
bull Combating Living Resource Depletion and Coastal Area Degradation in the Guinea Current LME through Ecosystem-based Regional Actions
bull Amansuri Conservation and Integrated Development Project (ACID) bull Danida Water and Sanitation Sector Programme II Support to Integrated Water Resources
Management (IWRM) Component (2004-2008)The Densu Basin aspect of the IWRM component
bull Reduction of Environmental Impact from coastal tourism
bull Bui Hydro Power Project
bull Sea Defence Project at Atorkor
bull Sea Defence Projects in selected towns in the Western Region of Ghana
36
49 CONCLUDING REMARKS
This chapter has highlighted the wide range of conventions laws policies regulations and activities affecting the inland and coastal regions and inland freshwater and marine environment of Ghana It will be important to keep all of these processes and procedures under review as the Fisheries and Aquaculture Sector Development Plan is taken forward to the implementation stage
The main responsibility for ensuring delivery of the Fisheries and Aquaculture Sector Development Programme will rest with the Fisheries Department of the Ministry of Food and Agriculture and the Fisheries Commission supported by the MCS Division and Ghana Navy However a key part of the programme is the development of local co-management arrangements and the Ministry of Local Government and Rural Development and individual District Assemblies will play a key role in helping to form and sustain Community Based Fisheries Management Committees
Over time a significant number of fishermen and individual fish processors are likely to leave the sector as harvesting landing and processing of the catch becomes more efficient Management of these changes especially where disadvantaged and vulnerable sections of the community are affected will need substantial support and investment and a high degree of coordination amongst government ministries and agencies NGOs and international partners to ensure that development assistance is effectively targeted
37
CHAPTER 5 WORLD BANK SAFEGUARD ISSUES
51 INTRODUCTION
The World Bankrsquos proposed funding support to the Government of Ghana covers an initial five yearsrsquo period which could potentially be extended at a later date As the Government of the Republic of Ghana notes in the draft FASDP ldquoimproving the management of the countryrsquos fisheries and ensuring that the impacts on individuals and communities are properly addressed will take 20 or more years to effectrdquo It has therefore been judged important in this report to distinguish between changes that might occur as a direct result of the World Bankrsquos financial assistance thereby triggering the Bankrsquos environmental and social safeguards and changes that could result from longer term adjustments to fisheries and other sectors of Ghanarsquos economy as a result of wider influences by Government other donors and world-wide factors (for example international progress in world trade agreements)
The aim in this chapter is to identify changes which are likely to fall within the purview of the World Banks reputational risks and responsibilities under the first five years of the Fisheries and Aquaculture Sector Development Plan (FASDP) It should be clearly understood that the views expressed are those of the consultancy team and it will be for the World Bankrsquos internal advisors to decide what formal recommendations are made to the World Bank Board
Trends that may emerge in later stages of the implementation of FASDP ndash subsequent to the initial five year period - are discussed in chapter 6
52 THE CURRENT SITUATION
The general status of Ghanarsquos fisheries has been described in Chapters 3 while the legal and policy context has been set out in Chapter 4 The World Bankrsquos investment is being planned specifically to support government policy with the aim of providing a more efficient and better regulated fisheries sector Currently open access is leading to progressive deterioration in fish stocks and lower economic returns Based on many international examples of successful intervention the current proposals (see Chapter 2) are to provide support to introduce formal licensing of all vessels and proper monitoring and control over the seasonal timing and location of fishing activity use of gear and approved nets and self regulation through co-management structures under which the Government and fishing communities will work together to achieve recovery of fish stocks higher income levels for fishers and better returns on catches by reducing post harvest losses and improving processing and marketing operations
53 ANTICIPATED OUTCOMES
It is expected that the proposed reforms and changes will eventually lead to significant improvement in the marine environment restoration of fisheries and enhanced incomes In this respect the provision of grants and loans from the World Bank will bring about major benefits to the economy livelihoods and the environment in the longer term The question that has to be addressed however is - are there likely to be any short term adverse environmental or social consequences from the Bankrsquos own investment strategy Answers are considered in relation to each of the planned components sub-components and activities which are summarised in Table 51 A colour coding and numbering system has been adopted to distinguish those activities that are seen as particularly relevant from the standpoint of the environmental and social assessment Elements highlighted in green are those likely to have positive and beneficial effects on the environment and social conditions those highlighted in orange red have potentially negative or adverse consequences if not handled properly
38
Component 1 Good Governance and Sustainable Management of the Fisheries
Sub-Component 11 seeks to develop the capacity rules procedures and practices that will lead to better governance As such these procedural interventions will have no direct effect on the environment or social conditions of fishing communities However it will be important to ensure that the drafting agencies (government departments and consultants) give due attention to environmental and social objectives during this phase of work Three specific areas are highlighted including undertaking a socio-economic impact assessment with mitigation measures as part of the plan for fishing capacity reduction reviewing the economic and social implications of subsidies and fish import tariffs in the fisheries sector and developing the policy for the development and operation of community-based management networks built around defined fisheries management units
In developing regulations and guidelines it will be important to consider how less able individuals and vulnerable sectors are going to adapt to new systems For example the new regulations on licensing canoes including completion of registration forms the display of registration numbers on vessels and demonstration of basic competence in health and safety standards may prove taxing demands for owners and crew lacking any formal education Similarly legal instruments that are used to remove fuel subsidies or other benefits will need to be carefully explained A socio-economic impact assessment is proposed in the draft PAD to be accompanied by appropriate mitigation measures This assessment should consider amongst other things
bull whether support should be offered and if so under what conditions to any company community or individual who fails to secure a license for a particular class of vessel
bull how the transfer or sale of licenses will be regulated in the wider public interest to ensure transparent processes and avoid the creation of monopolistic and oligopolistic elites
bull who wins and who loses from any planned changes to subsidies and fish import tariff adjustments
bull how the performance of community-based management networks will be judged bull what action will be taken to mitigate the loss of any traditional fishing grounds that become the
subject of marine protected area development or are subject to exclusion zones to protect oil drilling and production platforms
Sub-Component 12 introduces the concept of fishing rights This is to be initiated through a series of four pilot stakeholder-based fishery initiatives and the rolling out of licensing procedures Discussions with stakeholders have made it very clear that the credibility of the entire fisheries policy and programme could be challenged if these pilots do not show positive and constructive ways of moving forward with fisheries reform There is a great deal of distrust for new procedures amongst the fishing communities based on the knowledge that many previous initiatives have failed It is therefore essential that the pilots are led by a strong implementation team are adequately financed and include a credible transparent and inclusive process for debate discussion and consultation Co-operation from the selected communities will be more likely to be achieved if they can see early results in terms of income generating activities
Sub-Component 13 is targeted at adjusting fishing effort and capacity to more sustainable levels and supporting alternative livelihood opportunities These activities are critical in giving effect to the policy decisions that have already been taken to reduce the size of the industrial and semi-industrial fishing fleet and to strengthen the role of the canoe sector Specific measures are proposed for compensating crew members who lose their jobs and for providing training to young men who are willing to transfer
39
out of the fishing sector The scale of this task should not be under-estimated however since there are currently few alternative employment opportunities in the coastal belt for manual workers with low education and skill levels which typify the status of many young fishermen The concept of creating some additional employment with conservation of the coastal littoral and marine ecosystems is strongly supported since this can be linked with development of tourism
Sub-Component 14 is another element that is strongly focused on delivering improved livelihoods with its emphasis on social marketing communication and transparency The focus on stakeholder participation is particularly welcome and should lead to positive response providing it is backed with direct financial support to participating communities
Component 2 - Reduction of Illegal Fishing
There is no Sub-Component 21 within the Ghana Fisheries Programme
Sub-Component 22 aims to develop monitoring control and surveillance (MCS) systems These measures are largely procedural and apart from the relatively small team that will be recruited to operationalise the systems it will have minimal effects on either the environment or social conditions One element that is highlighted in Table 51 relates to provision of facilities and training for participatory coastal surveillance of small-scale fisheries This should have direct and strongly positive benefits for participants and the communities who are enrolled in the training programmes
Component 3 increasing the contribution of the marine fish resources to the local economies
Sub-Component 31 will support the development of basic infrastructure at nine marine fish landing sites and two inland sites The scale of physical construction will be restricted to repair and minor extension of roads and jetties wharves and construction of net mending screens and storage sheds These activities are unlikely to have any significant adverse environmental impacts and should lead to positive social effects
Sub-Component 32 will underpin efforts to improve fish product trade infrastructure information and systems Introduction of new technology for smoking and curing fish and the extension of existing ice preparation plants will start to have positive beneficial effects within the selected communities
Sub-Component 33 provides a modest level of support to marine and inland aquaculture development Aquaculture development should include finalization establishment and enforcement of current draft operational standards to cater for environmental friendliness of fish culture industry for its own survival The main focus will be on developing policy and legal frameworks together with support for stock improvement These measures will have some impact on affected communities in the short term but are clearly aimed at longer term benefits
40
Component 4 Coordination Monitoring and Evaluation and Program Management
Sub-Components 41 and 42 are directed specifically at strengthening the capacity of the Governmentrsquos institutions for national implementation and regional co-ordination As such they will have no direct environmental or social impacts
54 SUMMARY AND CONCLUSIONS
This review of potential environmental and social safeguard issues under the World Bankrsquos targeted programme concludes that there are unlikely to be any significant adverse environmental or social effects as a result of the planned investments
The only possible exception relates to the effectiveness of measures that are put in place under Sub-Component 12 to support pilot stakeholder-based fishery initiatives It is of paramount importance that these pilots are successful and win the confidence of all participants since failure to achieve positive results could set back the entire fisheries programme For this reason it is essential that planning of the pilot initiatives is linked closely with measures for supporting alternative livelihoods and strengthening processing and marketing initiatives under Sub-Components 13 and 14
A number of the planned interventions may have longer term consequences as policies regulations and bye-laws are put into effect but these will be addressed in subsequent work by the Government of Ghana (see Chapter 6)
Table 51 Elements of the World Bank Programme and assessment of potential environmental and social risks
Description of Component Sub-Component and Activities
Measure of Likely Effects
Large (3)
Moderate (2)
Small (1)
None
Beneficial
3
2
1
Adverse
3
2
1
Component 1 Good Governance amp Sustainable Management of the Fisheries
Sub-Component 11 Developing the Capacity Rules Procedures amp Practices for Good Governance of the Fisheries
Reviewing developing programmes and projects designed to support the Fisheries and Aquaculture Development Sector Plan (FASDEP)
Developing an operational policy to enable implementation of the Aquaculture and Fisheries
Plan for fishing capacity reduction (including socio-economic impact assessment and mitigation) 3 2
Commercial vessel and fishing activity licensing plan including allocation criteria rules for transfer of licenses
41
Sector Development Plan and timetable and schedule of license fees
Compliance strategy and plan
Regulations for the management of fisheries including the identification and specification of fisheries management units (ie stocks species areas)
Recommendations for environmental and social safeguards arising from the review of the economic and social implications of subsidies and fish import tariffs in the fisheries sector
3
Policy for the development and operation of community-based management networks built around defined fisheries management units
3
Policy on adaptation strategies for climate change and marine protected area development
2 2
Review of the Ghana Tuna Industry to identify policy or infrastructure needs that threaten Ghanarsquos hub status
Strengthening capture fisheries management systems and capability
Development of fisheries and aquaculture management systems and processes and training
Strengthening fisheries information systems
Installation and operation of fisheries lsquodashboardrsquo database and information collection
Sub-Component 12 Introducing Fishing Rights ($15 M GEF)
Developing 4 pilot Stakeholder-Based Fisheries Management initiatives around defined fisheries units (ie local management initiatives tied to defined fisheries resources including demand-side governance initiatives)
3 2
Introducing and administering a licensing regime (registry establishment training stakeholder education) 2 2
Sub-Component 13 Adjusting Fishing Effort and Capacity to more Sustainable Levels and Supporting Alternative Livelihood Opportunities where Needed
Vessel decommissioning Decommissioning of 60 to 80 industrial trawlers in an environmentally friendly manner
2
Developing alternative livelihoods for crew of decommissioned industrialsemi-industrial
Skills training and small business development training and support for young (18-30 yrs) industrialsemi-industrial crew members willing to transition out of the sector
3
42
vessels
Alternative livelihood development to incentivize voluntary capacity reduction in canoe sector
Alternative livelihoods fund and CDD support to targeted fishing communities
3 2
Marine Resource Conservation
Would include confirming conservation priorities and management regimes and possible provision of support for alternative livelihood options (funded under 133) associated with conservation of coastal littoral and marine ecosystems as well as de facto protected areas associated with the development of oil and gas extraction
3
Sub-Component 14 Social Marketing Communication and Transparency)
Communications stakeholder consultations and awareness raising programs to support fisheries development
3
Component 2 Reduction of Illegal Fishing
Sub-Component 21 does not apply to Ghana
Sub-Component 22 Monitoring Control and Surveillance (MCS) Systems
Developing compliance systems and capability
Development of judicial and policy capacity (training)
Compliance risk assessmentstrategy systems and process development
Enforcement Unit establishment (dedicated facility)
Coastal surveillance stations 2
Facilities and training for participatory coastal surveillance of small-scale fisheries
3
Training for surveillance officers
Operation of aerial and water patrols (vessel leases aerial patrols operational costs patrol vehicles)
Observer program
Compliance education (stakeholder training signage) 1
Upgrademaintenance of the Vessel Monitoring System (VMS)
43
Component 3 Increasing the Contribution of the Marine Fish Resources to the Local Economies
Sub-Component 31 Fish Landing Site Clusters
Product diversificationvalue chain development
9 marine landing sites (basic infrastructure) at Axim Dixcove Fete Jamestown Moree Mumford Senya-Beraku Teshi and Winneba
3 1
2 inland fish landing sites (improved access and berthing infrastructure) at Abotoase and Dzemeni
3 1
2 ports developed (technical studies for 1 new port at Axim and additional berthing space in existing port of Elmina)
3 2
Sub-Component 32 Fish Product Trade Infrastructure Information and Systems
Export certification center development
Fish processing technology improvements 1 1
Technical assistance training and goods to support the National Fisheries Advisory Group
Sub-Component 33 Marine and Inland Aquaculture Development
Developing aquaculture policy and legal framework
Improving genetic quality of Tilapia fingerlings and breedstock
Catalyzing aquaculture development 2
Component 4 Coordination Monitoring and Evaluation and Program Management
Sub-Component 41 National Implementation
Technical assistance for Secretariat to the Fisheries Commission to implement the Project
Sub-Component 42 Regional Coordination
Technical assistance for Regional Coordination Unit at the CSRP support to Fisheries Information Systems (lsquoDashboardrsquo)
45
CHAPTER 6 ENVIRONMENTAL AND SOCIAL ASSESSMENT OF DRAFT FISHERIES AND AQUACULTURE SECTOR DEVELOPMENT PLAN (FASDP)
61 INTRODUCTION
This chapter examines environmental and social issues which need to be considered as part of the overall structural and economic adjustments in Ghanarsquos fisheries sector in the longer term (ie 1-15 years) The assessment deliberately focuses on the longer term because it will take a number of years before current plans start to have their full effect However the same temporal considerations apply to measures that are designed to avoid or mitigate potentially harmful effects so it will be important to start planning remedial actions as part of the joint Government of Ghana and World Bank fisheries programme
611 Key sectors and activities The fishing industry is divided first into marine capture and inland capture fisheries and then aquaculture For each of these three sectors activities are then broken down as follows Marine Capture Fisheries CATEGORY ACTIVITY Stock Management Research Surveillance reef building Harvesting Vessels Gear Skills capacity Marketing Sellers Buyers Processing Fresh fish Sun dried Smoking Freezing Consumers By market sector Support Sectors Boat Canoe Building fuel supply net making kiln construction
refrigeration transport cold store management Legal Enforcement Financing Investment in all elements Infrastructure Harbour wharf processing plant construction
Inland Capture Fisheries CATEGORY ACTIVITY Stock Management Research Surveillance Harvesting Vessels Gear Skills capacity Marketing Sellers Buyers Processing Fresh fish Sun dried Smoking Freezing Support Sectors Boat Canoe Building fuel supply net making kiln construction
refrigeration transport cold store management Legal Enforcement Financing Investment in all elements Infrastructure Harbour wharf processing plant construction
46
Aquaculture and Mariculture CATEGORY ACTIVITY Stock Management Research Surveillance Rearing Roe fingerling production cage -pond rearing Harvesting Vessels Gear Skills capacity Marketing Sellers Buyers Processing Fresh fish Sun dried Smoking Freezing Support Sectors Boat Canoe Building fuel supply cage construction kiln construction
refrigeration transport cold store management Legal Enforcement Financing Investment in all elements Infrastructure Harbour wharf processing plant construction
612 Evaluation Criteria The environmental and social assessment has been undertaken using a matrix (See Annex 114) which analyses the key sectors and activities of the fishing industry and the changes that are envisaged against a set of evaluation criteria Evaluation Criteria are broken down into environmental and social issues distinguishing between beneficial and adverse effects Table 61 below shows the relationship between the groups of criteria Table 61 List of Evaluation Criteria
Environment Social
Positive Adverse Positive Adverse
bull Sea bed rejuvenated
bull Fish stocks recovered
bull Biodiversity enhanced
bull Sea bed degraded
bull Fish stocks reduced
bull Biodiversity reduced
bull Increased harvest (catch volume)
bull Increased catch value
bull Reduced costs of inputs
bull Increased profit
bull Enhanced livelihoods
bull Increased job opportunities
bull Increased local economic multiplier
bull Reduced harvest (catch volume)
bull Reduced catch value
bull Increased costs of inputs
bull Reduced profit
bull Reduced livelihoods
bull Reduced job opportunities
bull Reduced local economic multiplier
The assessment process has involved systematically considering each sectoractivity against the evaluation criteria and recording either positive or negative results by drawing on the judgement of the consultancy specialists The findings are discussed in the paragraphs that follow and are reflected in Table 81 forming part of the Draft Environmental and Social Management Plan
62 DETAILED ASSESSMENT OF THE MARINE AND AQUACULTURE SECTORS
47
TunaIndustrial fleet streamlined and catch per vessel improved At present industrial trawlers have to travel increasing distances to fishing grounds and while the level of catch is remaining broadly static costs are increasing against available economic returns A major shortcoming is lack of investment in re-equipping the aging fishing fleet Many of the 90 vessels that make up this sector are increasingly unseaworthy and need to be replaced with modern trawlers and gear The plan is to buy out owners of substandard vessels by offering compensation at market value based on a full commercial survey Vessels remaining in the fleet will be required to meet exacting standards By reducing the number of old and inefficient boats this will allow each of the remaining vessels to catch a higher proportion of fish The aim is to ensure that Ghana is equipped with the latest vessels and technology in order to preserve the countryrsquos position as the hub of the West African tuna fishing and processing industry (see also the section on canneries below) The effect of these measures on the environment will remain broadly neutral since the same number of fish will be caught Providing other policies and increased surveillance are successful in preventing trawling in inland waters the smaller fleet will have to fish in deep oceanic waters This could potentially transfer some environmental effects on fish populations to other parts of the migratory cycle However this would become part of the international effort through fishing quotas to regulate overall catches Reduction in the size of the industrial fleet will mean that fewer men are needed to crew and service the vessels However in practice many men who work in this sector have only part time work and since a significant percentage of boats no longer put to sea the number of crewmen who will be displaced could be in the range of 1000-30003
It will be important to set up support services for those losing their jobs including retraining and welfare assistance where necessary
Decommissioning will necessitate the sale of seaworthy vessels and their removal from Ghanaian waters Other boats will need to be broken up and scrapped This process requires heavy duty specialized equipment and can release significant quantities of waste oil other toxic chemicals including refrigerants and asbestos used in pipe and engine room cladding Measures will need to be taken to ensure that proper environmental and health safety precautions are taken that decommissioning takes place in properly equipped boatyards and that all waste products are disposed of without environmental risk Cannery sector optimized The Fisheries and Aquaculture Sector Development Plan seeks to maintain the port of Tema as the centre of the Tuna canning industry in Ghana At present a proportion of Ghanarsquos tuna catch is diverted to neighbouring countries due to constraints on processing capacity These limitations include poor port infrastructure ageing equipment and delays in handling catch for some operators due to preferential treatment of vessels that are part-owned by the existing canneries Options for improvement include encouraging upgrading of the capacity of one or more existing canneries or promoting more competition in the processing sector and improving the infrastructure Providing modern building designs and construction techniques are employed and a full environmental assessment is undertaken in accordance with Ghanarsquos EIA regulations there should be no significant environmental or social risks associated with these development possibilities The potential economic benefit resulting from encouraging investment in this sector is very high
Industrial fishing excluded from inshore waters A major longer-term intention under the new fisheries plan (FASDP) is to ensure that existing regulations that restrict industrial and semi-industrial vessels from trawling in inshore waters are properly enforced This requires provision of surveillance
3 Based on an average crew of 20
48
equipment fast patrol vessels capacity building and training and increased staffing within Government agencies together with a full programme of awareness raising training and financial support to local bodies providing self-governance under new co-management services Restriction of industrial trawling in coastal waters will greatly ease pressures on fish stocks and reduce environmental damage to the sea bed In time this should lead to healthier fish population with more fish to be caught by the canoe industry as a result However the task of policing and enforcing regulations will not be easy and will take a number of years to bring into full effect Reduction in fishing activity by inshore trawlers will displace a number of crew members and have a short-term impact on dependent families until these individuals are either absorbed into the canoe fleet or find alternative employment There will therefore be a need to assist genuinely deserving cases where crew members (and their families dependents) need to transfer to other sectors of the economy These measures will only be required in the short term since the anticipated improvement in fish stocks will lead to improved economic performance in the canoe sector within which the bulk of employment exists
Expansion of deep water fisheries The fisheries plan notes that there may be a potential for exploitation or increased exploitation of some deep sea fish resources However the status and population dynamics of some affected species is not well known so any such activities should be scientifically monitored through research and enforced by MCS
Tema Secondi Port infrastructure improvements (equipmentbuildings) Under present conditions the transfer of fish from commercial and industrial vessels to canneries is often delayed by the time taken to offload crates and manouvre within the port area where there are conflicting activities There are also difficulties that arise when vessels owned by the canneries are given priority for landing leaving other boats waiting for many hours which can result in quality deterioration At this stage no details are available about the precise improvements that could be introduced and this will need to be investigated as the fisheries plan is advanced Any environmental effects from infrastructure improvements would be contained within the existing port areas and should be largely positive in reducing fuel (energy) costs and increasing overall efficiency It will however be important to carry out an environmental review of specific development proposals at the design stage especially if these involve plans for any dredging or for altering facilities for discharging waste and disposing of bilge water Both of these activities can have damaging effects on the sea bed (The first through dispersal of silt and sediment and the second through release of potential contaminants) Socio-economic effects from the infrastructure improvements should also be beneficial by removing delays increasing efficiency and reducing waste However there could be some slight reduction in manpower requirements leading to the need for skills retraining Regulating the catch (eg Fishing for selected species reducing juvenile catch to improve value of catch in inshore waters) The fundamental aim of the fisheries plan is to reduce the harmful effects on fish stocks and low economic returns from fish catches by phasing out open access for all and introducing regulation of fishing activity This is to be achieved through close cooperation between the Fisheries Commission Monitoring and Surveillance Unit as well as marine fisheries management division and individual fishing communities working together under a co-management framework The practical details will need to be worked out through each individual co-management group and initially the World Bank is offering to assist in the establishment of four pilots These bodies will test exactly what is required to increase fishersrsquo awareness to build capacity in self regulation and agree on appropriate measures
49
From discussion with stakeholders it is clear that while the broad principles are accepted the majority of the fishing community simply do not believe that the new regulations will be enforced because they have witnessed the failure of so many previous efforts to introduce firm management A major issue for the planned programme is therefore how to change this critical mindset without which very little progress is likely to be made in practice It will be necessary to demonstrate through the pilots that by regulating fishing activity direct benefits will accrue to those participating fishing communities Unfortunately efforts to eliminate harmful practices are unlikely to result in an immediate gain in fish stocks Instead catches are likely to fall in the short term It will therefore be essential to introduce other forms of incentive to cushion short term losses Such measures might include the purchase of new nets and gear for sale at subsidized price to local cooperatives the introduction of cash incentives for canoes demonstrating best practice in the use of gear and nets preservation of the catch using ice and landing and marketing fish of the required size and quality As restriction of open access starts to take effect there should be positive environmental gains in terms of improving fish stocks and less damage of the sea bed On the other hand both fishers and fish processors will feel the adverse temporary effect of reduced catches These social and local economic impacts will need to be monitored closely and assistance provided to help foster alternative livelihoods Cephalopus (Octopus) harvesting encouraged in inshore waters Although most fish species are currently exploited to unacceptably high levels within coastal waters there is a specific opportunity to increase the number of octopus caught by pot fishing This fishery could be developed by both the semi-industrial and canoe sectors Taking octopus in pots would have no adverse physical impacts on the sea bed and could allow very slight expansion in fish species that are preyed on by octopus At the same time it is important to note that there is only limited information on species composition and functioning of selected marine habitats including those of the octopus and more research should be undertaken on this and other species that could be selected for expanded fishing activity There would be clear socio-economic benefits arising from the creation of this new fishery Focusing fish landing at specific landing sites (to improve opportunities for subsequent marketing processing) Plans are already being developed for the enhancement of landing and processing facilities at a number of existing locations along the coast These locations include the construction of harbours at Jamestown and Elmina and development of landing sites at Teshie Ada Axim Dixcove Winneba Mumford SenyaBeraku Gomoa Fetteh Moree Keta Dzemeni and Tapa Abotoase Two sets of issues need to be considered in relation to these improvements all of which affect existing fish landing and processing sites The first is the nature of the physical works and infrastructure and it s potential effect on the marine and terrestrial environment The second is the socio-economic impact Both Elmina and Jamestown are long established fishing ports where the catch is landed either directly onto the beach or shallow wharves It is understood that the primary aim of the improvements will be to increase the area of permanent wharves to make it easier for fish to be offloaded to reduce the time taken in transferring stock to processing plants and to introduce modern technology In the case of other smaller landing sites the scale of improvements will be quite modest involving improvement to existing short stretches of access road the erection of stores for nets and other gear and provision of covered areas to provide shade for net-mending With all proposals for physical infrastructure development there will be a need to consider possible
50
environmental implications Due to the existing nature of these sites there are no major industrial or other commercial processes in the vicinity which could give rise to cumulative impacts including contamination of fish products The scale of plant needed for ice-making and storage and commercial smokeries is commensurate with the artisanal nature of the fishing activity itself and would not give rise to any significant environmental effects on air or water quality Harbour works could potentially involve some small scale dredging (for example the removal of accumulated silt) Where dredging is required it will be important to identify disposal areas (either at sea or on land) where silt can be deposited without damage to sensitive habitats In terms of economic and social impacts it is not clear at this stage who are likely to be the major investors from the private sector although it may be assumed that existing operators who have access to finance will be the main beneficiaries Over time as landing marketing and processing become more efficient it is possible that individuals in the traditional fish smoking sector will lose a significant proportion of their trade as the product switches to fresh or frozen fish sales for transfer to the major urban markets and the beach price for fish rises The draft Ghana fisheries and aquaculture sector development Plan notes in annex 2 that proposed facilities associated with the ports and landing sites may not have support from fish mammies or at least formidable commercial advocates able to resist any opposition from that quarter Inspection of major fish landing areas like Elmina and Sekondi indicates that the existing social and commercial structure of support activities to fish harvesting is very complex and involves almost every member of the community including children and the elderly Such activities include net mending boatbuilding metalworking (for cooking pots stoves and grills supplies (ropes weights tar paint wood) fuel supplies ice crates transport etc Leaders of the fishing community confirmed that in principle the improvements of facilities is welcomed provided that safeguards are in place for those who may lose part or all of their current trading activity through rationalisation Stabilise fleet capacity at a sustainable level Fishery experts consider that there would be significant benefits in reducing the number of canoes from the present 10000-12000 to around 8000-9000 which correlates with the number operating in the mid 1990rsquos when catches were at optimum levels At the same time the Fisheries and Aquaculture Plan stresses that the canoe sector will remain at the heart of the Ghana fishing industry and this has strong political enforcement Consequently there is unlikely to be any enforced reduction in the number of canoes holding licenses and owners of all existing canoes will be able to register their vessels The ability of canoe owners to pay annual licence fees should rise as the overall measures to increase efficiency and improve catches take effect However many people anticipate that over time as the annual cost of holding licenses rises less efficient fishers will sell their licenses (and hence their rights to fish) There may therefore be a de facto reduction in the size of the canoe fleet Even if numbers do not decrease the fleet could be stabilized at its present size by taking a decision not to grant new licences The draft plan discusses the fact that under existing law (section 53) there is a requirement for licenses to be issued on demand (presumably to ensure that Ghanaians are not barred from subsistence fishing) It is argued in the plan that this is a misconception since canoe fishing is largely a commercial activity and it is concluded that lsquoit is therefore essential that the number of canoe licenses can be controlled in future and the legal basis for these controls must be reviewed as a matter of priorityrsquo Decisions of this nature will require the full support of local co-management groups if they are to be effective but committees could easily come under pressure to make exceptions as the coastal population continues to rise and families without alternative livelihoods start lobbying for assistance
51
Accusations of preferential treatment of certain individuals by committees (or committee officials) - possibly linked with suggestions of bribery and corruption -could cause a lot of social tension and start to undermine community trust in the need to work together to improve fisheries management It is therefore most important that the detailed proposals for co-management address this risk and include proposals for mitigating individual hardship of the less advantaged ndash for example by offering voluntary retirement with some form of incentive Influencing marketing to maximise value and reduce post harvest losses (marketing cooperatives strong market structures etc) FAO has estimated that physical post harvest losses in Ghana amount to between 3 and 17 of smoked fish production and 16-20 of gillnet landings The plan notes that introduction of lsquonew generationrsquo small scale fish smokers should be introduced to replace the traditional Chorkor model This would improve fish product quality by eliminating charring of fish over open flames and also protecting operatorsrsquo eyes from the damaging effect of smoke and particles The other major improvement in post harvest value and profits would arise from greater use of ice throughout the supply chain Developing Aquaculture A distinction needs to be made between aquaculture development in ponds and dugouts which are self-contained and fish rearing in cages within open water In the case of farm ponds the commercial rearing of fish is little different to other forms of intensive livestock rearing Providing there is no direct connection to rivers and streams there is little likelihood of interaction between farmed and wild stocks which could spread fish infections and parasites In the case of fish farms in open water (rivers and lakes) there are well known risks of the spread of disease which can arise if overstocking occurs Intensive feeding of large numbers of fish in a confined area can lead to significant deterioration in water quality through the build up of nutrients from wood and waste It is also possible for antibiotics and growth hormones to be dispersed beyond the area of farm cages Genetic modification of farmed fish can also affect the local fish population through escapes All of these issues are capable of being managed and mitigated through good initial planning and design and subsequent maintenance and supervision It will therefore be necessary to develop additional regulations and guidelines specifically for the aquaculture sector 63 SUMMARY OF ENVIRONMENTAL RISKS AND OPPORTUNITIES Review of the full range of governance and development activities suggests that there are no high levels of risk to the marine or littoral environment Successful implementation of the Policy and plan should in fact result in very significant environmental gains Over a timespan of 5-20 years five activities in particular should result in significant improvements in the condition of the sea bed in coastal waters (to a depth of 30 metres) reestablishment of benthic flora and niche habitats increased fish stock and enriched biodiversity These interlinked activities are bull The exclusion of industrial vessels and trawling within coastal waters bull Regulation of fish catches through zonation seasonal control of fishing and standards for vessels
gear bull Stabilisation of the fishing fleet within sustainable harvesting yields bull The adoption of management plans formulated and agreed with full cooperation of local
communities bull The introduction of fishing rights through co-management agreements and bull Well planned consultation and information dissemination throughout the fisheries sector
52
Three components of the development plan have been identified where minor to moderate risk to the physical and biological environment could arise if proper design and implementation standards are not adhered to These relate to bull A potential risk of over-exploitation of new catch species in deep water off the continental shelf if
such development is not accompanied by through research to establish the sustainable yield of target species
bull Strictly localized effects on the physical environment from construction of landing wharves or jetties and other harbour facilities and
bull Infrastructure development at the existing ports of Tema and Takoradi All of these risks are capable of being fully managed by improved governance in the fishing sector and EIA procedures that are well-established in Ghana 64 SUMMARY OF SOCIO-ECONOMIC RISKS AND OPPORTUNITIES Implementation of the Plan Project will bring about substantial change in the fisheries sector and over time increased revenue reduction of post[harvest losses and added value to fish products will bring major economic returns At the same time there will be some individuals who do not participate in direct gains and whose livelihoods could be adversely affected if appropriate safeguarding measures are not put in place The level and extent of these socio-economic risks will be determined by 1 the level of commitment that is entered into by Government and its development partners to
deliver incentives to vulnerable and disadvantaged groups and 2 the speed with which the sector is transformed Rapid change could cause significant
displacement of less-efficient operators especially within the semi-industrial and canoe sector which would have serious ramifications for dependent communities However these effects can be marginalized if the development programme is carefully phased to ensure that alternative livelihood and employment incentives are available
The main risks to local livelihoods relate to the potential for bull loss of employment for crews of unseaworthy obsolete vessels ( from all sectors including
industrial semi-industrial and canoes) that are withdrawn from the fishing fleet because they no longer comply with license regulations
bull the inability of vulnerable and disadvantaged groups including artisanal fishers vendors and individual fish processors in small fishing villages to adjust to new market conditions at selected landing sites
53
CHAPTER 7 ASSESSMENT OF POLICY OPTIONS
71 INTRODUCTION
In order to place the significance of the environmental and social safeguards assessment in context this chapter examines the possible consequences of different policy responses to the existing challenges that face the fisheries sector in Ghana These different policy responses range from a continuation of the status ndashquo effectively a ldquodo-nothingrdquo option (A) to full-scale commitment by all stakeholders to achieving a sustainable fisheries future the ldquoOptimum Solutionrdquo option (C) Various less sustainable outcomes lie in between these two ends of a continuum of policy choices and these are represented by the ldquoWeak Solutionrdquo option (B) 72 OPTION A ndash DO NOTHING Background research and discussion with stakeholders indicates that practical capacity to deliver on clearly stated national goals for sustainable fisheries livelihoods and the reduction of poverty is weak This situation exists despite the fact that Ghana has a strong legal framework for management of its fisheries including the Law Policies and Regulations There is inertia and strong resistance on the part of the majority of players to accept that it is largely their own actions which are responsible for present conditions This in turn leads to the attitude that it is only the lsquoGovernmentrsquo that must act by providing increased subsidies and cushioning the industry against further deterioration in catches Unfortunately there is overwhelming evidence from around the world that where fish stocks are exploited beyond their natural capacity to regenerate this can lead to sudden and near-total collapse Ghana has historically been one of the strongest fisheries in West Africa but the signs are ominous that current levels of exploitation are leading to progressive decreases in annual catches for most species in both marine and inland waters As fishing effort intensifies with an increasing number of all types of vessel using illegal methods and inappropriate gear the distinction between the traditional lsquopeak season and lean season (linked to migration patterns breeding cycles and upwelling) is becoming blurred This is clearly illustrated by a statement from one of Elminarsquos fish mammies ldquowe use to smoke the herring in the peak but now the fishers bring them all the yearrdquo Use of monofilament nets light dynamite and chemicals to obtain fish in the lean season is aggravating a situation where too many boats are chasing too few fish Many fishers blame the reduction of catch on global warming for increasing water temperature the emergent oil and gas industry for restricting access to traditional fishing grounds and industry and urban development for increasing pollution leading to deterioration in water quality Each of these assertions warrants careful consideration but the industry is generally in denial when it comes to the primary fact ndash too many fish including juveniles are caught to allow regeneration of the stock In addition weak governance and lack of resources to ensure implementation of policy result in a situation where the law can be ignored with impunity If collective failure to recognize the seriousness of the current position and lack of commitment to taking hard decisions continues the omens for the future are not good Within a period of 10-15 years fish catches could fall by 50 or more from their present level Impacts on each species would vary and catches of some fish with regional or global migration patterns could remain viable (although this depends on the international conservation effort) On the other hand stocks of fish that provide the mainstay of local food resources herring and sardine could be decimated
54
Complete collapse of all fish species is unlikely but it is possible to envisage a situation where catches might fall below 300000 tonnes a year by 2025 (a reduction of more than 25 from present levels) The most serious consequences would be felt as a result of the social and local economic impact on fishing communities Perhaps 30000 men representing the crews of 3000 canoes and semi industrial boats and 15000 women engaged in marketing and processing would lose their present livelihoods Population migration away from the coast could follow and severe social pressures and local economic hardship This is clearly a ldquoworst caserdquo scenario and if conditions were to worsen gradually it might be possible to intervene but the fact has to be accepted that fish stocks are dynamic and subject to rapid decline (as in the case of the North Sea Herring and Atlantic Cod) 73 OPTION B THE lsquoWEAKrsquo SOLUTION The bleak future painted in Option A is unlikely to arise if the present policy and draft fisheries development plan is followed since these are specifically directed to addressing the major challenges However realization of the aims is dependent upon delivery across a wide range of initiatives by multiple stakeholders The following paragraphs illustrate some of the ways in which delivery of policy objectives might be thwarted These may be summarized as
bull Commitment to good governance and institutional reform bull Political resolve to implement unpopular measures bull Availability of adequate technical and financial resources bull Inertia to necessary changes in fishing practice
Good Governance and Institutional Reform Fundamental reforms are required to fully equip the national fisheries management effort at government level This includes introduction of change management clarification of responsibilities for senior staff rationalization of financial management systems provision of equipment expansion of staff numbers additional training and capacity building As an illustration of the extent of the effort required reference can be made to just one topic area the issue of monitoring control and surveillance At present the Fisheries Commissionrsquos MCS Unit has only 10 employees to oversee implementation of the fisheries regulations throughout Ghana This number will be increased as other institutions are engaged in joint monitoring initiatives but it is obvious that staff numbers and capacity will need to be expanded if regulations on fishing activities are to be affected Enforcement is only one part of the equation however Much greater emphasis will need to be placed on voluntary controls and self-policing at community level through Co-management schemes
Failure to press ahead with governance and institutional reform could delay the process of introducing and registering licenses which represents a crucial first step in moving from open access to managed access in the fisheries sector Given the urgency for action the five years allowed in the current plan for completing the registration process seems very generous Political resolve to implement unpopular measures Stakeholder meetings have confirmed the significance of party political influence as a constraint on achieving progress in the reform of the fisheries sector The offer of incentives like subsidies or the promise of new facilities and equipment are regularly employed by individual politicians to garner votes whether or not these form part of party manifestos Examples have been quoted to the consultants where enabling regulations that might restrict fishing access and prove unpopular amongst the fishing community are quietly ignored and officers may be discouraged from pursuing breaches of the law where the offender has political influence These issues arise with governments of all political
55
persuasions and can apply at all levels from District Assemblies through to regional and national committees
A serious issue with fisheries sector reform is that once actions have been taken to conserve fish stocks it may be years before the full benefits are felt and the results are evident in terms of increased catches This makes it harder for governments to institute unpopular reforms ndash even though these are in the best interests of the nation fishing communities and individuals Fishermen and their families are used to seeing an instant lsquosame day returnrsquo on their catch and are less willing or able than stakeholders in other economic sectors to wait for gradual improvements There is an urgent need to establish cross-party support for the fisheries sector in Ghana and to seek agreements between the main political parties to support established policy and regulations where these are in the interests of delivering sustainable fish stocks Availability of Technical and Financial Resources The process of moving from complete open access to restricted use rights for both marine and inland capture fisheries will take many years to complete Progress will be heavily influenced by the level of political will availability of technical assistance and financial support Existing subsidies (pre-mix fuel and import tariffs) are seen as a deterrent to the encouragement of more efficient business practices However in order to reduce dependencies on these forms of government aid there is also a need to underwrite new forms of economic enterprise by giving help to start-up businesses developing training centres and promoting alternative livelihoods for those individuals who are either displaced or voluntarily give up work in the fisheries sector Inertia to Change Traditional fishing practices are quite literally a way of life for many Ghanaians and have been handed down from generation to generation These traditions are closely interlinked with cultural practices and power and influence resides in specific families with hereditary authority In order to change attitudes and gain acceptance of new approaches to fishing there is a need for a major awareness building and communications strategy targeting in particular the traditional leaders of the fishing industry Without such a plan it will be difficult to break down the internal resistance and inertia towards change The constraints that have been outlined above in relation to the lsquoweakrsquo option are very real and in combination they present a serious barrier to progress It will require real political commitment on the part of Government and strong financial support from international partners to break down these barriers 74 OPTION C THE lsquoOPTIMUMrsquo SOLUTION
The new Draft Fisheries and Aquaculture Plan together with the Act and Policies provide a solid foundation for revitalising the fisheries sector in Ghana However for the reasons discussed in relation to options A and B above there are a number of impediments that need to be overcome In addition to the measures in Option B an ldquoOptimumrdquo solution would also include
A coherent mix of Incentives (carrots) and Regulation (sticks) A top priority in developing existing strategies and plans will be to ensure that measures are in place to offer encouragement and practical assistance to fishers to convert to more sustainable practices while at the same time introducing effective enforcement There are some real challenges with both of these goals
56
New forms of incentive need to be developed to convince boat owners and their crews that it is worth their while to drop illegal methods (dynamiting use of monofilament nets etc) and to reduce the level of fishing effort (through close seasons introduction of restricted zones etc) Without these incentives it is highly unlikely that there will be significant take-up of the fisheries stock management and conservation message Special attention needs to be given to the role of chief fishermen and local community councils in developing effective local policing since it is impractical to rely on a national MCS team to regulate canoe activity in either the marine or inland capture fisheries The national MCS team will have its own responsibilities for policing local and international waters in relation to industrial and semi-industrial sized vessels Integrated Coastal Development The long term success of the fisheries strategy depends upon reducing fishing effort to a level at which catches become both sustainable and profitable for those who remain in the business This in turn requires that those displaced from the industry are able to find gainful employment and livelihoods in other sectors of the economy The fisheries industry is often seen as a separate economic sector which attracts its own funding and support but in order for the necessary reforms to take place these attitudes will need to change A new approach is required to lsquointegrated coastal developmentrsquo following the lessons from integrated rural development Many fishing inland and marine fishing communities are almost wholly dependent on fishing with less than 10 of the local economy being devoted to other industries Reform of the fishing sector therefore requires that as much ndash if not more ndash effort is devoted by government and its international partners to building up complementary economic activities in construction transportation manufacturing food processing environmental conservation and tourism There is a need to explore new state industry partnerships to establish appropriate economic development agencies and to coordinate activities between relevant state institutions ministries and departments under the current decentralisation initiatives with district assemblies taking a prominent role If initiatives of this sort are taken forward it will make the task much easier in persuading conservatively ndashminded fishing communities that they need to simultaneously develop their own entrepreneurial flair and impose their own discipline
57
Chapter 8 DRAFT ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK (ESMF) 81 INTRODUCTION Previous chapters of this report have described the principal environmental and social impacts that are likely to arise from reform in the fisheries sector This chapter sets out the Framework (ESMF) for an Environmental and Social Management Plan (ESMP)The first step has been to outline specific objectives to be achieved through implementation of the ESMF These objectives relate specifically to the issues described in earlier chapters Subsequent sections of the chapter detail the measures which are required to respond to specific areas of environmental and social impact through mitigation and amelioration works They also describe the types and level of environmental monitoring required together with the institutional aspects which need to be improved in order to support the fisheries sector 82 STRATEGY AND OBJECTIVES The basic aim of the environmental and social management plan is to set out guidelines for participatory programs under which members of local fishing communities and civil society in general can become involved in the design and implementation of local fishery co-management maintaining sustainable local livelihoods and achieving local monitoring of fishery efforts The basic principle for future fisheries management is that both marine and inland waters will be demarcated as territories for use rights to fisheries (TURFs) The principal goal of government policy in the fisheries sector is to ensure that the fisheries industry plays an increasingly important role in supporting the growth of the economy as outlined in the Ghana poverty reduction strategy (GPRS II) and the Republic of Ghana fisheries and aquaculture policy This goal will be supported by implementation of the fisheries and aquaculture sector development plan over the next five years In this timescale the aim will be to bull improve management of fisheries the conservation of aquatic resources and protection of the
natural environment bull promote value addition in the fisheries sector and the improvement of livelihoods in fisheries
communities bull encourage sustainable development of aquaculture bull improve the services provided to the fisheries sector by the fisheries commission and supporting
institutions The overall consequences of this strategy and the investments that are being made by the government and its aid partners will be stabilisation of fish stocks and sustainable catch levels a strengthening of the national economy and creation of a more robust fisheries industry with consequent benefits for fishing communities Impact assessment confirms that the result will be significant benefits for the marine environment and local economy However depending on the rate of transition from an open access to a fully regulated market a number of adverse effects could arise unless appropriate mitigation measures are put in place Specific issues which require attention in this plan are listed below bull potential risks of environmental degradation through development of new fishing targets in
deep water
58
bull localised environmental impacts at construction sites bull loss of resources for individual operators due to restricted or controlled access to fishing
grounds bull displacement of labour from crews of vessels that are withdrawn from the industrial and semi-
industrial fleet bull Decommissioning of obsolete industrial vessels may not necessarily lead to recovery of fish
stocks Catch Per Unit Effort (CPUE) may increase This could lead to loss of livelihoods to crew members and the owners of the decommissioned vessels it could increase catch for the few vessels remaining in the system
bull increase production costs due to idling time in closed seasons for fishing bull exclusion of some groups and individuals seeking entrance to the industry following completion
of licensing bull concentration of processing and marketing at selected landing sites leaving Fish Mammies and
their dependents in other smaller fishing communities at an economic disadvantage bull displacement of traditional canoe building and other ancillary support industries by more
efficient and modern methods of construction and the inability of some workers in these trades to train and re-skill in the use of modern materials
bull lack of employment opportunities in alternative sectors The ESMF will set out specific actions to address these concerns through a coordinated set of interlinked proposals as follows 1) Preparation of local management plans and close surveillance of all new fishing enterprises in
deep waters
2) Preparation of environmental protection clauses to be included in all contracts and agreements for physical development work
3) Regular inspection by environmental protection officers of construction work at harbours and landing sites
4) Establishment of community management plans to provide support to those groups and individuals who are adversely affected by any of the measures listed above
5) Creation of community liaison groups to actively support community development alternative livelihoods and conversion to new areas of economic activity for those Fisher families or individual fishers who are adversely impacted
6) Introduction of skills training centres and business advice for small and medium enterprise development
7) Establishment of a coastal development agency drawing on the resources of the ministry of local government agriculture and tourism (others to be added) to coordinate integrated projects and initiatives for economic development linked with the existing coastal zone management plans
8) Creation of a liaison group between the government of Ghana and its international development partners to ensure that investment in the fisheries sector is targeted in the most effective way to deliver plan objectives and avoid duplication of effort
59
83 COMPONENTS OF THE ESMF The following paragraphs provide a summary of the draft ESMF 831 Local Management Plans these plans will be prepared for discrete zones of influence around specified fishing settlements Each plan will contain the same standard list of relevant activities that are to be monitored 832 Environmental Protection In relation to construction activity a checklist will be prepared identifying precisely what level of environmental scrutiny is required for specific types of development This checklist will be prepared by the Fisheries Commission with the support and advice of the Environmental Protection Agency 833 Small-Scale Project Development and Livelihood Restoration a list of potential micro-projects will be prepared by the Fisheries Commission which are regarded as suitable for support funding Demand for these micro-projects will be determined at the local level (ie in villages and fishing communities) Applications for funding of micro-projects will be submitted to the community liaison group for vetting and recommendation based on pre-established eligibility criteria Recommended projects will be referred for formal approval at national level (or through the Coastal Development Agency) 84 POTENTIAL PROJECT IMPACTS ON ASSETS AND LIVELIHOODS The project will have some adverse impacts on assets and livelihoods Therefore provisions will be made under the ESMF to minimize all such impacts including those of socio- economic significance and on any environmentally sensitive sites Provisions are also made in the RPF to accommodate all potential situations including cases that may entail actual displacement and livelihood restoration assistance in accordance with the Governmentrsquos policy and World Bank Policy on Involuntary Resettlement OP412 (see Chapters 9 and 10) The potential social and environmental impacts associated with the project (see Chapters 5 and 6) are summarised in Table 81 and the approach to related mitigation measures is defined in section 85 and Table 82 below
Table 81 Potential Environmental impacts and Social issues
Type of Activity Description Environmental Significance
Social Significance
Decommissioning of obsolete industrial vessels
Scrapping of vessels may release toxic waste (contaminated oils asbestos pipe wrapping and insulation etc)
Contamination of landfill dumps
Related health hazards
Laying off of work force Recovery of fish stocks in areas currently over-fished by trawling
Decommissioning of excessovercapacity would result in loss of livelihoods for crew members
60
Plan for fishing capacity reduction
introduction of licensing system for canoes and enforcement of licensing system for semi industrial vessels
Reduced catch from the decline in the use of prohibited fishing methods (activities) as stipulated in the Fisheries Regulation 2010 (LI1968) eg use of light dynamite etc
Reduction in fishing capacity should lead to significant recovery of fish stocks with long term benefits for all
Short term reduction in fishing effort and increased regulation may prejudice vulnerable sectors (illiterate elderly fishers) Capping on new entrants may remove the safety net opportunity offered by fisheries to would-be fishers who may be without alternative livelihoods
Harbour development and landing site improvements
Construction of access road improvements Erection of fish processing and ice making plant The Project could give rise to a small level of physical displacement for some sectors of individual communities
Removal of shelters homes Displacement of boat repair and trading sites for local community
Possible non-voluntary resettlement including vulnerable groups (women children and the elderly)
Adaptation Strategies to climate change
Introduction over time of regulations relating to fishing activity in rivers lakes estuaries lagoons and lsquoareas of upwelling affected by climate change
Measures to combat tackle rising temperature and other climate induced changes should ameliorate environmental impacts
Both beneficial and adverse effects may result from changes in climate (eg faster growth rates from higher water temperature spread of invasive species)
Establishment of exclusion zones ndash oil production and marine protection areas
Restrictions on fishing in oil production areas and marine protection areas
Positive ndash recovery of fish stocks but also potential risks of pollution from oil leaks and human waste
Temporary loss of livelihood for those fishers displaced from lsquotraditionalrsquo fishing grounds
Development of Co-Management System
Creation of 4 pilot Stakeholder ndashbased Fisheries Management Initiatives
Demonstration of practical benefits for the marine environment resulting from elimination of damaging practices
Greater social cohesion and sense of purpose established
61
Type of Activity Description Environmental Significance
Social Significance
Support for PAPs Establishment of enterprise training programmes
Development of criteria for defining Project Affected Persons (PAP) Development of skills training schemes enterprise allowances alternative livelihoods fund
Major benefits for PAPs ndash but scope for misinterpretation mismanagement of programme at local level Jobs created under social significance should be familiar to the fishers ie things they will be willing to do
Developing Compliance Systems
Establishment of enforcement unit and development of facilities and training for participatory coastal surveillance of small-scale fisheries
This component will greatly improve controls over environmentally unfriendly damaging activities
A number of new jobs should be created under this programme
Improvements in fish processing technology
Development of more efficient fish processing plant
This measure should reduce significantly the proportion of fish lost or degraded post harvest Improved fish processing technology will also reduce wood used from the forest as firewood for fish smoking
Potential displacement of vulnerable groups (women children and the elderly)who currently participate in fish drying curing using basic equipment
Construction of fish ponds
Expanding areas of dug-outs and other farm ponds
Small scale impacts on vegetation stream flow
Displacement of existing land users
Catalysing aquaculture development
Encouragement of larger fish farming enterprises Installation of fish cage aquaculture
Localised deterioration in water quality increased nutrients leading to eutrophication potential spread of fish parasites disease
Potential competition with free capture fisheries displacing vulnerable groups in existing fishing villages
62
85 PROPOSED MITIGATION MEASURES AND COST ESTIMATES Mitigation measures The potential environmental and social impacts to be addressed within the context of preparing this Environmental and Social Management Framework are generalized as shown in Table 82 below It is not possible at this time to prepare specific mitigation measures It is expected though that environmental and social assessment studies will be carried out within specific localities as and when required The framework for compensationresettlement (See Chapters 9 and 10) will then be applied incorporating (1) specific institutional arrangements (2) resettlementcompensation eligibility criteria (3) implementation procedures (4) financial responsibilities and (5) monitoring and evaluation plan Livelihood restoration measures Furthermore the livelihood restoration measures will consider issues such as
(1) income levels of affected persons
(2) other non-monetary sources of livelihood
(3) constraints and opportunities for income generation
(4) number of persons not able to revert to previous occupation and
(5) existing skills of affected persons
Table 82 Proposed mitigation measures for some potential impacts
Type of Impact Description of mitigation measures
1 Decommissioning of obsolete industrial vessels
a) A register will be prepared of all industrial vessels that are due to be decommissioned recording the owner and location of each vessel b) A system will be introduced for tracking progress on decommissioning including the means of disposal and measures taken to dispose of all potentially toxic or hazardous materials c) Persons who lose their job or livelihood as a result of a decision to decommission any particular vessel will be entitled to benefit from the skills training schemes enterprise allowances alternative livelihoods fund being developed
2 Plan for fishing capacity reduction
a) A full Social and Environmental Impact Assessment will be carried out on the Plan for fishing capacity reduction and appropriate measures for ameliorating and mitigating adverse effects on affected sectors of the community and PAPs will be incorporated in a revised edition of this Fisheries Environmental and Social Management Framework
63
3 Harbour development and landing site improvements
a) All harbour development proposals will be subject to Environmental and Social Impact Assessment (ESSA) in accordance with EPA Regulations b) Proposals for improvement of individual landing sites will be assessed in accordance with the checklist (832) and submitted to EPA for a ruling on the level of environmental assessment that is required which will depend on the nature of the intended works
4 Adaptation Strategies to climate change
a) An adaptation Strategy shall include proposals for mitigating any impacts on the environment or social welfare of local communities
b) Any strategy for responding to potential effects of climate change on the fisheries sector will be submitted to EPA for review to determine whether an SEA or EIA is required
5 Establishment of exclusion zones ndash oil production and marine protection areas
a) Proposals for restricting access of fishing vessels to oil production areas and marine production areas shall be subject to an Environmental and Social Assessment which shall be submitted for approval to EPA b) In the event that restrictions are likely to adversely affect fishersrsquo livelihoods the provisions set out in 7 below will apply
6 Development of Co-Management System
a) Development of co-management systems will require full cooperation and engagement of all stakeholders In the unlikely event that the provisions of any scheme are challenged by local communities there shall be a right of appeal to the Minister of Food and Agriculture and the Fisheries Commission acting jointly
7 Support for PAPs
Establishment of enterprise training programmes
a) Identification of vulnerable people including women children and the elderly and identification of the cause and impacts of their vulnerability shall be established through direct interviews and procedures to be developed as part of 6 above b) A high priority within the Fisheries and Aquaculture Sector Development Plansrsquo first five year programme will be the development of specific proposals for the establishment of skills training programmes and the establishment of enterprise allowances and an alternative livelihoods fund c) The measures outlined in 7b) above will be targeted specifically at PAPs and vulnerable sectors of the community
8 Developing Compliance Systems
a) All proposals for securing compliance with fisheries regulations shall be subject to review by a fisheries stakeholder committee to be established by the Fisheries Commission with the remit of ensuring that the measures themselves and penalties for failure to comply are commensurate with the ability of offenders to make restitution and do not unfairly penalize vulnerable sectors of the community
9 Improvements in fish processing technology
a) All plans and proposals for the introduction of new fish processing technology shall be published and shall include a statement on the likely impact of the project on existing processors within the local community
64
b) Any members of the public who consider they are unfairly disadvantaged by proposals for the introduction of new technology may apply to the local co-management committee to determine whether or not they fall within the category of PAP (see 6 and 7 above)
10 Construction of fish ponds Proposals for the construction of new fish ponds shall be assessed in accordance with the checklist (see section 832)
11 Catalysing aquaculture development
a) All proposals for aquaculture development shall be in accordance with the provisions laid down in Local Management Plans applying to specific TURFs
65
iii
ACRONYMS
AF Affected Fisheries
CMA Co-management Associations
EIA Environmental Impact Assessment
ESMF Environmental and Social Management Framework
ESIA Environmental and Social Impact Assessment
FC Fisheries Commission
MCF Monitoring Control and Surveillance
MOFA Ministry of Food and Agriculture
MPA Marine Protected Area
NPF National Process Framework
NGO Non-governmental organisation
PAP Person affected by the project
PC Participating Communities
RAP Resettlement Action Plan
RPF Resettlement Policy Framework
TURF Territorial User Rights to Fisheries
WARFP West Africa Regional Fisheries Programme
WB World Bank
ZMGFR Zoning Map of Ghanarsquos Fishery Resources
v
TABLE OF CONTENTS EXECUTIVE SUMMARY 1 PART A ndash ENVIRONMENTAL AND SOCIAL SAFEGUARDS ASSESSMENT AND DRAFT ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK 1 INTRODUCTION 7
2 PLAN AND PROGRAMME DESCRIPTION 11
Part 1 The Draft Fisheries and Aquaculture Sector Development Plan 11 Part 2 The World Bankrsquo Contribution to the Ghana Fisheries Plan 11
3 BASELINE CONDITIONS 15 31 Profile of the Fisheries Industry 15 32 Environmental Conditions 20
4 POLICY AND LEGAL FRAMEWORK FOR ENVIRONMENTAL ISSUES 25 41 World Bank and Other Donorsrsquo Safeguard Policies 25 42 Governance Framework in Ghana 28
5 WORLD BANK SAFEGUARD ISSUES 37
6 ENVIRONMENTAL AND SOCIAL ASSESSMENT OF DRAFT FISHERIES AND AQUACULTURE SECTOR DEVELOPMENT PLAN (FASDP) 45 61 Positive Environmental and Social Impacts 62 Adverse Environmental and Social Impacts 7 ASSESSMENT OF POLICY OPTIONS 53 8 DRAFT ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK 57 PART B NATIONAL PROCESS FRAMEWORK AND DRAFT NATIONAL RESETTLEMENT POLICY 9 DRAFT NATIONAL PROCESS FRAMEWORK 67 10 DRAFT RESETTLEMENT POLICY FRAMEWORK 71 BIBLIOGRAPHY ANNEXES 1 Annex 1 to the Terms of Reference 2 Environmental and Social Evaluation Matrix
1
EXECUTIVE SUMMARY
This report draws together the contents of two separate documents which examine a number of interrelated issues concerned with environmental and social safeguards for the development of the fisheries sector in Ghana
The first document (Part A) contains the Environmental and Social Assessment (ESA) of the Ghana Fisheries and Aquaculture Sector Development Plan (FASDP) together with a draft of the Environmental and Social Management Framework (ESMF) that will be adopted by the Government of Ghana This document is reproduced in Chapters 1-8 of the Composite Report
The second document (Part B) contains the outline structure of Ghanarsquos National Process Framework (NPF) for implementing the design and implementation of local fishery co-managementmaintaining sustainability of local livelihoods and local monitoring of fisheries efforts together with an outline Resettlement Policy Framework (RPF) These elements are covered in Chapters 9-10 of the Composite Report
This Composite Report and its individual components have been prepared on behalf of the Government of Ghana and the World Bank Following review by both parties it will be adopted as part of the framework leading to promotion of the Ghana Fisheries and Aquaculture Sector Development Plan
Chapter 1 of the Report describes the need for environmental and social safeguards in the fisheries sector It notes that the overall aim of FASDP is to improve fish stocks and increase the sustainability of fishing activity which will have long term environmental and social benefits for the Country
Chapter 2 summarises the basic aims of the Ghana Fisheries and Aquaculture Sector Development Plan and proposals for financial and technical aid which are being developed by the World Bank A decision on funding support will be taken by the World Bank in 2011 The World Bank is proposing to support FASDP under four key components These are Good Governance and Sustainable management of the fisheries reduction of illegal fishing increasing the contribution of the marine fish resources to the local economies and assisting with coordination monitoring evaluation and programme management
Chapter 3 provides a baseline description of the current nature and importance of Ghanarsquos marine and inland fisheries which provide 65 of the countries protein requirements and sustain the livelihoods of almost 10 of the Ghanarsquos population Unfortunately however fishing is approaching a crisis In recent years the annual volume of catch has fallen (from in excess of 500000 to under 400000 tonnes) but at the same time fishing effort has increased If it were not for government subsidy the economic returns could no longer be justified since it costs more to catch and land fish than they are actually worth in the market place Fishing activity (principally trawling) is causing substantial damage to the marine environment while illegal methods in the canoe sector including dynamiting and use of chemicals threaten fish stocks and human health
Chapter 4 examines the governance legislative and policy framework under which reforms in the fisheries sector will take place The chapter identifies five World Bank safeguard policies that are potentially triggered by FASDP These are OP 401 Environmental Assessment OP404 Natural Habitats OP 409 Pest Management and OP 411 Physical and Cultural Resources and OP 412 Involuntary Resettlement In most cases the range of projects proposed under FASDP would have minimal impacts under these safeguards but there is nevertheless a need to ensure that adequate
2
protection and mitigation is provided through implementation of an Environmental and Social Management Plan
Chapter 5 considers the four funding components under which the World Bank is proposing to support the Ghana Fisheries and Aquaculture Sector Development Plan These cover
1 Good governance and sustainable management of the fisheries 2 Reduction of illegal fishing 3 Increasing the contribution of the marine fish resources to the local economy and 4 Coordination Monitoring and Evaluation and Program Management The potential for investment to give rise to adverse effects on the environment andor social conditions is reviewed It is concluded that that there are unlikely to be any significant adverse environmental or social effects as a result of the planned investments The only possible exception relates to the effectiveness of measures that are put in place under Sub-Component 12 to support pilot stakeholder-based fishery initiatives The outcome of the overall program will depend heavily on the success of these pilots For this reason it is essential that planning of the pilot initiatives is linked closely with measures for supporting alternative livelihoods and strengthening processing and marketing initiatives under Sub-Components 13 and 14
Chapter 6 provides an analysis of the environmental and social issues raised by the wider fisheries and aquaculture programme and as such it constitutes the Environmental and Social Assessment (ESA) A matrix is used to identify potential interactions between elements of marine and inland fishery capture operations and the natural environment together with possible socio-economic effects A similar matrix is also used to examine the potential for aquaculture development The overall effects of the planned interventions are positive in terms of both environmental and socio-economic gains but there are potentially some adverse social and economic consequences for a limited number of individuals whose livelihoods will be affected by restrictions on access to fishing or from changes in economic conditions affecting the purchase processing and marketing of fish Mitigation measures are considered subsequently in Chapter 8
Chapter 7 briefly considers the possible consequences of taking no action to deal with the declining stocks and profitability of fishing (the do-nothing option A) This is a standard part of the methodology for conducting an Environmental and Social Assessment The conclusions are compared with the alternatives of taking limited action (a lsquoweakrsquo option B) or of implementing the full set of plans and proposals (the lsquooptimumrsquo option C) The comparison includes the conclusion that the fisheries industry is often studied and dealt with in isolation from other parts of the economy However in order for the planned reforms to have maximum beneficial impact a new approach is required to integrated coastal development in which a range of ministries and agencies should be involved
Chapter 8 sets out a draft Environmental and Social Management Framework (ESMF) This picks up areas of risk identified in the ESA Report and proposes remedial action The ESMF notes that the principal goals of government policy are to
bull Improve management of fisheries the conservation of aquatic resources and protection of the natural environment
bull Promote value addition in the fisheries sector and the improvement of livelihoods in fisheries communities
bull Encourage sustainable development of aquaculture
3
bull Improve the services provided to the fisheries sector by the Fisheries Commission and supporting institutions
The Draft ESMF sets out eight specific interlinked actions namely
1) Preparation of local management plans and close surveillance of all new fishing enterprises in deep waters
2) Preparation of environmental protection clauses to be included in all contracts and agreements for physical development work
3) Regular inspection by environmental protection officers of construction work at harbours and landing sites
4) Establishment of community management plans to provide support to those groups and individuals who are adversely affected by any of the measures listed above
5) Creation of community liaison groups to actively support community development alternative livelihoods and conversion to new areas of economic activity for those Fisher families or individual fishers who are adversely impacted
6) Introduction of skills training centres and business advice for small and medium enterprise development
7) Establishment of a coastal development approach drawing on the resources of the ministry of local government agriculture and tourism (others to be added) to coordinate integrated projects and initiatives for economic development linked with the existing coastal zone management plans
8) Creation of a liaison group between the government of Ghana and its international development partners to ensure that investment in the fisheries sector is targeted in the most effective way to deliver plan objectives and avoid duplication of effort
Chapter 9 provides a draft National Process Framework (NPF)) to implement the recommended process framework laid down by the West Africa Regional Fisheries Program (WARFP) which Ghana will become part of This framework explains how eligibility criteria will be employed to determine which settlements qualify as participating communities and what the responsibilities of these communities will be in terms of setting up Co-management Committees (CMCs) and selecting classes of Project Affected People (PAPs) who will be eligible for assistance under national guidelines to be prepared by the Fisheries Commission The ESMP also outlines proposals for income restoration measures in accordance with World Bank guidance as interpreted through the West Africa Regional Fisheries process framework that where open access to fishery resources is restricted for the common good any adversely affected individuals should not be penalized but should receive assistance to restore their livelihoods at least to the extent that they are impacted by the project activities and preferably to an improved state1
1 Extract from Executive Summary Process Framework West African Regionl Fisheries Program (P106063) Cape Verde Liberia Sierra Leone Senegal Commission sous Regionale des Peche Dakar Senegal
Measures are also outlined for conflicts or grievance resolution administrative and legal procedures and monitoring arrangements
ldquoSection V Livelihood Restoration Measures World Bank policy requires that livelihoods be restored at least to the extent that they are impacted directly by project activities and preferably inproved This policy prescription is based on the principle that people who give up most for the public good ndash the PAPs- should not be penalised and impoverished as a result of their loss for the greater good The aim thereopfre is to improve the public good (in this instance marine resources) while also ensuring that those who lose access to resources and income because of restrictions on marine resources are assisted effectively to restore that part of their income that is affected through alternative livelihood measuresrdquo
4
Chapter 10 looks in more detail at specific safeguards relating to possible involuntary relocation of people as a result of the long term fisheries programme It constitutes the Resettlement Policy Framework (RPF) which while not a formal legal requirement of the World Bankrsquos lending policy is nevertheless recommended as good practice
5
PART A ENVIRONMENTAL AND SOCIAL SAFEGUARDS ASSESSMENT
The Environmental and Social Safeguard Assessment comprises bull Three background chapters (1-3) bull Two chapters which deal with assessment of the potential effects of the World Bankrsquos financial
and technical support for the Ghana Fisheries Programme over the initial five years (Chapter 4) and the longer term effects of the overall Fisheries Programme which is expected to run for 10-15 years (Chapter 5)
bull Analysis of the consequences of taking no action (the do-nothing option) in Chapter 7 and bull A draft Environmental and Social Management Framework (Chapter 8)
7
CHAPTER 1 INTRODUCTION
11 INTRODUCTION The government of Ghana is embarking on a Fisheries and Aquaculture Sector Development Plan (FASDP) for restructuring its coastal and inland fisheries The aim is to reverse the current trend whereby fish stocks are increasingly diminishing and the current rate of fishing is unsustainable resulting in less productive fisheries increased costs with declining profitability and the risk of exacerbating nutritional deficiencies and poverty within fishing communities To date the government has enacted legislation (Fisheries Act 2002) prepared policies (2008 updated in 2010) and published regulations (August 2010) but the Ministry of Food and Agriculture and the Fisheries Commission lack the capacity and financial resources to implement all of these initiatives The World Bank is therefore considering a supporting programme of technical assistance and finance which will assist with governance reforms the introduction of licensing for all vessels a reduction in the size of the industrial and semi-industrial fishing fleets and the progressive transfer of fishing activity to the canoe sector International support for Ghanas fishing industry is being coordinated under the West Africa Regional Fisheries Programme (WARFP) This initiative began with four countries Cape Verde Liberia Sierra Leone and Senegal It is now being extended to the following countries Ghana Guinea Guinea Bissau and Gambia A process framework has been developed by the Commission sous Regionale des Peche (Based in Dakar Senegal) to assist member countries of WARFP to prepare their own national process frameworks together with accompanying environmental and social safeguards assessment an environmental management plan and resettlement policy This report has been designed to provide the outline structure and contents for these documents on behalf of the Government of Ghana Another important function of the report is to review the application of the World Banks own Environmental and Social Safeguard policy to the planned investment Both the governments development plan (FASDP) and preparation of the World Banks financial assistance package are at an early stage Consequently this report covers (and can only cover) the broad principles and sets out initial conclusions It will be necessary for further reviews to be undertaken when the Government of Ghanarsquos programme has been developed in more detail Objectives of the Environmental and Social Assessment (ESA) The overall aims of planned interventions in the fisheries industry of Ghana are to improve fish stocks and increase the sustainability of fishing activity which will have long-term environmental and social benefits for the country However the process of introducing change is likely to have some short-term adverse effects on individuals and particularly those who are vulnerable or disadvantaged within poorer fishing communities unless appropriate mitigation measures are taken The purpose of the environmental and social assessment set out in chapter 6 is to identify potential environmental and social impacts both individually and cumulatively and to assess their relative magnitude duration reversibility and importance Based on these findings the draft management framework (see chapter 8) sets out proposals for avoiding or mitigating unacceptable change The process of reforming the fisheries sector will take a number of years and the existing FASDP covers only the first five years With the exception of proposals to scale down the size of the industrial and semi-industrial fishing fleets it is unlikely that major changes will take effect in terms of fishing activity during this five-year period Consequently from the standpoint of the World Banks investment there are likely to be relatively few issues in terms of potential conflict with safeguarding policies Later
8
however significant change is within the fishing industry and particularly onshore processing and marketing of fish products An important element in this report has therefore been the need to define the point at which the banksrsquo responsibilities are seen to terminate and all liabilities are transferred to other supporting donors and the government of Ghana In the short term a reduction in the industrial fleet may lead to the loss of 1000 to 3000 jobs for crew members although in practice most of this work is only part time and many of the vessels that are due to be withdrawn are no longer seaworthy In the longer term it is intended to encourage more selective fishing by limiting open and unfettered access to fish stocks eliminating illegal and damaging processes including dynamiting uncontrolled light fishing and the use of small size monofilament nets and introducing seasonal restrictions to protect breeding cycles The intention is that these measures will be managed jointly by the government and communities through co-management systems At the same time major efforts will be made to reduce the level of post-harvest losses and to increase the value of fish products The expectation is that the number of industrial semi-industrial vessels and canoes will be stabilised at a fixed lower level within five years Once this point is reached and no further licences are granted individual licences will acquire higher values especially as fish stocks recover and the size and value of fish catches starts to increase Subsequently licenses are likely to be sold and traded as less efficient owners drop out of the market and sell on to stronger individuals and companies In terms of onshore activities fish landing processing and marketing will become more efficient and losses will be reduced through use of better smokers freezing and drying equipment Previous studies in West Africa and elsewhere (Bennett et al 2001) have shown that the transition away from open access to a more regulated system of access management can give rise to social risks Specifically older men are likely to be displaced when they are no longer fit enough to withstand the rigours of fishing while a rising number of young men may find it harder to enter a career in fishing Women who currently manage or assist with all areas of buying processing and marketing using traditional clay ovens may also experience competition as new companies and enterprises are established to take advantage of higher profitability in the fishing sector perhaps using better equipment newer technologies and different logistics arrangements or their own transportation Methodology This study has followed the methodology developed within the process framework for the West Africa regional fisheries programme (WARFP) Figure 1 sets out both sequence and timescale for the work
The range of jobs at risk is based on assumptions about the number of vessels and average crew size and cannot be determined with any degree of accuracy until the necessary surveys are undertaken
9
The report is based on three major areas of activity 1 documentary analysis and utilisation of the studies already carried out by the fisheries commission 2 meetings with institutional stakeholders principally affected by the project and 3 Consultations and visits to some of the key fishing villages and communities The planned presentation of findings to Stakeholders has been postponed at the Clientrsquos request due to other pressing commitments in the agriculture and fisheries sectors This presentation will however need to be subsequently undertaken by the Ministry and the Fisheries Commission
11
CHAPTER 2 PLAN AND PROGRAMME DESCRIPTION
INTRODUCTION This chapter is divided into two parts Part 1 sets out the progress which the government Ghana is making in giving effect to the legislation policy and regulations Part 2 describes the proposed programme of assistance being offered by the World Bank with the specific aims of strengthening governance and enforcement systems (Components 1 and 2) and in promoting value addition and reduction of post-harvest losses
PART 1- THE DRAFT FISHERIES AND AQUACULTURE SECTOR DEVELOPMENT PLAN (FASDP) This plan (FASDP) covers the period 2010-2015 It recognises the importance of Ghanarsquos fisheries which generate in the order of US$ 1 billion a year contribute 45 to GDP and indirectly support the livelihoods of 22 million people However through over-fishing and lack of investment in management and value addition the average income per canoe has dropped by up to 40 over the last ten years to the point where it costs as much to fish as the catch is worth By comparison well managed fisheries in other parts of the world are capable of generating economic returns of 30-60 on investment (equivalent to a potential income of US$ 300 million a year for Ghanarsquos fisheries) The Draft FASDP acknowledges that the fishing sector is expected to make a substantial contribution towards doubling the size of the Ghanaian economy by 2015 (GPRS II) as part of the Republic of Ghana Fisheries and Aquaculture Policy Seven targets are set in the draft FASDP 1 Maintaining capture fisheries production at current levels 2amp3 Increasing revenue and profitability in capture fisheries by at least US$ 50 million a year after
five years 4 Increasing aquaculture production to 35000 tonnes a year after five years 5 Retaining Ghana as a landing and processing hub for the West Africa tuna industry 6 Developing fisheries management to allow effective control of all commercial fishing effort in
Ghanaian waters and 7 Ensuring fisheries management costs are sustainable and that the fisheries sector overall make a
fiscal contribution to Government revenues There is an underlying presumption that the canoe sector will remain at the heart of Ghanarsquos fishing industry but the plan is not prescriptive and leaves open the ways of achieving the overall goals At the same time there is an underlying assumption that the long term sustainability of Ghanarsquos fisheries will depend upon discouraging further entry by new operators
PART 2 THE WORLD BANKrsquos CONTRIBUTION TO GHANA FISHERIESPLAN (FASDP)
The essential aim of the World Bankrsquos contribution to FASDP is to provide investment which will build the necessary policy and capacity for effective fisheries management designed to reduce fishing effort while maintaining approximately the same catch levels and to address the impacts of change for fishers
12
and the communities in which they live Based on the currently available draft Project Appraisal Document (PAD) each of the components is now described in turn Component 1 - Good governance and sustainable management of the fisheries This component on good governance comprises four subcomponents which are broken down in turn into a number of separate activities Sub-component 11 developing the capacity rules procedures and practices for good governance of the fisheries Activity 111 reviewing the Fisheries Act and developing regulations to support the Sector Policy and the Fisheries and Aquaculture Sector Development Plan Activity 112 Developing an operational policy to enable implementation of the aquaculture and fisheries sector development plan Activity 11 3 strengthening fisheries management systems and capability (fisheries management plan development aquaculture implementation technical support and training) Activity 114 strengthening fisheries Information Systems (catch recording and monitoring systems statistical analysis and training)
Sub-component 12 introducing fishing rights
Activity 121 developing pilot stakeholder-based fisheries management initiatives around defined fisheries units (ie local management initiatives tighter defining fisheries resources in up to 6 selected Fisher communities) Activity 122 introducing and administering a licensing regime
Subcomponent 13 Adjusting fishing effort and capacity to more sustainable levels marine resource conservation and supporting alternative livelihood opportunities when needed Activity 131 vessel decommissioning Activity 132 compensation packages for crew of decommissioned industrialsemi-industrial vessels Activity 133 alternative livelihood development to incentivise voluntary capacity reduction in the canoe sector Activity 134 marine resources management and conservation
Subcomponent 14 social marketing communication and transparency Activity 141 communications stakeholder consultations and awareness raising programmes to support fishery development Component 2 reduction of illegal fishing Under the West Africa regional fisheries programme subcomponent 21 allows for enabling environment for reduction of illegal fishing These provisions already exist within Ghana and this subcomponent is therefore omitted Subcomponent 22 monitoring control and surveillance (MCS) systems Activity 221 developing compliant systems and capability
13
Component 3 increasing the contribution of the marine fish resources to the local economies Subcomponent 31 product diversificationvalue chain development (freshfrozen producttrade facilitation) Activity 311 landing site development Activity 312 Port development Subcomponent 32 fish product trade infrastructure information and systems - regional minimum integrated trade expansion platform (MITEP) Activity 321 export certification centre development Activity 322 fish processing technology improvements Activity 323 national fisheries advisory group Subcomponent 33 marine and inland aquaculture development Activity 331 space developing aquaculture policy and legal framework Activity 332 improving genetic policy of tilapia fingerlings and breedstock Activity 333 catalysing aquaculture development Component 4 Coordination monitoring and evaluation and program management Subcomponent 41 national implementation subcomponent 42 regional coordination Each of the components sub-components and activities are described in more detail in Chapter 5 which assesses the nature of environmental and social safeguards issues in terms of the World Bankrsquos planned investment
15
CHAPTER 3 BASELINE CONDITIONS
INTRODUCTION This chapter discusses the existing fishery resources of Ghana and describes recent environmental and social trends It identifies some of the pressures that led to the reduction in value of fishing activity and indicates the threats that could be posed if no action is taken in accordance with the planned fisheries and aquaculture program to deal with them FISHERY RESOURCES The continental and coastal waters of Ghana are potentially very rich due to a combination of warm waters and nutrients carried in ocean currents which up-well seasonally on the continental shelf The tonnage of fish caught in marine waters peaked in the mid-1990s around 500000 tonnes and currently averages around 400000 t(See Figure 1) Figure 1 Wild Capture Production in Ghana 1950-2005
2
Table31 Top 10 Species Exported (by value)
1 Canned tuna ($72000000) 2 Fresh tuna ($7200000) 3 Tilapia (no figure available) 4 Miscellaneous dried fish ($1000000) 5 Salmonids frozen ($900000) 6 Marine fish frozen ($600000) 7 Cuttlefish and squid ($600000) 8 Shrimps and prawns ($90000) 9 Sardines ($80000) 10 Crustaceans frozen ($50000) Source FAO Fishstat
The principal catch from deep waters is tuna Industrial vessels registered in Ghana target these species in international waters but also illegally in coastal waters Herring sardine and anchovies are fished in coastal waters by semi-industrial vessels and canoes Table 31 shows the top 10 species of fish exported from Ghana in 2005 PROFILE OF THE FISHING INDUSTRY Fishing is of vital importance in Ghana not only in terms of its contribution to gross domestic product (45 per annum) but because fish provides 65 of the countrys protein In recent years (between 2003-2008) and more specifically in 2004 the countryrsquos annual fish requirement has been estimated to be 882000 tonnes of which the country produces just about half (Tetteh 2007) Of the total population of 22 million people it has been estimated that between 15 and 22 million people are employed or gain their livelihoods from fishing (8-10) Of these there are 210000 men who are directly employed as
2 This figure is the Fisheries Departmentrsquos estimate for 2008
16
fishers The total export of seafood was valued US$824 billion in 2005 Ghanas fishing industry can be divided into three sections marine capture inland capture and aquaculture It can be further analysed by scale of operations distinguishing between industrial semi-industrial and artisanal sectors Marine fisheries Industrial sector Commercial fishing for tuna began in 1962 In the early 1980s Ghana sought to develop an industrial fishing fleet and there are currently 90 industrial trawlers and other vessels which are located in Tema and Takoradi Sekondi The port of Tema was expanded from 1962 to create four main areas the Inner Harbour Outer Harbour Canoe Basin and Commercial Area In 1999 fish landing facilities were improved at the Albert Bosumtwi Sam Fishing Harbour built in Sekondi This harbour is equipped with a cold store an ice-making plant offices a berthing bay for inshore vessels a jetty for canoes and a net drying area Under Ghanaian law more than 50 of the ownership of industrial vessels must be registered with a Ghanaian company or individuals However in practice many vessels are owned by foreign nationals with token Ghanaian ownership Relatively few of these large vessels regularly put to sea and a number are in poor condition or obsolete Nevertheless the impact of trawling activities by Ghanaian registered and foreign owned vessels has been very considerable in coastal waters in recent years Fish landed from industrial vessels is usually transferred directly to Canning factories in Tema and Takoradi Ghana has the largest canning industry in West Africa In the region of 30000 tonnes of tuna are landed In addition to trawling some industrial vessels are engaged in shrimping the use of tuna lines and polls purse seining and demersal trawling Semi-industrial sector in addition to deep sea trawlers there are around 230 large semi-industrial ships propelled by inboard motors which are used for trawling in shallow waters during the off-season and purse seining during upwelling seasons There are currently reported to be 48 bottom trawlers 14 pair trawlers 2 shrimpers 33 pole and line vessels and 10 tuna purse seiners operating from 2 of the 7 landing sites Canoe sector Ghanas artisanal fishing sector is based on between 10000 and 12000 wooden canoes Fifty seven per cent of the fleet is powered by outboard motors supported by paddle and occasionally sail Each Canoe carries a crew of between three and 20 men depending on size and length There are over 334 landing sites along the 550 km coast of Ghana and the majority of fish caught by canoe (180000 tonnes) is returned to these sites accounting for 70 of Ghanarsquos fish production The principal landing sites are at Teshie Jamestown Chorkor Shama Axim Elmina Winneba Mumford Akplabonya Adina Atiteti Abutiakope and more Fishing is undertaken by men but the majority of canoes are owned by women who pre-finance fishing trips (purchasing gear and premixed fuel) and purchase the catch Women also predominate in processing and marketing fish and fish products Only about 20 of fish sold fresh a further 20 is salted and the majority (60) is smoked It is estimated that up to 30 of the catch is spoilt through lack of ice for storage or alternative processing facilities
17
Inland fisheries Water Resources Ghanarsquos inland fishery resources consist of a natural lake( Lake Bosomtwe) and nine major river basins which from east to west of the country are
bull the Volta bull Densu bull Ayensu bull Ochi bull Kakum bull Pra bull Ankobra and bull the Tano
The River Tano forms the border between Ghana and Cote drsquo Ivoire The largest of the rivers is the Volta which drains more than two-thirds of the country through several large tributaries in virtually all regions of the country The Volta river system also incorporates the Volta reservoir generally known as the Volta Lake which has a surface area of around 8400 km2 The Volta lake discharges through the Akosombo dam before flowing through a delta into the Atlantic Ocean The eight other river systems are relatively smaller simpler and open more directly into the Atlantic There are also several reservoirs created on the smaller river systems mainly for potable water production irrigation and flood control These reservoirs irrespective of their primary purposes enhance availability of more permanent aquatic habitable space for fish and therefore support some fisheries Finally with all the river systems opening into the Atlantic there are a series of lagoons and estuaries which act as interfaces between the rivers and the sea These water areas constitute another type of inland water resource for salt and brackish water fishes Inland Fish resources Within the inland water resources of Ghana there are over 150 fish species more than 90 of which are fished for food
In commenting on inland fisheries in Ghana it must be noted that virtually all available information on inland fisheries is obtained from the Volta Lake No national fish production records have been kept on the fisheries of the eight smaller river systems and the lagoons and estuaries Thus the usual statement that inland fish production constitutes about 20 of what the country produces should refer to fish production from the Volta Lake In practice the total inland fish contribution could more realistically be estimated at about 30-35 of national fish production This is a very considerable but understated contribution to national food security and nutrition
Fishing vessels The dominant fishing vessel on the Volta Lake is the canoe the majority of which are built from wooden planks On some other river systems while plank canoes predominate a small number are carved as dug-outs from single tree trunks There is some variety in sizes of the canoes depending on how many planks are used to build the boat and the size of tree trunk used in building a canoe The total number of canoes estimated on the Volta Lake during a survey in 2000 was 24035 On the tributary rivers of the Volta Lake and other river systems in the country the planked canoe is the main vessel used in fishing
18
Fishing gear There are about eleven main kinds of gear used for fishing on the Volta Lake They are Gill Nets Cast Nets Hook and Line Basket and wire mesh traps Winch net Beach seine Bamboo Nifa-nifa Wangara Spears and Atidzas On other rivers in the country Gill nets Cast nets Hook and Line and traps are the fishing gear used On both the lake and rivers the Gill net is the main gear
People Involved In the 2000 frame survey of the Volta Lake conducted by the Fisheries Directorate of Ghana the estimate of fishers on the Volta Lake was put at 71861 Fishers on the lake work in collaboration with a host of fishmongers or handlers who also function as wholesalers for individual fishing groups Assuming that the fisher population on the lake has increased by a modest 3 in the ten years from 1998 to 2010 a fisher population of about 93500 could be considered to be on the Volta Lake now If again it is estimated that number of fishers on rivers in the country were to be a tenth of those on the lake this would put the fisher population on inland waters (apart from the Volta Lake) at about 9350 fishers A very conservative estimate therefore puts the total number of individuals who are directly engaged in inland fishing at over 100000 This excludes all directly associated groups such as fish handlers processors and traders An estimate of secondary fisheries operators such as boat builders out-board motor operators and mechanics as well as bulk salt and fuel wood sellers and those engaged in buying selling and distributing fish would have to be considered in developing estimates for both direct and indirect employment in inland fisheries but the number can be assumed to lie between 125000 and 150000 people
Aquaculture Under Ghanarsquos legal framework aquaculture is defined as ldquoany activity designed to cultivate or farm fish and other aquatic living resourcesrdquo Currently only fin fishes are involved in aquaculture in Ghana
Current culture media and environment Currently fish culture takes place almost exclusively in fresh water in Ghana either in cages brush parks or dugouts Dug-outs are excavations made in floodplains in the savannah parts of the country were water scarcity has been a major hindrance to development in general and food security in particular Dug-outs get filled with flood waters and whatever the water carries during major wet periods of a year in the savannah areas Waters that fill Dug-outs invariably contain fish which are trapped in the Dug-out after the wet period These water bodies are managed until the end of the dry period and the fish are harvested before the next flood period Since the 1960rsquos various strategies to augment fish production from Dug-outs have been developed and tested These involve adding fingerlings of selected fish species to those which are lsquonaturally stockedrsquo in Dug-outs by floods Dug-outs are the major fish culture production approach in the savannah parts of the country which accounts for a little more than half the area of the country The Environment of fish culture Currently fish culture is taking place mainly in freshwater environments Brackish water fish culture and mari-culture activities which will bring lagoons estuaries and the sea into fish culture production have long term potential for development Fishes in culture Fishes being cultivated in Ghana In order of importance are Nile tilapia Oreochromis niloticus the African catfish Clarias gariepinus species of the catfish Heterobranchus and the Bony tongue Heterotis niloticus Scale of Culture Based on level of production fish culture operations can be categorized as follows
bull Large scale commercial where an enterprise produces up to 10000 tonnes per year
19
bull Medium scale commercial where a single enterprise produces between 50 and 500 tonnes bull Small scale commercial where an enterprise produces between one and 20 tonnes and bull Very small scale commercial with productions below 20 tonnes
Fish culture production Cultured fish contribution to national production was officially stated as 9000 tonnes for the year 2009 However informed opinion amongst fish farmers indicates that a figure of between 16000 and 20000 tonnes in 2010 would be closer to reality This statement is based on the facts that most producersrsquo published figures are underestimates several small to medium scale producers are not recorded in official lists and the recording of newly established fish farms has lagged actual establishment especially since 2009 Although cultured production up till 2009 may not have been significant considering a shortfall of about 460000 mt (as recorded in 2004) between captured fish production and national demand this reflected the fact that there were only two large scale commercial producers in the country each of which had had less than ten years of operation Anticipated growth in fish culture production within the next five years is expected to be dramatic as some of the critical challenges of the industry are resolved
CHALLENGES AND PROSPECTS Marine Fisheries The fishing sector is vital for food security and job creation to help alleviate rural poverty in Ghana However the levels of fisheries harvests are generally considered to be close to or to have exceeded the maximum sustained yield Future sustainability in the industry will depend upon the restriction of open access to fisheries and the introduction of management systems which allow fish stocks to recover and the establishment of consistent yields in both marine and inland waters Inland Fisheries Environmental conditions on the Volta Lake constitute the major environmental and social challenges for fisheries its sustainability and profitability In terms of future prospects success will depend heavily on implementation of the lsquoGhana Fisheries and Aquaculture Sector Development Planrsquo and the capacity of the system in Ghana to enforce the Fisheries Regulations passed by parliament in August 2010 Aspects of the Development plan that offers great prospects for the lakes fisheries include the provisions for eventually licensing boats (although the scale of this task should not be underestimated) and measures to involve communities in management of fisheries resources of the Lake
Aquaculture The main challenges facing aquaculture development in Ghana relate to bull The high cost of fish feed (significantly due to its importation from other countries) bull None availability of commercial fish hatcheries as enterprises bull Lack of a nation-wide distribution network for fish seed and cultured fish producers Most
sources of fingerlings are concentrated in one part of the country and since farms all over Ghana obtain their fingerlings individually transportation costs add significantly to overall production costs
bull Now emerging certification and monitoring to check the health and safety of aquaculture processes and products
bull The absence of adequate regulations regarding establishment of an aquaculture enterprise until August 2010 (In the absence of regulations only the large and medium scale commercial farms worked towards conforming to international performance Standards and operational regulations for certification of farms and their products still remain in a draft state)
bull Low national support for research to support expansion and systematic development of aquaculture
20
The prospects for development of aquaculture as an industry in Ghana are good since a number of practical policy and legal frameworks have been put in place to resolve the basic challenges to the industry listed above These include
bull Construction of the first local fish feed plant by an international fish feed company with the expectation of having initial products on the Ghanaian market during 2011
bull A lsquoLarge scale commercial fish farmrsquo with great capacity for fingerling production is shifting emphasis to fish seed production And several localized fish seed producers are expanding operations
bull Distribution strategies by cultured fish producers have started to emerge on a limited scale and are expected to evolve with increasing production as existing commercial farms expand and new ones join in
Now that regulations regarding establishment of aquaculture enterprises have been gazetted there is likely to be a positive response amongst fish farmers of all size categories New operational standards are being prepared which will introduce minimum standards for local certification This should set the stage for preparation of fish culture products and the broadening of choice for consumers while also qualifying Ghanaian producers to enter external markets
ENVIRONMENTAL CONDITIONS The coastal and marine environment a critical zone of influence for this study comprises a 550 km coastline a coastal belt ranging from 1 to 20 km in width and coastal waters extending to 200 nautical mile limit which was established in 1977(under the territorial waters and continental shelf act 1973 as amended by the territorial waters and continental shelf amendment decree 1977) The Coastal Belt The coastal belt accounts for only 65 of the land mass of Ghana but it is one of the most densely settled areas accounting for 25 of the population and80 of the industrial establishments in Ghana Historically the coastal zone was cultivated for coconut (copra) but this industry is in decline Vegetables and other agricultural produce are grown on better soils but the principal economic activities are fishing transportation salt production and sand and stone winning Tourism also offers great potential There is considerable expectation that the discovery of offshore oil and gas deposits will bring new wealth to parts of the coastal corridor However present plans to transfer crude products to tankers at sea and then export them directly will limit industrial activity to a support role A high percentage of industrial and municipal wastes is dumped at landfill sites within the coastal zone which creates pollution risks The coastal belt is generally a low-lying area less than 200 m above sea level Vegetation types reflect the rainfall gradient and consist of coastal shrub and Savannah to Winneba southern marginal forest to the east of Sekondi dry semi-deciduous and moist semi-deciduous forest to the east of Cape Three Points estuary and wet evergreen forest in the extreme south Soils are variable within this area ranging from fertile pockets river valleys to Sandy poorer quality soils close to the sea The Coast The coast line divides into three sections (Ly 1980)
bull West of Cape Three Points this area has a wide and flat beaches backed by coastal lagoons and
21
wave heights are generally low bull Between Cape three points and Tema the coast consists of a series of rock headlands enclosing
shallow bays together with sandbars or spits enclosing coastal lagoons The surf zone is a medium to high energy environment with wave heights often exceeding 1 m South-westerly prevailing winds give rise to longshore drift in an easterly direction
bull Between Tema and Aflao most of the shore is sandy although there are rocky outlets The coastal zone is important internationally in providing feeding roosting and nesting sites for thousands of migratory birds Environmental degradation is significant in Ghana and is recognized in the countryrsquos environmental action plan It contributes to rising poverty levels coupled with poor human health and inadequately planned urbanization which fuel a vicious cycle inhibiting human development The core issues include
bull Domestic sanitation bull Increased urbanization without appropriate infrastructure bull Wetlands and mangrove degradation bull Coastal erosion and bull General biodiversity loss
Briefly each of the above could directly or indirectly adversely influence fisheries and aquaculture separately or together For example in a recently completed study of water quality scenarios of the Volta Lake in relation to fish production as a component of a comprehensive study (The Challenge Program Project of Water amp Food) it was concluded among others that poor sanitation in highly populated fisheries communities adversely influenced water quality to the detriment of fish life and thus fish production With reference to aquaculture the same unsanitary conditions in highly populated shore communities adversely influenced water quality especially in terms of oxygen depletion when lake waters extend to the shore in high water periods This is a situation which has caused fish kills in cages because caged fish cannot escape lsquopollutedrsquo waters Degradation of wetlands and mangroves leads directly to a reduction in their capacities as spawning and nursery zones for both marine and inland water fishes which reduce fish production in both environments The situation outlined above is often contributed to by anthropogenic and industrial pollution due to urbanization without appropriate infrastructure Another issue linking human activity to a deteriorating environment is demonstrated by the encroachment of aquatic weeds on inland waters such as the Volta Lake Weed growth is accelerated by farming reservoir catchments which increases nutrient levels and the building of dams which reduce or cut off intrusion of sea water into rivers Currently as climatic change observable impacts such as floods seem to escape predictions The project could possibly contribute to mitigating against direct and indirect effects of climate change on fishing and aquaculture through investment into climate change orientation and education of fishers and fish farmers to mainly influence reasonable precautions they take Marine waters The continental shelf is relatively narrow projecting out to 25-35 km except in the area of Cape Coast to Salt Pond where it extends to almost 80 kms Sandy and rocky substrates which previously supported coral and seaweeds have been severely affected by former trawling activity which indiscriminately
22
dredges material from the seabed Coastal waters are enriched by freshwater discharges from the relatively small number of rivers and by two seasonal up-wellings which occur between late June and early October (the main upwelling) and January and March (the minor upwelling) The origin and driving mechanisms of these up-wellings are not fully understood and both their location and strength varies from year to year
Lake Volta and other inland water
Major environmental issues on the Volta Lake which might also be considered as challenges to sustainable fisheries on the major inland fisheries resource can be summarised as follows
bull The Volta Lake is known to be low in nutrients It therefore has low standing crops of phytoplankton and zoo plankton to support high fish production
bull The northern segment of the lake together with tributary rivers constitute the spawning and feeding grounds for majority of fish species in the lake during the wet season however these segments are intensely fished during the same period
bull The Volta Lake is divided into eight unequal strata with different distribution of boats per Km2 At the last estimation of carrying capacity in 2000 stratum V and II had the highest (527) and lowest(157) number of boatsKm2 respectively
bull The rate of siltation in the lake is considered to be increasing due to erosion associated with high rates of deforestation
bull A major challenge exists in getting fishers fishing communities and fishing entrepreneurs to understand and comply with fishing regulations aimed at conserving fish and fisheries resources
bull There is a lack of resources studies and research to support fisheries management of the Lake
bull High illiteracy exists amongst lake shore communities
bull Open access to the fish resources of the Lake has been in operation since its formation
bull Declining fish yields are occurring in the lake (468 Kgha in 1976 to 320 Kgha in 2003-MOFA) brought about by the constraints listed above
bull The commonly assumed estimate of potential fish production from the lake of around 75500 mtyr) is considered to be a serious underestimate since Stratum VII alone was estimated to produce 33800mtyr in 1996
bull The policy environment for aquaculture is currently strongly supportive of the industry and related enterprises
bull There is good quality and more than sufficient water to allow some kind of aquaculture to be developed in every region of the country with the Volta lake (about 8400 Km2) as the single most important water unit for fish culture Currently it appears that the free access to the fish resources of the lake has to some extent been applied to establishment of small scale caged fish culture enterprises a situation constituting environmental risk to investments of large scale commercial fish culture establishments in the lake
bull The Volta Lake is low in nutrients (Obeng 1964) resulting in a situation where higher fish yields could be sustained if greater quantities of fish feed were available
23
bull In Ghana the Nile tilapia O niloticus occurred naturally only in the Volta system Due to positive culture characteristics of the fish it has been moved into virtually all other river basins in the country The situation provides opportunities for hybridization of the Nile tilapia with other tilapia species native to the river basin into which the Nile tilapia has been moved
25
CHAPTER 4 POLICY AND LEGAL FRAMEWORK FOR ENVIRONMENTAL AND SOCIAL ISSUES
41 INTRODUCTION
Development and implementation of the Ghana Fisheries and Aquaculture Sector Development Plan and the World Bankrsquos supporting program need to be developed with full regard to existing international conventions national legislation policies and regulations This chapter highlights the main legislative and policy considerations for the protection of the environment natural resources fisheries and social and economic development It begins with reference to the World Bankrsquos safeguard framework and those of other donors This is followed by a section on the governance framework in Ghana
42 WORLD BANK AND OTHER DONORSrsquo SAFEGUARDS POLICIES
The World Bankrsquos safeguard policies exist to ensure that all projects which it finances are developed and implemented on environmentally and socially sound principles A range of different policies exist and these have been carefully considered to ensure that the Ghana Fisheries and Aquaculture Development Sector Development Plan complies with these safeguards All policies have been screened and those that have no bearing on the fisheries programme have been excluded from Table 41 below Table 41 lists policies which could have some applicability to the FASDP even if this interaction might be very slight It is important to stress that the comments in the third column of Table 41 relate to the entirety of the Fisheries and Aquaculture Sector Development Plan whose effects will continue to be experienced long after the World Bankrsquos financial support has been expended Most of the activities in the FASDP will have no effect in relation to safeguard objectives and where there are implications these are likely to occur at precise locations (for example at fish landing sites) rather than throughout the industry Where potential interactions have been noted the necessary mitigating measures are incorporated in the Draft Process Framework
Table 41 World Bank Safeguard Policies in Context
Safeguard Policy
Safeguard Policy Objective Brief Description and relevance to FASDP
OP 401 Environmental Assessment
This policy aims to ensure that Bank-financed projects are environmentally sound and sustainable and that the decision-making process is improved through appropriate analysis of actions and mitigation of their likely environmental impacts This policy is triggered if a project is likely to carry potentially adverse environmental risks and impacts on its area of influence OP 401 covers impacts on the natural environment (air water and land)
The majority of actions planned under FASDP will be beneficial to the marine environment and to inland waters However new construction activities could have impacts and depending on the project and the nature of impacts a range of instruments can be used to ameliorate and mitigate adverse effects while enhancing beneficial effects These include EIA environmental audit risk assessment and environmental management plans (EMP) The need for EIA and EMP is considered in this report
26
OP 404 Natural Habitats
This policy recognizes that conservation of natural habitats is essential to safeguard their unique biodiversity and to maintain environmental services and goods for human society and for long-term sustainable development The Bank therefore supports the protection management and restoration of natural habitats in its project financing as well as policy dialogue and economic and sectoral work Natural habitats comprise many types of terrestrial freshwater coastal and marine ecosystems They include areas lightly modified by human activities but retaining their ecological functions and most native species
This policy is triggered by any project (including any sub-project under a sector investment or financial intermediary) with the potential to cause significant conversion (loss) or degradation of natural habitats whether directly (through construction) or indirectly (through human activities induced by the project) This policy is applicable to the Ghana Fisheries Programme because the project focuses on the integrated management of natural habitats However by screening all proposals under the ESMF any sub-projects that might impact these habitats will not be funded
OP 409 Pest Management
The objective of this project is to (i) promote the use of biological or environmental control and reduce reliance on synthetic chemical pesticides and (ii) strengthen the capacity of the countryrsquos regulatory framework and institutions to promote and support safe effective and environmentally sound pest management
The policy is triggered if (i) procurement of pesticides or pesticide application equipment is envisaged either directly through the project or indirectly through on-lending co-financing or government counterpart funding (ii) the project supports an activity requiring the use of pesticides that may have negative effects on the environment The only instance in which this policy might be triggered by the Ghana Fisheries Programme is if aquatic herbicides or antibiotics were to be used in connection with aquaculture This is most unlikely but can be monitored through the implementation programme
OP 411 Physical Cultural Resources
The policy objective is to assist countries in avoiding or mitigating adverse impacts of development projects on physical cultural resources For the purposes of this policy ldquophysical cultural resourcesrdquo are defined as movable or immovable objects sites structures groups of structures natural features and landscapes that have
Under the Ghana Fisheries Programme construction and rehabilitation activities that could have negative impacts on cultural property will be avoided In the case of discovery of remains national procedures will be applied
27
archaeological paleontological historical architectural religious aesthetic or other cultural significance
OP 412 Involuntary Resettlement
The objective of this policy is to (i) avoid or minimize involuntary resettlement where feasible while exploring all viable alternative project designs (ii) to assist displaced persons in raising their former living standards income-earning capacity and production levels or at least in restoring them (iii) encourage community participation in planning and implementing resettlement and (iv) provide assistance to affected people regardless of the legality of land tenure
The policy covers not only physical relocation but any loss of land or other assets resulting in (i) relocation or loss of shelter (ii) loss of assets or access to assets (iii) loss of income sources or means of livelihood whether or not the affected people must move to another location The activities of the Ghana Fisheries Programme are likely to result in loss of assets or access to assets and loss of income sources or means of livelihood for some groups and individuals The potential for such losses will be carefully scrutinised and compensated for through the National Process Framework and Resettlement Policy Framework described in this report and appropriate procedures will be followed where necessary
Other donors and aid agencies including International and National NGOs play an active role within the fisheries sector in Ghana and their safeguards standards will be observed through operation of the Environmental and Social Safeguards Management Plan
28
43 THE GOVERNANCE FRAMEWORK IN GHANA
The Ministry of Food and Agriculture (MOFA) Preparation of Fisheries laws and policies fall under the responsibilities of the Minister of Food and Agriculture who in turn delegates functions including implementation to a semi-autonomous body the Fisheries Commission
The Fisheries Commission (FC) was established under the Fisheries Commission Act (625 2002) It oversees management regulation and utilisation of the fisheries resources of Ghana drawing on powers set out in the Fisheries Law (PNDC 256 1991) Fisheries Act 625 provided for the establishment of a more robust Fisheries Commission (FC) which is an amalgamation of the erstwhile FC and Department of Fisheries
Ten individuals constitute the Board which is led by a chairman (appointed by the President of Ghana in consultation with the Council of State) supported by three members drawn from the ministries of transport defence and environment There are three representatives from the following parastatal organizations - the Ghana Marine Fishing Officers Association Water Research Institute and Ghana Irrigation Development Authority- and two representatives (one from the artisanal and one from the industrial sections )of the National Fisheries Association of Ghana Finally the tenth member is a person with requisite knowledge of the fishing industry or natural resources renewal management
The day to day work of the Fisheries Commission is undertaken by the Department of Fisheries (DOF) which serves as the implementation secretariat of the Fisheries Commission as stipulated by the Fisheries Act 625 of 2002 Specific tasks that are undertaken by the Department of Fisheries include
bull preparing fishery resource management plans bull developing regulations for the fishing industry bull organizing monitoring surveillance and enforcement for the national fishery resources and
ensuring compliance with national fisheries law and institutionalizing co-management concepts
The MCS Division of the DoF (established under the Fisheries Sub sector Capacity Building project) works in conjunction with the Ghana Navy and undertakes sea patrols to exclude industrial fishing vessels from the 30-metre depth IEZ reserved for artisanal fisheries The MCS also conducts inspection of industrial vessels at the fishing ports of Tema and Takoradi for
bull valid fishing licences bull legality of fishing gear bull skipperrsquos certificate bull log book and crew composition
The MCS undertakes similar functions for inland fisheries on Lake Volta
The Ministry of Local Government and Rural Development (MLGRD) is responsible for managing fishers fish processors and fishery resources at district and sub-district levels which it undertakes through the District Assemblies In 2002 the District Assemblies in collaboration with DoF were mandated to facilitate fishery resource management by
bull helping to form and sustain Community Based Fisheries Management Committees (CBFMCs) bull cooperating with the DoF MCS units bull providing legal and financial support to the CBFMCs and bull approving levies proposed by the CBFMCs
29
Community-Based Fisheries Management Committees are charged with the responsibility of enforcing national fisheries laws at community level as well as initiating and enforcing their own by-laws
44 THE LEGAL FRAMEWORK
441 International Conventions
Ghana has ratified a number of international conventions and treaties which have an important bearing on the state of its marine and inland waters and the condition of the fisheries These are listed in Box 1 below
Box 1 International Conventions treaties and agreements to which Ghana is a signatory 1 International Convention for the Prevention of Pollution of the sea by Oil 21 October 1962 2 Convention on the Africa Migratory Locust 25 May 1962 3 Treaty Banning Nuclear Weapon Tests in the Atmosphere in Outer Space and Under Water 5th August 1963 4 International Convention for the Conservation of Atlantic Tunas 4 May 1966 5 Africa Convention on the Conservation of Nature and Natural Resources 15 September 1968 6 International Convention on Civil Liability for Oil Pollution Damage 29 November 1969 7 International Convention Relating to Intervention on the High Seas in Cases of Oil Pollution Causalities 8 Convention on Wetlands of International Importance Especially as Waterfowl Habitats 2 February 1971 9 Treaty and Prohibition of the Emplacement of Nuclear Weapons of Mass Destruction on the Seabed and the Ocean Floor and in the Subsoil Thereof 11 January 1971 10 International Convention on the Establishment of an International Fund for Compensation of Oil Pollution Damage 18th December 1971 11 Convention Concerning the Protection of World Cultural and Natural Heritage 16 November 1972 12 Convention on International Trade on Endangered Species of Wild Fauna and For a 3 March 1973 13 Convention on the Military or Any other Hostile Use of the Environmental Modification Techniques 10 December 1976 14 Convention on the Conservation of Migratory Species of Wild Animals 23 June 1979 15 Convention for the Cooperation in the Protection and Development of the Marine and Coastal Environment of the West and Central African Region1981(Abidjan Convention) 16 United Nation Convention on the Law of the Sea 10 December 1982 17 Montreal Protocol on Substances that Deplete the Ozone Layer 24 July 1989 18 Convention to Combat Drought and Desertification 19 Framework Convention on Climate Change June 1992 20 Convention on Biological Diversity1992 442 Environmental-Related Conventions Environmentally related conventions ratified by Ghana include
bull International Convention for the Prevention of Pollution of the sea by Oil 21 October 1962
bull Convention on the Africa Migratory Locust 25 May 1962 Treaty Banning Nuclear Weapon Tests in the Atmosphere in Outer Space and Under Water 5th August 1963
bull International Convention for the Conservation of Atlantic Tunas 4 May 1966 bull Africa Convention on the Conservation of Nature and Natural Resources 15 September 1968 bull 992256International Convention on Civil Liability for Oil Pollution Damage 29 November
1969 bull International Convention Relating to Intervention on the High Seas in Cases of Oil
30
Pollution Causalities bull Convention on Wetlands of International Importance Especially as Waterfowl Habitats
2 February 1971 bull Treaty and Prohibition of the Emplacement of Nuclear Weapons of Mass Destruction
on the Seabed and the Ocean Floor and in the Subsoil Thereof 11 January 1971 bull International Convention on the Establishment of an International Fund for
Compensation of Oil Pollution Damage 18th December 1971 bull Convention Concerning the Protection of World Cultural and Natural Heritage 16
November 1972 bull Convention on International Trade on Endangered Species of Wild Fauna and For a 3
March 1973 bull Convention on the Military or Any other Hostile Use of the Environmental
Modification Techniques 10 December 1976 bull Convention on the Conservation of Migratory Species of Wild Animals 23 June 1979 bull Convention for the Cooperation in the Protection and Development of the Marine and
Coastal Environment of the West and Central African Region1981(Abidjan Convention)
bull United Nation Convention on the Law of the Sea 10 December 1982 bull Montreal Protocol on Substances that Deplete the Ozone Layer 24 July 1989 bull Convention to Combat Drought and Desertification bull Framework Convention on Climate Change June 1992 bull Convention on Biological Diversity1992
443 National Legislation
The principal national legislation that affects fisheries in Ghana is listed below
1 Fisheries Regulation 1984 LI 1294 2 Fisheries (Amendment) Regulation 1977 3 Maritime Zones (Delimitation) Law 1986 4 PNDC Law 256 of 1991 5 Fisheries Commission Act of 1993 and 6 Fisheries Act 625 of 2002 7 Fisheries Regulations passed in 2010 LI 1968
Other laws that have relevance to the fisheries sector include
1 Wild Animals Preservation Act 1961 (Act 43) 2 Volta River Development Act 1961 (Act 46) 3 Ghana Water and Sewerage Corporation Act 1965 (Act 310) 4 Oil in Navigable Waters Act 1964 (Act 235) 5 Irrigation Development Authority Decree 1977 (SMCD 85) 6 Minerals and Mining Law 1986 (PNDCL 153) 7 Environmental Protection Agency Act 1994 (Act 490) 8 Ghana Highway Authority Act 1997 (Act 540) 9 Timber Resources Management Act 1998 (Act 547) and 10 Minerals and Mining Act 2006 (Act 703
31
434 Policies A number of Environmental related Policies exist in Ghana however there is no specific policy on the coastal zone These include
bull The National Environment Policy bull National Wetlands Policy bull Agricultural Policy bull Tourism Development Policy bull Land Management Policy bull National Health Policy bull Energy Policy bull Minerals Policy bull Wildlife Conservation Policy
The main thrust and orientation of national policies on the protection management and development of the marine and coastal environment focuses on the following three major areas
bull Integrated coastal zone management and sustainable development bull Marine environmental protection both from land-based activities and from sea-based
activities and bull Sustainable use and conservation of marine living resources (both of the high seas and
under national jurisdiction) Specific plans have been developed to ensure the realization of prudent management of the marine and coastal environment These include
bull Coastal Zone Management Indicative Plan 1990 bull National Environmental Action Plan 1994 bull Draft Integrated Coastal Zone Plan 1998 bull Coastal Zone Profile of Ghana 1998 bull National Oil Spill Contingency Plan with specific reference to the marine environment
2002 bull Environmental sensitivity map of the coastal areas of Ghana 1999 and 2004
Despite the existence of these plans active integration and coordination has been lacking in practice at local level 434 Regulations Though several legislations exist on coastal protection and sustainable development there is no omnibus legislation on the environment Legislation relating to the area include the following
bull Beaches Obstruction Ordinance 1897 (Cap 240) bull The Mineral and Mining Law 1986 (PNDC 153) bull Rivers Ordinance 1903 (Cap 226) bull Land Planning and Soil Conservation Ordinance No 32 of 1953 as Amended by the bull Land Planning and Soil Conservation (Amendment) Act 1957 (No 35 of 1957) bull Maritime Zones (Delimitation) Law 1986 (PNDCL 159) urban planning and
32
bull development bull Town and Country Planning Ordinance (Cap 84) bull Wild Animals Preservation Act Act 235 1964 bull The Towns Ordinance (Cap 86) bull National Building Regulations 1996 (LI 1630) bull Volta River Development Act 1961 bull Fisheries Act 2002 Act 625 bull Fisheries Law 1991 (PNDC 256) bull Fisheries (Amended) Regulations 1977 and 1984
The sustainable use and conservation of marine resources is encouraged through legislation regulations education and awareness creation programmes as well as the enforcement of existing regulations and legislation The legal framework for coastal zones issues and management in the country are contained in the following documents
bull The 1992 constitution bull EPA Act 1994 (Act 490) bull Environmental Assessment Regulations 1999 (LI 1652) bull Local Government Act 1993 (Act 462) bull Environmental Standards and Guidelines bull
In addition there are other specific legal frameworks which include a) The legal framework for Ecosystem Protection which are
bull Wild Animals Preservation Act 1961 (Act 43) bull Wildlife Conservation Regulations 1971 (LI685) bull Wild Reserves Regulations 1971 (LI 740) bull The Wetland Management (Ramsar sites) Regulation 1999 bull Oil in Navigable Waters Act 1964 (Act 235)
b) The legal framework for Fisheries Resources which are bull Fisheries Law 1971 (PNDCL 256) bull Fisheries Act 2000
c) The legal framework for Oil and Gas Industry bull Petroleum (Exploration and production) Law 1984 (PNDCL 84) bull Mineral (Offshore) Regulations 1963 (LI 257) bull Mineral (Oil and Gas) Regulations 1963 (LI 256) bull Oil and Mining Regulations 1957 (LI 221)
d) The legal framework for Tourism Promotion (including coastal tourism) bull Ghana investment Promotion Centre Act 1994 (Act 478) bull Companies Code 1963 (Act 179) bull Free Zone Act 1995 (Act 504) bull Ghana Tourism Board bull Ghana Commission on Culture
44 ACTIVITIES RELATING TO FISHERIES INTERESTS
33
Over the years several activities have been undertaken which are of relevance to protection of the marine environment and fisheries These include
bull Ghana Environmental Resource Management Project in Coastal Wetlands Management Component
bull Gulf of Guinea Large Marine Ecosystem Project bull Fisheries Sub-sector Capacity Building Project bull Establishment of a Protected Wetland Ecosystem on the coast bull Development and Implementation of Oil Spill Contingency Plan bull Monitoring of fish stock levels and associated oceanographic parameters bull Institution of a programme of Monitoring Compliance and Surveillance of the marine
environment bull Development of industrial pollution standards bull Development of University course on Coastal Zone Management bull Increased public education on sound coastal and marine environmental practices
45 RELEVANT INSTITUTIONS With regards to protection management and development of the marine and coastal environment a number of ministries and agencies have been identified as potential stakeholders Those shown with an asterisk are likely to have a particularly active role
bull Ministry of Environment and Science bull The Environmental Protection Agency bull Ministry of Tourism bull Ministry of Local Government and Rural Development bull Ministry of Ports bull District Assemblies bull Ghana Ports and Harbours Authority bull Hydrological Services Department bull Ministry of Food and Agriculture bull Ghana Tourist Board bull Ghana Investment Promotion Centre bull Fisheries Commission Ministry of trade Industries and PSI bull Ministry of Lands and Natural Resources Forestry and Mines bull Ministry of Energy bull Ministry of Health bull Ministry of Education Youth and Sports bull Ministry of Defence bull Ghana Navy bull Ministry of Works and Housing bull Ministry of Women and Childrenrsquos Affairs bull Ministry of Roads and Transport bull National Development Planning Commission bull Council for Scientific and Industrial Research bull Universities and Research Institutions bull Ghana Meteorological Agency bull Town and Country Planning Department bull Water Resources Commission
34
bull Ghana National Petroleum Corporation bull Volta River Authority bull Geological Survey Department bull Forestry Commission (Forestry and Wildlife Division) bull Traditional Rulers and their analogous ministry and laws
Non-Governmental Organisations including Resource Development amp Environmental Oriented Development Organisation
bull Friends of the Earth bull Green Earth bull Wildlife Society bull Recerca e Cooperazione bull Centre for African Wetlands bull And many others
46 PARTNERSHIPS Few formal partnerships exist However support for coastal conservation activities has been received from the private sector as well as from Government Regional and sub-regional collaboration efforts occur at various levels although the level of practical intervention is sometimes limited The science and technology unit of ECOWAS is engaged on issues relating to the management of the Gulf of Guinea In addition a bilateral arrangement exists between Ghana and Cote drsquoIvoire for the management of and datasharing on Sardinella stocks which migrate between the two countries The NEPAD framework among the coastal states of Africa is also developing an interest in marine and coastal management 461 Technical and financial support Ghana receives technical support in the form of training research and project implementation from national bilateral and multi-lateral sources Financing of activities in the sector is primarily supported from the national budget However donor support from both bilateral and multilateral sources has also been obtained for specific programmes such as the World Bank sponsored Fisheries Sub-sector Capacity Building Project UNOPS sponsored Environmental Sensitivity Map for Coastal Areas The Ghana Coastal Wetland Project of the World Bank UNEPrsquos WACAF Programmes and The Darwin Marine Biodiversity of West Africa Project by DFID implemented by the University of Ghana 47 ACTIVITIES Activities undertaken in the country with importance to the marine and coastal area are outlined in the following sections 471 Environment-related activities
bull Ecological Baseline studies of Korle Lagoon (1990-2000) This was carried out to satisfy EIA requirement and as a result pollution status of the lagoon was established
bull Lower Volta Mangrove Project (1996-1998) The objective is to ensure sustainable management of mangrove stands and as such baseline information was documented
bull Save the Seashore Birds Project (1985-1995) This was to protect the seashore birds and as a result conservation awareness of seashore birds was achieved
bull Ghana coastal wetlands management project (1996-1999) In this management of the five coastal wetlands designated as Ramsar Site was put in place
bull Darwin Marine Biodiversity of West Africa Project It is a training project in marine biodiversity assessment
35
472 Social-related activities bull A considerable amount of attention is currently being given to the potential impact of oil-related
development in coastal regions following the publication of Environmental and Social Impact Assessments and Management Plans relating to the Jubilee Oil Field discoveries
473 Coastal area management bull Climate and vulnerability and adaptation assessment on water resources agriculture and the
coastal zone Projects (1997-1999) The projects assessed the vulnerability of the coastal zone to climate change
bull Coastal area management plan for Princess Town (1998-2000) which aimed at providing a plan for the management of Princess Town
bull Keta Sea Defence Project Work (2000-2004) The project aimed at protecting the Keta and its environs from the episodes of erosion faced in the area and also to ensure improvement in environmental and socio-economic conditions at Keta and its immediate surroundings
474 Regional Programmes bull Gulf of Guinea Large Marine Ecosystems Project (1996-1999) The project developed an
effective approach to prevent and control pollution in the Gulf of Guinea and conserve its biodiversity As a result regional institutional capacities were strengthened and also a coastal zone management profile and plans produced
bull UNEP WACAF Projects 1 amp 2 This aims at institutionalising and coordination of national contingency plans monitoring of pollution in the marine environment and control of coastal erosion
475 Other major programmes Other recent programmes and activities in the marine and coastal environments have included
bull Ghana Environmental Resources Management Project in Coastal Wetlands bull Fisheries sub-sector Capacity Building Project bull Establishment of a Protected Wetland Ecosystem on the coast bull Development and Implementation of Oil Spill Contingency Plan bull
48 ONGOING PROJECTS Ghana is currently implementing several projects in the marine and coastal area Some of these projects are linked to developmental projects for which impact assessments are required under the Environmental Assessment Regulations of 1999 Some of the projects are large scale in nature with extensive baseline and monitoring studies like the Keta Sea Defence Project and the West Africa Gas Pipeline project Others are projects being implemented under the auspices of the United Nations agencies and non-governmental organisations include
bull Combating Living Resource Depletion and Coastal Area Degradation in the Guinea Current LME through Ecosystem-based Regional Actions
bull Amansuri Conservation and Integrated Development Project (ACID) bull Danida Water and Sanitation Sector Programme II Support to Integrated Water Resources
Management (IWRM) Component (2004-2008)The Densu Basin aspect of the IWRM component
bull Reduction of Environmental Impact from coastal tourism
bull Bui Hydro Power Project
bull Sea Defence Project at Atorkor
bull Sea Defence Projects in selected towns in the Western Region of Ghana
36
49 CONCLUDING REMARKS
This chapter has highlighted the wide range of conventions laws policies regulations and activities affecting the inland and coastal regions and inland freshwater and marine environment of Ghana It will be important to keep all of these processes and procedures under review as the Fisheries and Aquaculture Sector Development Plan is taken forward to the implementation stage
The main responsibility for ensuring delivery of the Fisheries and Aquaculture Sector Development Programme will rest with the Fisheries Department of the Ministry of Food and Agriculture and the Fisheries Commission supported by the MCS Division and Ghana Navy However a key part of the programme is the development of local co-management arrangements and the Ministry of Local Government and Rural Development and individual District Assemblies will play a key role in helping to form and sustain Community Based Fisheries Management Committees
Over time a significant number of fishermen and individual fish processors are likely to leave the sector as harvesting landing and processing of the catch becomes more efficient Management of these changes especially where disadvantaged and vulnerable sections of the community are affected will need substantial support and investment and a high degree of coordination amongst government ministries and agencies NGOs and international partners to ensure that development assistance is effectively targeted
37
CHAPTER 5 WORLD BANK SAFEGUARD ISSUES
51 INTRODUCTION
The World Bankrsquos proposed funding support to the Government of Ghana covers an initial five yearsrsquo period which could potentially be extended at a later date As the Government of the Republic of Ghana notes in the draft FASDP ldquoimproving the management of the countryrsquos fisheries and ensuring that the impacts on individuals and communities are properly addressed will take 20 or more years to effectrdquo It has therefore been judged important in this report to distinguish between changes that might occur as a direct result of the World Bankrsquos financial assistance thereby triggering the Bankrsquos environmental and social safeguards and changes that could result from longer term adjustments to fisheries and other sectors of Ghanarsquos economy as a result of wider influences by Government other donors and world-wide factors (for example international progress in world trade agreements)
The aim in this chapter is to identify changes which are likely to fall within the purview of the World Banks reputational risks and responsibilities under the first five years of the Fisheries and Aquaculture Sector Development Plan (FASDP) It should be clearly understood that the views expressed are those of the consultancy team and it will be for the World Bankrsquos internal advisors to decide what formal recommendations are made to the World Bank Board
Trends that may emerge in later stages of the implementation of FASDP ndash subsequent to the initial five year period - are discussed in chapter 6
52 THE CURRENT SITUATION
The general status of Ghanarsquos fisheries has been described in Chapters 3 while the legal and policy context has been set out in Chapter 4 The World Bankrsquos investment is being planned specifically to support government policy with the aim of providing a more efficient and better regulated fisheries sector Currently open access is leading to progressive deterioration in fish stocks and lower economic returns Based on many international examples of successful intervention the current proposals (see Chapter 2) are to provide support to introduce formal licensing of all vessels and proper monitoring and control over the seasonal timing and location of fishing activity use of gear and approved nets and self regulation through co-management structures under which the Government and fishing communities will work together to achieve recovery of fish stocks higher income levels for fishers and better returns on catches by reducing post harvest losses and improving processing and marketing operations
53 ANTICIPATED OUTCOMES
It is expected that the proposed reforms and changes will eventually lead to significant improvement in the marine environment restoration of fisheries and enhanced incomes In this respect the provision of grants and loans from the World Bank will bring about major benefits to the economy livelihoods and the environment in the longer term The question that has to be addressed however is - are there likely to be any short term adverse environmental or social consequences from the Bankrsquos own investment strategy Answers are considered in relation to each of the planned components sub-components and activities which are summarised in Table 51 A colour coding and numbering system has been adopted to distinguish those activities that are seen as particularly relevant from the standpoint of the environmental and social assessment Elements highlighted in green are those likely to have positive and beneficial effects on the environment and social conditions those highlighted in orange red have potentially negative or adverse consequences if not handled properly
38
Component 1 Good Governance and Sustainable Management of the Fisheries
Sub-Component 11 seeks to develop the capacity rules procedures and practices that will lead to better governance As such these procedural interventions will have no direct effect on the environment or social conditions of fishing communities However it will be important to ensure that the drafting agencies (government departments and consultants) give due attention to environmental and social objectives during this phase of work Three specific areas are highlighted including undertaking a socio-economic impact assessment with mitigation measures as part of the plan for fishing capacity reduction reviewing the economic and social implications of subsidies and fish import tariffs in the fisheries sector and developing the policy for the development and operation of community-based management networks built around defined fisheries management units
In developing regulations and guidelines it will be important to consider how less able individuals and vulnerable sectors are going to adapt to new systems For example the new regulations on licensing canoes including completion of registration forms the display of registration numbers on vessels and demonstration of basic competence in health and safety standards may prove taxing demands for owners and crew lacking any formal education Similarly legal instruments that are used to remove fuel subsidies or other benefits will need to be carefully explained A socio-economic impact assessment is proposed in the draft PAD to be accompanied by appropriate mitigation measures This assessment should consider amongst other things
bull whether support should be offered and if so under what conditions to any company community or individual who fails to secure a license for a particular class of vessel
bull how the transfer or sale of licenses will be regulated in the wider public interest to ensure transparent processes and avoid the creation of monopolistic and oligopolistic elites
bull who wins and who loses from any planned changes to subsidies and fish import tariff adjustments
bull how the performance of community-based management networks will be judged bull what action will be taken to mitigate the loss of any traditional fishing grounds that become the
subject of marine protected area development or are subject to exclusion zones to protect oil drilling and production platforms
Sub-Component 12 introduces the concept of fishing rights This is to be initiated through a series of four pilot stakeholder-based fishery initiatives and the rolling out of licensing procedures Discussions with stakeholders have made it very clear that the credibility of the entire fisheries policy and programme could be challenged if these pilots do not show positive and constructive ways of moving forward with fisheries reform There is a great deal of distrust for new procedures amongst the fishing communities based on the knowledge that many previous initiatives have failed It is therefore essential that the pilots are led by a strong implementation team are adequately financed and include a credible transparent and inclusive process for debate discussion and consultation Co-operation from the selected communities will be more likely to be achieved if they can see early results in terms of income generating activities
Sub-Component 13 is targeted at adjusting fishing effort and capacity to more sustainable levels and supporting alternative livelihood opportunities These activities are critical in giving effect to the policy decisions that have already been taken to reduce the size of the industrial and semi-industrial fishing fleet and to strengthen the role of the canoe sector Specific measures are proposed for compensating crew members who lose their jobs and for providing training to young men who are willing to transfer
39
out of the fishing sector The scale of this task should not be under-estimated however since there are currently few alternative employment opportunities in the coastal belt for manual workers with low education and skill levels which typify the status of many young fishermen The concept of creating some additional employment with conservation of the coastal littoral and marine ecosystems is strongly supported since this can be linked with development of tourism
Sub-Component 14 is another element that is strongly focused on delivering improved livelihoods with its emphasis on social marketing communication and transparency The focus on stakeholder participation is particularly welcome and should lead to positive response providing it is backed with direct financial support to participating communities
Component 2 - Reduction of Illegal Fishing
There is no Sub-Component 21 within the Ghana Fisheries Programme
Sub-Component 22 aims to develop monitoring control and surveillance (MCS) systems These measures are largely procedural and apart from the relatively small team that will be recruited to operationalise the systems it will have minimal effects on either the environment or social conditions One element that is highlighted in Table 51 relates to provision of facilities and training for participatory coastal surveillance of small-scale fisheries This should have direct and strongly positive benefits for participants and the communities who are enrolled in the training programmes
Component 3 increasing the contribution of the marine fish resources to the local economies
Sub-Component 31 will support the development of basic infrastructure at nine marine fish landing sites and two inland sites The scale of physical construction will be restricted to repair and minor extension of roads and jetties wharves and construction of net mending screens and storage sheds These activities are unlikely to have any significant adverse environmental impacts and should lead to positive social effects
Sub-Component 32 will underpin efforts to improve fish product trade infrastructure information and systems Introduction of new technology for smoking and curing fish and the extension of existing ice preparation plants will start to have positive beneficial effects within the selected communities
Sub-Component 33 provides a modest level of support to marine and inland aquaculture development Aquaculture development should include finalization establishment and enforcement of current draft operational standards to cater for environmental friendliness of fish culture industry for its own survival The main focus will be on developing policy and legal frameworks together with support for stock improvement These measures will have some impact on affected communities in the short term but are clearly aimed at longer term benefits
40
Component 4 Coordination Monitoring and Evaluation and Program Management
Sub-Components 41 and 42 are directed specifically at strengthening the capacity of the Governmentrsquos institutions for national implementation and regional co-ordination As such they will have no direct environmental or social impacts
54 SUMMARY AND CONCLUSIONS
This review of potential environmental and social safeguard issues under the World Bankrsquos targeted programme concludes that there are unlikely to be any significant adverse environmental or social effects as a result of the planned investments
The only possible exception relates to the effectiveness of measures that are put in place under Sub-Component 12 to support pilot stakeholder-based fishery initiatives It is of paramount importance that these pilots are successful and win the confidence of all participants since failure to achieve positive results could set back the entire fisheries programme For this reason it is essential that planning of the pilot initiatives is linked closely with measures for supporting alternative livelihoods and strengthening processing and marketing initiatives under Sub-Components 13 and 14
A number of the planned interventions may have longer term consequences as policies regulations and bye-laws are put into effect but these will be addressed in subsequent work by the Government of Ghana (see Chapter 6)
Table 51 Elements of the World Bank Programme and assessment of potential environmental and social risks
Description of Component Sub-Component and Activities
Measure of Likely Effects
Large (3)
Moderate (2)
Small (1)
None
Beneficial
3
2
1
Adverse
3
2
1
Component 1 Good Governance amp Sustainable Management of the Fisheries
Sub-Component 11 Developing the Capacity Rules Procedures amp Practices for Good Governance of the Fisheries
Reviewing developing programmes and projects designed to support the Fisheries and Aquaculture Development Sector Plan (FASDEP)
Developing an operational policy to enable implementation of the Aquaculture and Fisheries
Plan for fishing capacity reduction (including socio-economic impact assessment and mitigation) 3 2
Commercial vessel and fishing activity licensing plan including allocation criteria rules for transfer of licenses
41
Sector Development Plan and timetable and schedule of license fees
Compliance strategy and plan
Regulations for the management of fisheries including the identification and specification of fisheries management units (ie stocks species areas)
Recommendations for environmental and social safeguards arising from the review of the economic and social implications of subsidies and fish import tariffs in the fisheries sector
3
Policy for the development and operation of community-based management networks built around defined fisheries management units
3
Policy on adaptation strategies for climate change and marine protected area development
2 2
Review of the Ghana Tuna Industry to identify policy or infrastructure needs that threaten Ghanarsquos hub status
Strengthening capture fisheries management systems and capability
Development of fisheries and aquaculture management systems and processes and training
Strengthening fisheries information systems
Installation and operation of fisheries lsquodashboardrsquo database and information collection
Sub-Component 12 Introducing Fishing Rights ($15 M GEF)
Developing 4 pilot Stakeholder-Based Fisheries Management initiatives around defined fisheries units (ie local management initiatives tied to defined fisheries resources including demand-side governance initiatives)
3 2
Introducing and administering a licensing regime (registry establishment training stakeholder education) 2 2
Sub-Component 13 Adjusting Fishing Effort and Capacity to more Sustainable Levels and Supporting Alternative Livelihood Opportunities where Needed
Vessel decommissioning Decommissioning of 60 to 80 industrial trawlers in an environmentally friendly manner
2
Developing alternative livelihoods for crew of decommissioned industrialsemi-industrial
Skills training and small business development training and support for young (18-30 yrs) industrialsemi-industrial crew members willing to transition out of the sector
3
42
vessels
Alternative livelihood development to incentivize voluntary capacity reduction in canoe sector
Alternative livelihoods fund and CDD support to targeted fishing communities
3 2
Marine Resource Conservation
Would include confirming conservation priorities and management regimes and possible provision of support for alternative livelihood options (funded under 133) associated with conservation of coastal littoral and marine ecosystems as well as de facto protected areas associated with the development of oil and gas extraction
3
Sub-Component 14 Social Marketing Communication and Transparency)
Communications stakeholder consultations and awareness raising programs to support fisheries development
3
Component 2 Reduction of Illegal Fishing
Sub-Component 21 does not apply to Ghana
Sub-Component 22 Monitoring Control and Surveillance (MCS) Systems
Developing compliance systems and capability
Development of judicial and policy capacity (training)
Compliance risk assessmentstrategy systems and process development
Enforcement Unit establishment (dedicated facility)
Coastal surveillance stations 2
Facilities and training for participatory coastal surveillance of small-scale fisheries
3
Training for surveillance officers
Operation of aerial and water patrols (vessel leases aerial patrols operational costs patrol vehicles)
Observer program
Compliance education (stakeholder training signage) 1
Upgrademaintenance of the Vessel Monitoring System (VMS)
43
Component 3 Increasing the Contribution of the Marine Fish Resources to the Local Economies
Sub-Component 31 Fish Landing Site Clusters
Product diversificationvalue chain development
9 marine landing sites (basic infrastructure) at Axim Dixcove Fete Jamestown Moree Mumford Senya-Beraku Teshi and Winneba
3 1
2 inland fish landing sites (improved access and berthing infrastructure) at Abotoase and Dzemeni
3 1
2 ports developed (technical studies for 1 new port at Axim and additional berthing space in existing port of Elmina)
3 2
Sub-Component 32 Fish Product Trade Infrastructure Information and Systems
Export certification center development
Fish processing technology improvements 1 1
Technical assistance training and goods to support the National Fisheries Advisory Group
Sub-Component 33 Marine and Inland Aquaculture Development
Developing aquaculture policy and legal framework
Improving genetic quality of Tilapia fingerlings and breedstock
Catalyzing aquaculture development 2
Component 4 Coordination Monitoring and Evaluation and Program Management
Sub-Component 41 National Implementation
Technical assistance for Secretariat to the Fisheries Commission to implement the Project
Sub-Component 42 Regional Coordination
Technical assistance for Regional Coordination Unit at the CSRP support to Fisheries Information Systems (lsquoDashboardrsquo)
45
CHAPTER 6 ENVIRONMENTAL AND SOCIAL ASSESSMENT OF DRAFT FISHERIES AND AQUACULTURE SECTOR DEVELOPMENT PLAN (FASDP)
61 INTRODUCTION
This chapter examines environmental and social issues which need to be considered as part of the overall structural and economic adjustments in Ghanarsquos fisheries sector in the longer term (ie 1-15 years) The assessment deliberately focuses on the longer term because it will take a number of years before current plans start to have their full effect However the same temporal considerations apply to measures that are designed to avoid or mitigate potentially harmful effects so it will be important to start planning remedial actions as part of the joint Government of Ghana and World Bank fisheries programme
611 Key sectors and activities The fishing industry is divided first into marine capture and inland capture fisheries and then aquaculture For each of these three sectors activities are then broken down as follows Marine Capture Fisheries CATEGORY ACTIVITY Stock Management Research Surveillance reef building Harvesting Vessels Gear Skills capacity Marketing Sellers Buyers Processing Fresh fish Sun dried Smoking Freezing Consumers By market sector Support Sectors Boat Canoe Building fuel supply net making kiln construction
refrigeration transport cold store management Legal Enforcement Financing Investment in all elements Infrastructure Harbour wharf processing plant construction
Inland Capture Fisheries CATEGORY ACTIVITY Stock Management Research Surveillance Harvesting Vessels Gear Skills capacity Marketing Sellers Buyers Processing Fresh fish Sun dried Smoking Freezing Support Sectors Boat Canoe Building fuel supply net making kiln construction
refrigeration transport cold store management Legal Enforcement Financing Investment in all elements Infrastructure Harbour wharf processing plant construction
46
Aquaculture and Mariculture CATEGORY ACTIVITY Stock Management Research Surveillance Rearing Roe fingerling production cage -pond rearing Harvesting Vessels Gear Skills capacity Marketing Sellers Buyers Processing Fresh fish Sun dried Smoking Freezing Support Sectors Boat Canoe Building fuel supply cage construction kiln construction
refrigeration transport cold store management Legal Enforcement Financing Investment in all elements Infrastructure Harbour wharf processing plant construction
612 Evaluation Criteria The environmental and social assessment has been undertaken using a matrix (See Annex 114) which analyses the key sectors and activities of the fishing industry and the changes that are envisaged against a set of evaluation criteria Evaluation Criteria are broken down into environmental and social issues distinguishing between beneficial and adverse effects Table 61 below shows the relationship between the groups of criteria Table 61 List of Evaluation Criteria
Environment Social
Positive Adverse Positive Adverse
bull Sea bed rejuvenated
bull Fish stocks recovered
bull Biodiversity enhanced
bull Sea bed degraded
bull Fish stocks reduced
bull Biodiversity reduced
bull Increased harvest (catch volume)
bull Increased catch value
bull Reduced costs of inputs
bull Increased profit
bull Enhanced livelihoods
bull Increased job opportunities
bull Increased local economic multiplier
bull Reduced harvest (catch volume)
bull Reduced catch value
bull Increased costs of inputs
bull Reduced profit
bull Reduced livelihoods
bull Reduced job opportunities
bull Reduced local economic multiplier
The assessment process has involved systematically considering each sectoractivity against the evaluation criteria and recording either positive or negative results by drawing on the judgement of the consultancy specialists The findings are discussed in the paragraphs that follow and are reflected in Table 81 forming part of the Draft Environmental and Social Management Plan
62 DETAILED ASSESSMENT OF THE MARINE AND AQUACULTURE SECTORS
47
TunaIndustrial fleet streamlined and catch per vessel improved At present industrial trawlers have to travel increasing distances to fishing grounds and while the level of catch is remaining broadly static costs are increasing against available economic returns A major shortcoming is lack of investment in re-equipping the aging fishing fleet Many of the 90 vessels that make up this sector are increasingly unseaworthy and need to be replaced with modern trawlers and gear The plan is to buy out owners of substandard vessels by offering compensation at market value based on a full commercial survey Vessels remaining in the fleet will be required to meet exacting standards By reducing the number of old and inefficient boats this will allow each of the remaining vessels to catch a higher proportion of fish The aim is to ensure that Ghana is equipped with the latest vessels and technology in order to preserve the countryrsquos position as the hub of the West African tuna fishing and processing industry (see also the section on canneries below) The effect of these measures on the environment will remain broadly neutral since the same number of fish will be caught Providing other policies and increased surveillance are successful in preventing trawling in inland waters the smaller fleet will have to fish in deep oceanic waters This could potentially transfer some environmental effects on fish populations to other parts of the migratory cycle However this would become part of the international effort through fishing quotas to regulate overall catches Reduction in the size of the industrial fleet will mean that fewer men are needed to crew and service the vessels However in practice many men who work in this sector have only part time work and since a significant percentage of boats no longer put to sea the number of crewmen who will be displaced could be in the range of 1000-30003
It will be important to set up support services for those losing their jobs including retraining and welfare assistance where necessary
Decommissioning will necessitate the sale of seaworthy vessels and their removal from Ghanaian waters Other boats will need to be broken up and scrapped This process requires heavy duty specialized equipment and can release significant quantities of waste oil other toxic chemicals including refrigerants and asbestos used in pipe and engine room cladding Measures will need to be taken to ensure that proper environmental and health safety precautions are taken that decommissioning takes place in properly equipped boatyards and that all waste products are disposed of without environmental risk Cannery sector optimized The Fisheries and Aquaculture Sector Development Plan seeks to maintain the port of Tema as the centre of the Tuna canning industry in Ghana At present a proportion of Ghanarsquos tuna catch is diverted to neighbouring countries due to constraints on processing capacity These limitations include poor port infrastructure ageing equipment and delays in handling catch for some operators due to preferential treatment of vessels that are part-owned by the existing canneries Options for improvement include encouraging upgrading of the capacity of one or more existing canneries or promoting more competition in the processing sector and improving the infrastructure Providing modern building designs and construction techniques are employed and a full environmental assessment is undertaken in accordance with Ghanarsquos EIA regulations there should be no significant environmental or social risks associated with these development possibilities The potential economic benefit resulting from encouraging investment in this sector is very high
Industrial fishing excluded from inshore waters A major longer-term intention under the new fisheries plan (FASDP) is to ensure that existing regulations that restrict industrial and semi-industrial vessels from trawling in inshore waters are properly enforced This requires provision of surveillance
3 Based on an average crew of 20
48
equipment fast patrol vessels capacity building and training and increased staffing within Government agencies together with a full programme of awareness raising training and financial support to local bodies providing self-governance under new co-management services Restriction of industrial trawling in coastal waters will greatly ease pressures on fish stocks and reduce environmental damage to the sea bed In time this should lead to healthier fish population with more fish to be caught by the canoe industry as a result However the task of policing and enforcing regulations will not be easy and will take a number of years to bring into full effect Reduction in fishing activity by inshore trawlers will displace a number of crew members and have a short-term impact on dependent families until these individuals are either absorbed into the canoe fleet or find alternative employment There will therefore be a need to assist genuinely deserving cases where crew members (and their families dependents) need to transfer to other sectors of the economy These measures will only be required in the short term since the anticipated improvement in fish stocks will lead to improved economic performance in the canoe sector within which the bulk of employment exists
Expansion of deep water fisheries The fisheries plan notes that there may be a potential for exploitation or increased exploitation of some deep sea fish resources However the status and population dynamics of some affected species is not well known so any such activities should be scientifically monitored through research and enforced by MCS
Tema Secondi Port infrastructure improvements (equipmentbuildings) Under present conditions the transfer of fish from commercial and industrial vessels to canneries is often delayed by the time taken to offload crates and manouvre within the port area where there are conflicting activities There are also difficulties that arise when vessels owned by the canneries are given priority for landing leaving other boats waiting for many hours which can result in quality deterioration At this stage no details are available about the precise improvements that could be introduced and this will need to be investigated as the fisheries plan is advanced Any environmental effects from infrastructure improvements would be contained within the existing port areas and should be largely positive in reducing fuel (energy) costs and increasing overall efficiency It will however be important to carry out an environmental review of specific development proposals at the design stage especially if these involve plans for any dredging or for altering facilities for discharging waste and disposing of bilge water Both of these activities can have damaging effects on the sea bed (The first through dispersal of silt and sediment and the second through release of potential contaminants) Socio-economic effects from the infrastructure improvements should also be beneficial by removing delays increasing efficiency and reducing waste However there could be some slight reduction in manpower requirements leading to the need for skills retraining Regulating the catch (eg Fishing for selected species reducing juvenile catch to improve value of catch in inshore waters) The fundamental aim of the fisheries plan is to reduce the harmful effects on fish stocks and low economic returns from fish catches by phasing out open access for all and introducing regulation of fishing activity This is to be achieved through close cooperation between the Fisheries Commission Monitoring and Surveillance Unit as well as marine fisheries management division and individual fishing communities working together under a co-management framework The practical details will need to be worked out through each individual co-management group and initially the World Bank is offering to assist in the establishment of four pilots These bodies will test exactly what is required to increase fishersrsquo awareness to build capacity in self regulation and agree on appropriate measures
49
From discussion with stakeholders it is clear that while the broad principles are accepted the majority of the fishing community simply do not believe that the new regulations will be enforced because they have witnessed the failure of so many previous efforts to introduce firm management A major issue for the planned programme is therefore how to change this critical mindset without which very little progress is likely to be made in practice It will be necessary to demonstrate through the pilots that by regulating fishing activity direct benefits will accrue to those participating fishing communities Unfortunately efforts to eliminate harmful practices are unlikely to result in an immediate gain in fish stocks Instead catches are likely to fall in the short term It will therefore be essential to introduce other forms of incentive to cushion short term losses Such measures might include the purchase of new nets and gear for sale at subsidized price to local cooperatives the introduction of cash incentives for canoes demonstrating best practice in the use of gear and nets preservation of the catch using ice and landing and marketing fish of the required size and quality As restriction of open access starts to take effect there should be positive environmental gains in terms of improving fish stocks and less damage of the sea bed On the other hand both fishers and fish processors will feel the adverse temporary effect of reduced catches These social and local economic impacts will need to be monitored closely and assistance provided to help foster alternative livelihoods Cephalopus (Octopus) harvesting encouraged in inshore waters Although most fish species are currently exploited to unacceptably high levels within coastal waters there is a specific opportunity to increase the number of octopus caught by pot fishing This fishery could be developed by both the semi-industrial and canoe sectors Taking octopus in pots would have no adverse physical impacts on the sea bed and could allow very slight expansion in fish species that are preyed on by octopus At the same time it is important to note that there is only limited information on species composition and functioning of selected marine habitats including those of the octopus and more research should be undertaken on this and other species that could be selected for expanded fishing activity There would be clear socio-economic benefits arising from the creation of this new fishery Focusing fish landing at specific landing sites (to improve opportunities for subsequent marketing processing) Plans are already being developed for the enhancement of landing and processing facilities at a number of existing locations along the coast These locations include the construction of harbours at Jamestown and Elmina and development of landing sites at Teshie Ada Axim Dixcove Winneba Mumford SenyaBeraku Gomoa Fetteh Moree Keta Dzemeni and Tapa Abotoase Two sets of issues need to be considered in relation to these improvements all of which affect existing fish landing and processing sites The first is the nature of the physical works and infrastructure and it s potential effect on the marine and terrestrial environment The second is the socio-economic impact Both Elmina and Jamestown are long established fishing ports where the catch is landed either directly onto the beach or shallow wharves It is understood that the primary aim of the improvements will be to increase the area of permanent wharves to make it easier for fish to be offloaded to reduce the time taken in transferring stock to processing plants and to introduce modern technology In the case of other smaller landing sites the scale of improvements will be quite modest involving improvement to existing short stretches of access road the erection of stores for nets and other gear and provision of covered areas to provide shade for net-mending With all proposals for physical infrastructure development there will be a need to consider possible
50
environmental implications Due to the existing nature of these sites there are no major industrial or other commercial processes in the vicinity which could give rise to cumulative impacts including contamination of fish products The scale of plant needed for ice-making and storage and commercial smokeries is commensurate with the artisanal nature of the fishing activity itself and would not give rise to any significant environmental effects on air or water quality Harbour works could potentially involve some small scale dredging (for example the removal of accumulated silt) Where dredging is required it will be important to identify disposal areas (either at sea or on land) where silt can be deposited without damage to sensitive habitats In terms of economic and social impacts it is not clear at this stage who are likely to be the major investors from the private sector although it may be assumed that existing operators who have access to finance will be the main beneficiaries Over time as landing marketing and processing become more efficient it is possible that individuals in the traditional fish smoking sector will lose a significant proportion of their trade as the product switches to fresh or frozen fish sales for transfer to the major urban markets and the beach price for fish rises The draft Ghana fisheries and aquaculture sector development Plan notes in annex 2 that proposed facilities associated with the ports and landing sites may not have support from fish mammies or at least formidable commercial advocates able to resist any opposition from that quarter Inspection of major fish landing areas like Elmina and Sekondi indicates that the existing social and commercial structure of support activities to fish harvesting is very complex and involves almost every member of the community including children and the elderly Such activities include net mending boatbuilding metalworking (for cooking pots stoves and grills supplies (ropes weights tar paint wood) fuel supplies ice crates transport etc Leaders of the fishing community confirmed that in principle the improvements of facilities is welcomed provided that safeguards are in place for those who may lose part or all of their current trading activity through rationalisation Stabilise fleet capacity at a sustainable level Fishery experts consider that there would be significant benefits in reducing the number of canoes from the present 10000-12000 to around 8000-9000 which correlates with the number operating in the mid 1990rsquos when catches were at optimum levels At the same time the Fisheries and Aquaculture Plan stresses that the canoe sector will remain at the heart of the Ghana fishing industry and this has strong political enforcement Consequently there is unlikely to be any enforced reduction in the number of canoes holding licenses and owners of all existing canoes will be able to register their vessels The ability of canoe owners to pay annual licence fees should rise as the overall measures to increase efficiency and improve catches take effect However many people anticipate that over time as the annual cost of holding licenses rises less efficient fishers will sell their licenses (and hence their rights to fish) There may therefore be a de facto reduction in the size of the canoe fleet Even if numbers do not decrease the fleet could be stabilized at its present size by taking a decision not to grant new licences The draft plan discusses the fact that under existing law (section 53) there is a requirement for licenses to be issued on demand (presumably to ensure that Ghanaians are not barred from subsistence fishing) It is argued in the plan that this is a misconception since canoe fishing is largely a commercial activity and it is concluded that lsquoit is therefore essential that the number of canoe licenses can be controlled in future and the legal basis for these controls must be reviewed as a matter of priorityrsquo Decisions of this nature will require the full support of local co-management groups if they are to be effective but committees could easily come under pressure to make exceptions as the coastal population continues to rise and families without alternative livelihoods start lobbying for assistance
51
Accusations of preferential treatment of certain individuals by committees (or committee officials) - possibly linked with suggestions of bribery and corruption -could cause a lot of social tension and start to undermine community trust in the need to work together to improve fisheries management It is therefore most important that the detailed proposals for co-management address this risk and include proposals for mitigating individual hardship of the less advantaged ndash for example by offering voluntary retirement with some form of incentive Influencing marketing to maximise value and reduce post harvest losses (marketing cooperatives strong market structures etc) FAO has estimated that physical post harvest losses in Ghana amount to between 3 and 17 of smoked fish production and 16-20 of gillnet landings The plan notes that introduction of lsquonew generationrsquo small scale fish smokers should be introduced to replace the traditional Chorkor model This would improve fish product quality by eliminating charring of fish over open flames and also protecting operatorsrsquo eyes from the damaging effect of smoke and particles The other major improvement in post harvest value and profits would arise from greater use of ice throughout the supply chain Developing Aquaculture A distinction needs to be made between aquaculture development in ponds and dugouts which are self-contained and fish rearing in cages within open water In the case of farm ponds the commercial rearing of fish is little different to other forms of intensive livestock rearing Providing there is no direct connection to rivers and streams there is little likelihood of interaction between farmed and wild stocks which could spread fish infections and parasites In the case of fish farms in open water (rivers and lakes) there are well known risks of the spread of disease which can arise if overstocking occurs Intensive feeding of large numbers of fish in a confined area can lead to significant deterioration in water quality through the build up of nutrients from wood and waste It is also possible for antibiotics and growth hormones to be dispersed beyond the area of farm cages Genetic modification of farmed fish can also affect the local fish population through escapes All of these issues are capable of being managed and mitigated through good initial planning and design and subsequent maintenance and supervision It will therefore be necessary to develop additional regulations and guidelines specifically for the aquaculture sector 63 SUMMARY OF ENVIRONMENTAL RISKS AND OPPORTUNITIES Review of the full range of governance and development activities suggests that there are no high levels of risk to the marine or littoral environment Successful implementation of the Policy and plan should in fact result in very significant environmental gains Over a timespan of 5-20 years five activities in particular should result in significant improvements in the condition of the sea bed in coastal waters (to a depth of 30 metres) reestablishment of benthic flora and niche habitats increased fish stock and enriched biodiversity These interlinked activities are bull The exclusion of industrial vessels and trawling within coastal waters bull Regulation of fish catches through zonation seasonal control of fishing and standards for vessels
gear bull Stabilisation of the fishing fleet within sustainable harvesting yields bull The adoption of management plans formulated and agreed with full cooperation of local
communities bull The introduction of fishing rights through co-management agreements and bull Well planned consultation and information dissemination throughout the fisheries sector
52
Three components of the development plan have been identified where minor to moderate risk to the physical and biological environment could arise if proper design and implementation standards are not adhered to These relate to bull A potential risk of over-exploitation of new catch species in deep water off the continental shelf if
such development is not accompanied by through research to establish the sustainable yield of target species
bull Strictly localized effects on the physical environment from construction of landing wharves or jetties and other harbour facilities and
bull Infrastructure development at the existing ports of Tema and Takoradi All of these risks are capable of being fully managed by improved governance in the fishing sector and EIA procedures that are well-established in Ghana 64 SUMMARY OF SOCIO-ECONOMIC RISKS AND OPPORTUNITIES Implementation of the Plan Project will bring about substantial change in the fisheries sector and over time increased revenue reduction of post[harvest losses and added value to fish products will bring major economic returns At the same time there will be some individuals who do not participate in direct gains and whose livelihoods could be adversely affected if appropriate safeguarding measures are not put in place The level and extent of these socio-economic risks will be determined by 1 the level of commitment that is entered into by Government and its development partners to
deliver incentives to vulnerable and disadvantaged groups and 2 the speed with which the sector is transformed Rapid change could cause significant
displacement of less-efficient operators especially within the semi-industrial and canoe sector which would have serious ramifications for dependent communities However these effects can be marginalized if the development programme is carefully phased to ensure that alternative livelihood and employment incentives are available
The main risks to local livelihoods relate to the potential for bull loss of employment for crews of unseaworthy obsolete vessels ( from all sectors including
industrial semi-industrial and canoes) that are withdrawn from the fishing fleet because they no longer comply with license regulations
bull the inability of vulnerable and disadvantaged groups including artisanal fishers vendors and individual fish processors in small fishing villages to adjust to new market conditions at selected landing sites
53
CHAPTER 7 ASSESSMENT OF POLICY OPTIONS
71 INTRODUCTION
In order to place the significance of the environmental and social safeguards assessment in context this chapter examines the possible consequences of different policy responses to the existing challenges that face the fisheries sector in Ghana These different policy responses range from a continuation of the status ndashquo effectively a ldquodo-nothingrdquo option (A) to full-scale commitment by all stakeholders to achieving a sustainable fisheries future the ldquoOptimum Solutionrdquo option (C) Various less sustainable outcomes lie in between these two ends of a continuum of policy choices and these are represented by the ldquoWeak Solutionrdquo option (B) 72 OPTION A ndash DO NOTHING Background research and discussion with stakeholders indicates that practical capacity to deliver on clearly stated national goals for sustainable fisheries livelihoods and the reduction of poverty is weak This situation exists despite the fact that Ghana has a strong legal framework for management of its fisheries including the Law Policies and Regulations There is inertia and strong resistance on the part of the majority of players to accept that it is largely their own actions which are responsible for present conditions This in turn leads to the attitude that it is only the lsquoGovernmentrsquo that must act by providing increased subsidies and cushioning the industry against further deterioration in catches Unfortunately there is overwhelming evidence from around the world that where fish stocks are exploited beyond their natural capacity to regenerate this can lead to sudden and near-total collapse Ghana has historically been one of the strongest fisheries in West Africa but the signs are ominous that current levels of exploitation are leading to progressive decreases in annual catches for most species in both marine and inland waters As fishing effort intensifies with an increasing number of all types of vessel using illegal methods and inappropriate gear the distinction between the traditional lsquopeak season and lean season (linked to migration patterns breeding cycles and upwelling) is becoming blurred This is clearly illustrated by a statement from one of Elminarsquos fish mammies ldquowe use to smoke the herring in the peak but now the fishers bring them all the yearrdquo Use of monofilament nets light dynamite and chemicals to obtain fish in the lean season is aggravating a situation where too many boats are chasing too few fish Many fishers blame the reduction of catch on global warming for increasing water temperature the emergent oil and gas industry for restricting access to traditional fishing grounds and industry and urban development for increasing pollution leading to deterioration in water quality Each of these assertions warrants careful consideration but the industry is generally in denial when it comes to the primary fact ndash too many fish including juveniles are caught to allow regeneration of the stock In addition weak governance and lack of resources to ensure implementation of policy result in a situation where the law can be ignored with impunity If collective failure to recognize the seriousness of the current position and lack of commitment to taking hard decisions continues the omens for the future are not good Within a period of 10-15 years fish catches could fall by 50 or more from their present level Impacts on each species would vary and catches of some fish with regional or global migration patterns could remain viable (although this depends on the international conservation effort) On the other hand stocks of fish that provide the mainstay of local food resources herring and sardine could be decimated
54
Complete collapse of all fish species is unlikely but it is possible to envisage a situation where catches might fall below 300000 tonnes a year by 2025 (a reduction of more than 25 from present levels) The most serious consequences would be felt as a result of the social and local economic impact on fishing communities Perhaps 30000 men representing the crews of 3000 canoes and semi industrial boats and 15000 women engaged in marketing and processing would lose their present livelihoods Population migration away from the coast could follow and severe social pressures and local economic hardship This is clearly a ldquoworst caserdquo scenario and if conditions were to worsen gradually it might be possible to intervene but the fact has to be accepted that fish stocks are dynamic and subject to rapid decline (as in the case of the North Sea Herring and Atlantic Cod) 73 OPTION B THE lsquoWEAKrsquo SOLUTION The bleak future painted in Option A is unlikely to arise if the present policy and draft fisheries development plan is followed since these are specifically directed to addressing the major challenges However realization of the aims is dependent upon delivery across a wide range of initiatives by multiple stakeholders The following paragraphs illustrate some of the ways in which delivery of policy objectives might be thwarted These may be summarized as
bull Commitment to good governance and institutional reform bull Political resolve to implement unpopular measures bull Availability of adequate technical and financial resources bull Inertia to necessary changes in fishing practice
Good Governance and Institutional Reform Fundamental reforms are required to fully equip the national fisheries management effort at government level This includes introduction of change management clarification of responsibilities for senior staff rationalization of financial management systems provision of equipment expansion of staff numbers additional training and capacity building As an illustration of the extent of the effort required reference can be made to just one topic area the issue of monitoring control and surveillance At present the Fisheries Commissionrsquos MCS Unit has only 10 employees to oversee implementation of the fisheries regulations throughout Ghana This number will be increased as other institutions are engaged in joint monitoring initiatives but it is obvious that staff numbers and capacity will need to be expanded if regulations on fishing activities are to be affected Enforcement is only one part of the equation however Much greater emphasis will need to be placed on voluntary controls and self-policing at community level through Co-management schemes
Failure to press ahead with governance and institutional reform could delay the process of introducing and registering licenses which represents a crucial first step in moving from open access to managed access in the fisheries sector Given the urgency for action the five years allowed in the current plan for completing the registration process seems very generous Political resolve to implement unpopular measures Stakeholder meetings have confirmed the significance of party political influence as a constraint on achieving progress in the reform of the fisheries sector The offer of incentives like subsidies or the promise of new facilities and equipment are regularly employed by individual politicians to garner votes whether or not these form part of party manifestos Examples have been quoted to the consultants where enabling regulations that might restrict fishing access and prove unpopular amongst the fishing community are quietly ignored and officers may be discouraged from pursuing breaches of the law where the offender has political influence These issues arise with governments of all political
55
persuasions and can apply at all levels from District Assemblies through to regional and national committees
A serious issue with fisheries sector reform is that once actions have been taken to conserve fish stocks it may be years before the full benefits are felt and the results are evident in terms of increased catches This makes it harder for governments to institute unpopular reforms ndash even though these are in the best interests of the nation fishing communities and individuals Fishermen and their families are used to seeing an instant lsquosame day returnrsquo on their catch and are less willing or able than stakeholders in other economic sectors to wait for gradual improvements There is an urgent need to establish cross-party support for the fisheries sector in Ghana and to seek agreements between the main political parties to support established policy and regulations where these are in the interests of delivering sustainable fish stocks Availability of Technical and Financial Resources The process of moving from complete open access to restricted use rights for both marine and inland capture fisheries will take many years to complete Progress will be heavily influenced by the level of political will availability of technical assistance and financial support Existing subsidies (pre-mix fuel and import tariffs) are seen as a deterrent to the encouragement of more efficient business practices However in order to reduce dependencies on these forms of government aid there is also a need to underwrite new forms of economic enterprise by giving help to start-up businesses developing training centres and promoting alternative livelihoods for those individuals who are either displaced or voluntarily give up work in the fisheries sector Inertia to Change Traditional fishing practices are quite literally a way of life for many Ghanaians and have been handed down from generation to generation These traditions are closely interlinked with cultural practices and power and influence resides in specific families with hereditary authority In order to change attitudes and gain acceptance of new approaches to fishing there is a need for a major awareness building and communications strategy targeting in particular the traditional leaders of the fishing industry Without such a plan it will be difficult to break down the internal resistance and inertia towards change The constraints that have been outlined above in relation to the lsquoweakrsquo option are very real and in combination they present a serious barrier to progress It will require real political commitment on the part of Government and strong financial support from international partners to break down these barriers 74 OPTION C THE lsquoOPTIMUMrsquo SOLUTION
The new Draft Fisheries and Aquaculture Plan together with the Act and Policies provide a solid foundation for revitalising the fisheries sector in Ghana However for the reasons discussed in relation to options A and B above there are a number of impediments that need to be overcome In addition to the measures in Option B an ldquoOptimumrdquo solution would also include
A coherent mix of Incentives (carrots) and Regulation (sticks) A top priority in developing existing strategies and plans will be to ensure that measures are in place to offer encouragement and practical assistance to fishers to convert to more sustainable practices while at the same time introducing effective enforcement There are some real challenges with both of these goals
56
New forms of incentive need to be developed to convince boat owners and their crews that it is worth their while to drop illegal methods (dynamiting use of monofilament nets etc) and to reduce the level of fishing effort (through close seasons introduction of restricted zones etc) Without these incentives it is highly unlikely that there will be significant take-up of the fisheries stock management and conservation message Special attention needs to be given to the role of chief fishermen and local community councils in developing effective local policing since it is impractical to rely on a national MCS team to regulate canoe activity in either the marine or inland capture fisheries The national MCS team will have its own responsibilities for policing local and international waters in relation to industrial and semi-industrial sized vessels Integrated Coastal Development The long term success of the fisheries strategy depends upon reducing fishing effort to a level at which catches become both sustainable and profitable for those who remain in the business This in turn requires that those displaced from the industry are able to find gainful employment and livelihoods in other sectors of the economy The fisheries industry is often seen as a separate economic sector which attracts its own funding and support but in order for the necessary reforms to take place these attitudes will need to change A new approach is required to lsquointegrated coastal developmentrsquo following the lessons from integrated rural development Many fishing inland and marine fishing communities are almost wholly dependent on fishing with less than 10 of the local economy being devoted to other industries Reform of the fishing sector therefore requires that as much ndash if not more ndash effort is devoted by government and its international partners to building up complementary economic activities in construction transportation manufacturing food processing environmental conservation and tourism There is a need to explore new state industry partnerships to establish appropriate economic development agencies and to coordinate activities between relevant state institutions ministries and departments under the current decentralisation initiatives with district assemblies taking a prominent role If initiatives of this sort are taken forward it will make the task much easier in persuading conservatively ndashminded fishing communities that they need to simultaneously develop their own entrepreneurial flair and impose their own discipline
57
Chapter 8 DRAFT ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK (ESMF) 81 INTRODUCTION Previous chapters of this report have described the principal environmental and social impacts that are likely to arise from reform in the fisheries sector This chapter sets out the Framework (ESMF) for an Environmental and Social Management Plan (ESMP)The first step has been to outline specific objectives to be achieved through implementation of the ESMF These objectives relate specifically to the issues described in earlier chapters Subsequent sections of the chapter detail the measures which are required to respond to specific areas of environmental and social impact through mitigation and amelioration works They also describe the types and level of environmental monitoring required together with the institutional aspects which need to be improved in order to support the fisheries sector 82 STRATEGY AND OBJECTIVES The basic aim of the environmental and social management plan is to set out guidelines for participatory programs under which members of local fishing communities and civil society in general can become involved in the design and implementation of local fishery co-management maintaining sustainable local livelihoods and achieving local monitoring of fishery efforts The basic principle for future fisheries management is that both marine and inland waters will be demarcated as territories for use rights to fisheries (TURFs) The principal goal of government policy in the fisheries sector is to ensure that the fisheries industry plays an increasingly important role in supporting the growth of the economy as outlined in the Ghana poverty reduction strategy (GPRS II) and the Republic of Ghana fisheries and aquaculture policy This goal will be supported by implementation of the fisheries and aquaculture sector development plan over the next five years In this timescale the aim will be to bull improve management of fisheries the conservation of aquatic resources and protection of the
natural environment bull promote value addition in the fisheries sector and the improvement of livelihoods in fisheries
communities bull encourage sustainable development of aquaculture bull improve the services provided to the fisheries sector by the fisheries commission and supporting
institutions The overall consequences of this strategy and the investments that are being made by the government and its aid partners will be stabilisation of fish stocks and sustainable catch levels a strengthening of the national economy and creation of a more robust fisheries industry with consequent benefits for fishing communities Impact assessment confirms that the result will be significant benefits for the marine environment and local economy However depending on the rate of transition from an open access to a fully regulated market a number of adverse effects could arise unless appropriate mitigation measures are put in place Specific issues which require attention in this plan are listed below bull potential risks of environmental degradation through development of new fishing targets in
deep water
58
bull localised environmental impacts at construction sites bull loss of resources for individual operators due to restricted or controlled access to fishing
grounds bull displacement of labour from crews of vessels that are withdrawn from the industrial and semi-
industrial fleet bull Decommissioning of obsolete industrial vessels may not necessarily lead to recovery of fish
stocks Catch Per Unit Effort (CPUE) may increase This could lead to loss of livelihoods to crew members and the owners of the decommissioned vessels it could increase catch for the few vessels remaining in the system
bull increase production costs due to idling time in closed seasons for fishing bull exclusion of some groups and individuals seeking entrance to the industry following completion
of licensing bull concentration of processing and marketing at selected landing sites leaving Fish Mammies and
their dependents in other smaller fishing communities at an economic disadvantage bull displacement of traditional canoe building and other ancillary support industries by more
efficient and modern methods of construction and the inability of some workers in these trades to train and re-skill in the use of modern materials
bull lack of employment opportunities in alternative sectors The ESMF will set out specific actions to address these concerns through a coordinated set of interlinked proposals as follows 1) Preparation of local management plans and close surveillance of all new fishing enterprises in
deep waters
2) Preparation of environmental protection clauses to be included in all contracts and agreements for physical development work
3) Regular inspection by environmental protection officers of construction work at harbours and landing sites
4) Establishment of community management plans to provide support to those groups and individuals who are adversely affected by any of the measures listed above
5) Creation of community liaison groups to actively support community development alternative livelihoods and conversion to new areas of economic activity for those Fisher families or individual fishers who are adversely impacted
6) Introduction of skills training centres and business advice for small and medium enterprise development
7) Establishment of a coastal development agency drawing on the resources of the ministry of local government agriculture and tourism (others to be added) to coordinate integrated projects and initiatives for economic development linked with the existing coastal zone management plans
8) Creation of a liaison group between the government of Ghana and its international development partners to ensure that investment in the fisheries sector is targeted in the most effective way to deliver plan objectives and avoid duplication of effort
59
83 COMPONENTS OF THE ESMF The following paragraphs provide a summary of the draft ESMF 831 Local Management Plans these plans will be prepared for discrete zones of influence around specified fishing settlements Each plan will contain the same standard list of relevant activities that are to be monitored 832 Environmental Protection In relation to construction activity a checklist will be prepared identifying precisely what level of environmental scrutiny is required for specific types of development This checklist will be prepared by the Fisheries Commission with the support and advice of the Environmental Protection Agency 833 Small-Scale Project Development and Livelihood Restoration a list of potential micro-projects will be prepared by the Fisheries Commission which are regarded as suitable for support funding Demand for these micro-projects will be determined at the local level (ie in villages and fishing communities) Applications for funding of micro-projects will be submitted to the community liaison group for vetting and recommendation based on pre-established eligibility criteria Recommended projects will be referred for formal approval at national level (or through the Coastal Development Agency) 84 POTENTIAL PROJECT IMPACTS ON ASSETS AND LIVELIHOODS The project will have some adverse impacts on assets and livelihoods Therefore provisions will be made under the ESMF to minimize all such impacts including those of socio- economic significance and on any environmentally sensitive sites Provisions are also made in the RPF to accommodate all potential situations including cases that may entail actual displacement and livelihood restoration assistance in accordance with the Governmentrsquos policy and World Bank Policy on Involuntary Resettlement OP412 (see Chapters 9 and 10) The potential social and environmental impacts associated with the project (see Chapters 5 and 6) are summarised in Table 81 and the approach to related mitigation measures is defined in section 85 and Table 82 below
Table 81 Potential Environmental impacts and Social issues
Type of Activity Description Environmental Significance
Social Significance
Decommissioning of obsolete industrial vessels
Scrapping of vessels may release toxic waste (contaminated oils asbestos pipe wrapping and insulation etc)
Contamination of landfill dumps
Related health hazards
Laying off of work force Recovery of fish stocks in areas currently over-fished by trawling
Decommissioning of excessovercapacity would result in loss of livelihoods for crew members
60
Plan for fishing capacity reduction
introduction of licensing system for canoes and enforcement of licensing system for semi industrial vessels
Reduced catch from the decline in the use of prohibited fishing methods (activities) as stipulated in the Fisheries Regulation 2010 (LI1968) eg use of light dynamite etc
Reduction in fishing capacity should lead to significant recovery of fish stocks with long term benefits for all
Short term reduction in fishing effort and increased regulation may prejudice vulnerable sectors (illiterate elderly fishers) Capping on new entrants may remove the safety net opportunity offered by fisheries to would-be fishers who may be without alternative livelihoods
Harbour development and landing site improvements
Construction of access road improvements Erection of fish processing and ice making plant The Project could give rise to a small level of physical displacement for some sectors of individual communities
Removal of shelters homes Displacement of boat repair and trading sites for local community
Possible non-voluntary resettlement including vulnerable groups (women children and the elderly)
Adaptation Strategies to climate change
Introduction over time of regulations relating to fishing activity in rivers lakes estuaries lagoons and lsquoareas of upwelling affected by climate change
Measures to combat tackle rising temperature and other climate induced changes should ameliorate environmental impacts
Both beneficial and adverse effects may result from changes in climate (eg faster growth rates from higher water temperature spread of invasive species)
Establishment of exclusion zones ndash oil production and marine protection areas
Restrictions on fishing in oil production areas and marine protection areas
Positive ndash recovery of fish stocks but also potential risks of pollution from oil leaks and human waste
Temporary loss of livelihood for those fishers displaced from lsquotraditionalrsquo fishing grounds
Development of Co-Management System
Creation of 4 pilot Stakeholder ndashbased Fisheries Management Initiatives
Demonstration of practical benefits for the marine environment resulting from elimination of damaging practices
Greater social cohesion and sense of purpose established
61
Type of Activity Description Environmental Significance
Social Significance
Support for PAPs Establishment of enterprise training programmes
Development of criteria for defining Project Affected Persons (PAP) Development of skills training schemes enterprise allowances alternative livelihoods fund
Major benefits for PAPs ndash but scope for misinterpretation mismanagement of programme at local level Jobs created under social significance should be familiar to the fishers ie things they will be willing to do
Developing Compliance Systems
Establishment of enforcement unit and development of facilities and training for participatory coastal surveillance of small-scale fisheries
This component will greatly improve controls over environmentally unfriendly damaging activities
A number of new jobs should be created under this programme
Improvements in fish processing technology
Development of more efficient fish processing plant
This measure should reduce significantly the proportion of fish lost or degraded post harvest Improved fish processing technology will also reduce wood used from the forest as firewood for fish smoking
Potential displacement of vulnerable groups (women children and the elderly)who currently participate in fish drying curing using basic equipment
Construction of fish ponds
Expanding areas of dug-outs and other farm ponds
Small scale impacts on vegetation stream flow
Displacement of existing land users
Catalysing aquaculture development
Encouragement of larger fish farming enterprises Installation of fish cage aquaculture
Localised deterioration in water quality increased nutrients leading to eutrophication potential spread of fish parasites disease
Potential competition with free capture fisheries displacing vulnerable groups in existing fishing villages
62
85 PROPOSED MITIGATION MEASURES AND COST ESTIMATES Mitigation measures The potential environmental and social impacts to be addressed within the context of preparing this Environmental and Social Management Framework are generalized as shown in Table 82 below It is not possible at this time to prepare specific mitigation measures It is expected though that environmental and social assessment studies will be carried out within specific localities as and when required The framework for compensationresettlement (See Chapters 9 and 10) will then be applied incorporating (1) specific institutional arrangements (2) resettlementcompensation eligibility criteria (3) implementation procedures (4) financial responsibilities and (5) monitoring and evaluation plan Livelihood restoration measures Furthermore the livelihood restoration measures will consider issues such as
(1) income levels of affected persons
(2) other non-monetary sources of livelihood
(3) constraints and opportunities for income generation
(4) number of persons not able to revert to previous occupation and
(5) existing skills of affected persons
Table 82 Proposed mitigation measures for some potential impacts
Type of Impact Description of mitigation measures
1 Decommissioning of obsolete industrial vessels
a) A register will be prepared of all industrial vessels that are due to be decommissioned recording the owner and location of each vessel b) A system will be introduced for tracking progress on decommissioning including the means of disposal and measures taken to dispose of all potentially toxic or hazardous materials c) Persons who lose their job or livelihood as a result of a decision to decommission any particular vessel will be entitled to benefit from the skills training schemes enterprise allowances alternative livelihoods fund being developed
2 Plan for fishing capacity reduction
a) A full Social and Environmental Impact Assessment will be carried out on the Plan for fishing capacity reduction and appropriate measures for ameliorating and mitigating adverse effects on affected sectors of the community and PAPs will be incorporated in a revised edition of this Fisheries Environmental and Social Management Framework
63
3 Harbour development and landing site improvements
a) All harbour development proposals will be subject to Environmental and Social Impact Assessment (ESSA) in accordance with EPA Regulations b) Proposals for improvement of individual landing sites will be assessed in accordance with the checklist (832) and submitted to EPA for a ruling on the level of environmental assessment that is required which will depend on the nature of the intended works
4 Adaptation Strategies to climate change
a) An adaptation Strategy shall include proposals for mitigating any impacts on the environment or social welfare of local communities
b) Any strategy for responding to potential effects of climate change on the fisheries sector will be submitted to EPA for review to determine whether an SEA or EIA is required
5 Establishment of exclusion zones ndash oil production and marine protection areas
a) Proposals for restricting access of fishing vessels to oil production areas and marine production areas shall be subject to an Environmental and Social Assessment which shall be submitted for approval to EPA b) In the event that restrictions are likely to adversely affect fishersrsquo livelihoods the provisions set out in 7 below will apply
6 Development of Co-Management System
a) Development of co-management systems will require full cooperation and engagement of all stakeholders In the unlikely event that the provisions of any scheme are challenged by local communities there shall be a right of appeal to the Minister of Food and Agriculture and the Fisheries Commission acting jointly
7 Support for PAPs
Establishment of enterprise training programmes
a) Identification of vulnerable people including women children and the elderly and identification of the cause and impacts of their vulnerability shall be established through direct interviews and procedures to be developed as part of 6 above b) A high priority within the Fisheries and Aquaculture Sector Development Plansrsquo first five year programme will be the development of specific proposals for the establishment of skills training programmes and the establishment of enterprise allowances and an alternative livelihoods fund c) The measures outlined in 7b) above will be targeted specifically at PAPs and vulnerable sectors of the community
8 Developing Compliance Systems
a) All proposals for securing compliance with fisheries regulations shall be subject to review by a fisheries stakeholder committee to be established by the Fisheries Commission with the remit of ensuring that the measures themselves and penalties for failure to comply are commensurate with the ability of offenders to make restitution and do not unfairly penalize vulnerable sectors of the community
9 Improvements in fish processing technology
a) All plans and proposals for the introduction of new fish processing technology shall be published and shall include a statement on the likely impact of the project on existing processors within the local community
64
b) Any members of the public who consider they are unfairly disadvantaged by proposals for the introduction of new technology may apply to the local co-management committee to determine whether or not they fall within the category of PAP (see 6 and 7 above)
10 Construction of fish ponds Proposals for the construction of new fish ponds shall be assessed in accordance with the checklist (see section 832)
11 Catalysing aquaculture development
a) All proposals for aquaculture development shall be in accordance with the provisions laid down in Local Management Plans applying to specific TURFs
65
v
TABLE OF CONTENTS EXECUTIVE SUMMARY 1 PART A ndash ENVIRONMENTAL AND SOCIAL SAFEGUARDS ASSESSMENT AND DRAFT ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK 1 INTRODUCTION 7
2 PLAN AND PROGRAMME DESCRIPTION 11
Part 1 The Draft Fisheries and Aquaculture Sector Development Plan 11 Part 2 The World Bankrsquo Contribution to the Ghana Fisheries Plan 11
3 BASELINE CONDITIONS 15 31 Profile of the Fisheries Industry 15 32 Environmental Conditions 20
4 POLICY AND LEGAL FRAMEWORK FOR ENVIRONMENTAL ISSUES 25 41 World Bank and Other Donorsrsquo Safeguard Policies 25 42 Governance Framework in Ghana 28
5 WORLD BANK SAFEGUARD ISSUES 37
6 ENVIRONMENTAL AND SOCIAL ASSESSMENT OF DRAFT FISHERIES AND AQUACULTURE SECTOR DEVELOPMENT PLAN (FASDP) 45 61 Positive Environmental and Social Impacts 62 Adverse Environmental and Social Impacts 7 ASSESSMENT OF POLICY OPTIONS 53 8 DRAFT ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK 57 PART B NATIONAL PROCESS FRAMEWORK AND DRAFT NATIONAL RESETTLEMENT POLICY 9 DRAFT NATIONAL PROCESS FRAMEWORK 67 10 DRAFT RESETTLEMENT POLICY FRAMEWORK 71 BIBLIOGRAPHY ANNEXES 1 Annex 1 to the Terms of Reference 2 Environmental and Social Evaluation Matrix
1
EXECUTIVE SUMMARY
This report draws together the contents of two separate documents which examine a number of interrelated issues concerned with environmental and social safeguards for the development of the fisheries sector in Ghana
The first document (Part A) contains the Environmental and Social Assessment (ESA) of the Ghana Fisheries and Aquaculture Sector Development Plan (FASDP) together with a draft of the Environmental and Social Management Framework (ESMF) that will be adopted by the Government of Ghana This document is reproduced in Chapters 1-8 of the Composite Report
The second document (Part B) contains the outline structure of Ghanarsquos National Process Framework (NPF) for implementing the design and implementation of local fishery co-managementmaintaining sustainability of local livelihoods and local monitoring of fisheries efforts together with an outline Resettlement Policy Framework (RPF) These elements are covered in Chapters 9-10 of the Composite Report
This Composite Report and its individual components have been prepared on behalf of the Government of Ghana and the World Bank Following review by both parties it will be adopted as part of the framework leading to promotion of the Ghana Fisheries and Aquaculture Sector Development Plan
Chapter 1 of the Report describes the need for environmental and social safeguards in the fisheries sector It notes that the overall aim of FASDP is to improve fish stocks and increase the sustainability of fishing activity which will have long term environmental and social benefits for the Country
Chapter 2 summarises the basic aims of the Ghana Fisheries and Aquaculture Sector Development Plan and proposals for financial and technical aid which are being developed by the World Bank A decision on funding support will be taken by the World Bank in 2011 The World Bank is proposing to support FASDP under four key components These are Good Governance and Sustainable management of the fisheries reduction of illegal fishing increasing the contribution of the marine fish resources to the local economies and assisting with coordination monitoring evaluation and programme management
Chapter 3 provides a baseline description of the current nature and importance of Ghanarsquos marine and inland fisheries which provide 65 of the countries protein requirements and sustain the livelihoods of almost 10 of the Ghanarsquos population Unfortunately however fishing is approaching a crisis In recent years the annual volume of catch has fallen (from in excess of 500000 to under 400000 tonnes) but at the same time fishing effort has increased If it were not for government subsidy the economic returns could no longer be justified since it costs more to catch and land fish than they are actually worth in the market place Fishing activity (principally trawling) is causing substantial damage to the marine environment while illegal methods in the canoe sector including dynamiting and use of chemicals threaten fish stocks and human health
Chapter 4 examines the governance legislative and policy framework under which reforms in the fisheries sector will take place The chapter identifies five World Bank safeguard policies that are potentially triggered by FASDP These are OP 401 Environmental Assessment OP404 Natural Habitats OP 409 Pest Management and OP 411 Physical and Cultural Resources and OP 412 Involuntary Resettlement In most cases the range of projects proposed under FASDP would have minimal impacts under these safeguards but there is nevertheless a need to ensure that adequate
2
protection and mitigation is provided through implementation of an Environmental and Social Management Plan
Chapter 5 considers the four funding components under which the World Bank is proposing to support the Ghana Fisheries and Aquaculture Sector Development Plan These cover
1 Good governance and sustainable management of the fisheries 2 Reduction of illegal fishing 3 Increasing the contribution of the marine fish resources to the local economy and 4 Coordination Monitoring and Evaluation and Program Management The potential for investment to give rise to adverse effects on the environment andor social conditions is reviewed It is concluded that that there are unlikely to be any significant adverse environmental or social effects as a result of the planned investments The only possible exception relates to the effectiveness of measures that are put in place under Sub-Component 12 to support pilot stakeholder-based fishery initiatives The outcome of the overall program will depend heavily on the success of these pilots For this reason it is essential that planning of the pilot initiatives is linked closely with measures for supporting alternative livelihoods and strengthening processing and marketing initiatives under Sub-Components 13 and 14
Chapter 6 provides an analysis of the environmental and social issues raised by the wider fisheries and aquaculture programme and as such it constitutes the Environmental and Social Assessment (ESA) A matrix is used to identify potential interactions between elements of marine and inland fishery capture operations and the natural environment together with possible socio-economic effects A similar matrix is also used to examine the potential for aquaculture development The overall effects of the planned interventions are positive in terms of both environmental and socio-economic gains but there are potentially some adverse social and economic consequences for a limited number of individuals whose livelihoods will be affected by restrictions on access to fishing or from changes in economic conditions affecting the purchase processing and marketing of fish Mitigation measures are considered subsequently in Chapter 8
Chapter 7 briefly considers the possible consequences of taking no action to deal with the declining stocks and profitability of fishing (the do-nothing option A) This is a standard part of the methodology for conducting an Environmental and Social Assessment The conclusions are compared with the alternatives of taking limited action (a lsquoweakrsquo option B) or of implementing the full set of plans and proposals (the lsquooptimumrsquo option C) The comparison includes the conclusion that the fisheries industry is often studied and dealt with in isolation from other parts of the economy However in order for the planned reforms to have maximum beneficial impact a new approach is required to integrated coastal development in which a range of ministries and agencies should be involved
Chapter 8 sets out a draft Environmental and Social Management Framework (ESMF) This picks up areas of risk identified in the ESA Report and proposes remedial action The ESMF notes that the principal goals of government policy are to
bull Improve management of fisheries the conservation of aquatic resources and protection of the natural environment
bull Promote value addition in the fisheries sector and the improvement of livelihoods in fisheries communities
bull Encourage sustainable development of aquaculture
3
bull Improve the services provided to the fisheries sector by the Fisheries Commission and supporting institutions
The Draft ESMF sets out eight specific interlinked actions namely
1) Preparation of local management plans and close surveillance of all new fishing enterprises in deep waters
2) Preparation of environmental protection clauses to be included in all contracts and agreements for physical development work
3) Regular inspection by environmental protection officers of construction work at harbours and landing sites
4) Establishment of community management plans to provide support to those groups and individuals who are adversely affected by any of the measures listed above
5) Creation of community liaison groups to actively support community development alternative livelihoods and conversion to new areas of economic activity for those Fisher families or individual fishers who are adversely impacted
6) Introduction of skills training centres and business advice for small and medium enterprise development
7) Establishment of a coastal development approach drawing on the resources of the ministry of local government agriculture and tourism (others to be added) to coordinate integrated projects and initiatives for economic development linked with the existing coastal zone management plans
8) Creation of a liaison group between the government of Ghana and its international development partners to ensure that investment in the fisheries sector is targeted in the most effective way to deliver plan objectives and avoid duplication of effort
Chapter 9 provides a draft National Process Framework (NPF)) to implement the recommended process framework laid down by the West Africa Regional Fisheries Program (WARFP) which Ghana will become part of This framework explains how eligibility criteria will be employed to determine which settlements qualify as participating communities and what the responsibilities of these communities will be in terms of setting up Co-management Committees (CMCs) and selecting classes of Project Affected People (PAPs) who will be eligible for assistance under national guidelines to be prepared by the Fisheries Commission The ESMP also outlines proposals for income restoration measures in accordance with World Bank guidance as interpreted through the West Africa Regional Fisheries process framework that where open access to fishery resources is restricted for the common good any adversely affected individuals should not be penalized but should receive assistance to restore their livelihoods at least to the extent that they are impacted by the project activities and preferably to an improved state1
1 Extract from Executive Summary Process Framework West African Regionl Fisheries Program (P106063) Cape Verde Liberia Sierra Leone Senegal Commission sous Regionale des Peche Dakar Senegal
Measures are also outlined for conflicts or grievance resolution administrative and legal procedures and monitoring arrangements
ldquoSection V Livelihood Restoration Measures World Bank policy requires that livelihoods be restored at least to the extent that they are impacted directly by project activities and preferably inproved This policy prescription is based on the principle that people who give up most for the public good ndash the PAPs- should not be penalised and impoverished as a result of their loss for the greater good The aim thereopfre is to improve the public good (in this instance marine resources) while also ensuring that those who lose access to resources and income because of restrictions on marine resources are assisted effectively to restore that part of their income that is affected through alternative livelihood measuresrdquo
4
Chapter 10 looks in more detail at specific safeguards relating to possible involuntary relocation of people as a result of the long term fisheries programme It constitutes the Resettlement Policy Framework (RPF) which while not a formal legal requirement of the World Bankrsquos lending policy is nevertheless recommended as good practice
5
PART A ENVIRONMENTAL AND SOCIAL SAFEGUARDS ASSESSMENT
The Environmental and Social Safeguard Assessment comprises bull Three background chapters (1-3) bull Two chapters which deal with assessment of the potential effects of the World Bankrsquos financial
and technical support for the Ghana Fisheries Programme over the initial five years (Chapter 4) and the longer term effects of the overall Fisheries Programme which is expected to run for 10-15 years (Chapter 5)
bull Analysis of the consequences of taking no action (the do-nothing option) in Chapter 7 and bull A draft Environmental and Social Management Framework (Chapter 8)
7
CHAPTER 1 INTRODUCTION
11 INTRODUCTION The government of Ghana is embarking on a Fisheries and Aquaculture Sector Development Plan (FASDP) for restructuring its coastal and inland fisheries The aim is to reverse the current trend whereby fish stocks are increasingly diminishing and the current rate of fishing is unsustainable resulting in less productive fisheries increased costs with declining profitability and the risk of exacerbating nutritional deficiencies and poverty within fishing communities To date the government has enacted legislation (Fisheries Act 2002) prepared policies (2008 updated in 2010) and published regulations (August 2010) but the Ministry of Food and Agriculture and the Fisheries Commission lack the capacity and financial resources to implement all of these initiatives The World Bank is therefore considering a supporting programme of technical assistance and finance which will assist with governance reforms the introduction of licensing for all vessels a reduction in the size of the industrial and semi-industrial fishing fleets and the progressive transfer of fishing activity to the canoe sector International support for Ghanas fishing industry is being coordinated under the West Africa Regional Fisheries Programme (WARFP) This initiative began with four countries Cape Verde Liberia Sierra Leone and Senegal It is now being extended to the following countries Ghana Guinea Guinea Bissau and Gambia A process framework has been developed by the Commission sous Regionale des Peche (Based in Dakar Senegal) to assist member countries of WARFP to prepare their own national process frameworks together with accompanying environmental and social safeguards assessment an environmental management plan and resettlement policy This report has been designed to provide the outline structure and contents for these documents on behalf of the Government of Ghana Another important function of the report is to review the application of the World Banks own Environmental and Social Safeguard policy to the planned investment Both the governments development plan (FASDP) and preparation of the World Banks financial assistance package are at an early stage Consequently this report covers (and can only cover) the broad principles and sets out initial conclusions It will be necessary for further reviews to be undertaken when the Government of Ghanarsquos programme has been developed in more detail Objectives of the Environmental and Social Assessment (ESA) The overall aims of planned interventions in the fisheries industry of Ghana are to improve fish stocks and increase the sustainability of fishing activity which will have long-term environmental and social benefits for the country However the process of introducing change is likely to have some short-term adverse effects on individuals and particularly those who are vulnerable or disadvantaged within poorer fishing communities unless appropriate mitigation measures are taken The purpose of the environmental and social assessment set out in chapter 6 is to identify potential environmental and social impacts both individually and cumulatively and to assess their relative magnitude duration reversibility and importance Based on these findings the draft management framework (see chapter 8) sets out proposals for avoiding or mitigating unacceptable change The process of reforming the fisheries sector will take a number of years and the existing FASDP covers only the first five years With the exception of proposals to scale down the size of the industrial and semi-industrial fishing fleets it is unlikely that major changes will take effect in terms of fishing activity during this five-year period Consequently from the standpoint of the World Banks investment there are likely to be relatively few issues in terms of potential conflict with safeguarding policies Later
8
however significant change is within the fishing industry and particularly onshore processing and marketing of fish products An important element in this report has therefore been the need to define the point at which the banksrsquo responsibilities are seen to terminate and all liabilities are transferred to other supporting donors and the government of Ghana In the short term a reduction in the industrial fleet may lead to the loss of 1000 to 3000 jobs for crew members although in practice most of this work is only part time and many of the vessels that are due to be withdrawn are no longer seaworthy In the longer term it is intended to encourage more selective fishing by limiting open and unfettered access to fish stocks eliminating illegal and damaging processes including dynamiting uncontrolled light fishing and the use of small size monofilament nets and introducing seasonal restrictions to protect breeding cycles The intention is that these measures will be managed jointly by the government and communities through co-management systems At the same time major efforts will be made to reduce the level of post-harvest losses and to increase the value of fish products The expectation is that the number of industrial semi-industrial vessels and canoes will be stabilised at a fixed lower level within five years Once this point is reached and no further licences are granted individual licences will acquire higher values especially as fish stocks recover and the size and value of fish catches starts to increase Subsequently licenses are likely to be sold and traded as less efficient owners drop out of the market and sell on to stronger individuals and companies In terms of onshore activities fish landing processing and marketing will become more efficient and losses will be reduced through use of better smokers freezing and drying equipment Previous studies in West Africa and elsewhere (Bennett et al 2001) have shown that the transition away from open access to a more regulated system of access management can give rise to social risks Specifically older men are likely to be displaced when they are no longer fit enough to withstand the rigours of fishing while a rising number of young men may find it harder to enter a career in fishing Women who currently manage or assist with all areas of buying processing and marketing using traditional clay ovens may also experience competition as new companies and enterprises are established to take advantage of higher profitability in the fishing sector perhaps using better equipment newer technologies and different logistics arrangements or their own transportation Methodology This study has followed the methodology developed within the process framework for the West Africa regional fisheries programme (WARFP) Figure 1 sets out both sequence and timescale for the work
The range of jobs at risk is based on assumptions about the number of vessels and average crew size and cannot be determined with any degree of accuracy until the necessary surveys are undertaken
9
The report is based on three major areas of activity 1 documentary analysis and utilisation of the studies already carried out by the fisheries commission 2 meetings with institutional stakeholders principally affected by the project and 3 Consultations and visits to some of the key fishing villages and communities The planned presentation of findings to Stakeholders has been postponed at the Clientrsquos request due to other pressing commitments in the agriculture and fisheries sectors This presentation will however need to be subsequently undertaken by the Ministry and the Fisheries Commission
11
CHAPTER 2 PLAN AND PROGRAMME DESCRIPTION
INTRODUCTION This chapter is divided into two parts Part 1 sets out the progress which the government Ghana is making in giving effect to the legislation policy and regulations Part 2 describes the proposed programme of assistance being offered by the World Bank with the specific aims of strengthening governance and enforcement systems (Components 1 and 2) and in promoting value addition and reduction of post-harvest losses
PART 1- THE DRAFT FISHERIES AND AQUACULTURE SECTOR DEVELOPMENT PLAN (FASDP) This plan (FASDP) covers the period 2010-2015 It recognises the importance of Ghanarsquos fisheries which generate in the order of US$ 1 billion a year contribute 45 to GDP and indirectly support the livelihoods of 22 million people However through over-fishing and lack of investment in management and value addition the average income per canoe has dropped by up to 40 over the last ten years to the point where it costs as much to fish as the catch is worth By comparison well managed fisheries in other parts of the world are capable of generating economic returns of 30-60 on investment (equivalent to a potential income of US$ 300 million a year for Ghanarsquos fisheries) The Draft FASDP acknowledges that the fishing sector is expected to make a substantial contribution towards doubling the size of the Ghanaian economy by 2015 (GPRS II) as part of the Republic of Ghana Fisheries and Aquaculture Policy Seven targets are set in the draft FASDP 1 Maintaining capture fisheries production at current levels 2amp3 Increasing revenue and profitability in capture fisheries by at least US$ 50 million a year after
five years 4 Increasing aquaculture production to 35000 tonnes a year after five years 5 Retaining Ghana as a landing and processing hub for the West Africa tuna industry 6 Developing fisheries management to allow effective control of all commercial fishing effort in
Ghanaian waters and 7 Ensuring fisheries management costs are sustainable and that the fisheries sector overall make a
fiscal contribution to Government revenues There is an underlying presumption that the canoe sector will remain at the heart of Ghanarsquos fishing industry but the plan is not prescriptive and leaves open the ways of achieving the overall goals At the same time there is an underlying assumption that the long term sustainability of Ghanarsquos fisheries will depend upon discouraging further entry by new operators
PART 2 THE WORLD BANKrsquos CONTRIBUTION TO GHANA FISHERIESPLAN (FASDP)
The essential aim of the World Bankrsquos contribution to FASDP is to provide investment which will build the necessary policy and capacity for effective fisheries management designed to reduce fishing effort while maintaining approximately the same catch levels and to address the impacts of change for fishers
12
and the communities in which they live Based on the currently available draft Project Appraisal Document (PAD) each of the components is now described in turn Component 1 - Good governance and sustainable management of the fisheries This component on good governance comprises four subcomponents which are broken down in turn into a number of separate activities Sub-component 11 developing the capacity rules procedures and practices for good governance of the fisheries Activity 111 reviewing the Fisheries Act and developing regulations to support the Sector Policy and the Fisheries and Aquaculture Sector Development Plan Activity 112 Developing an operational policy to enable implementation of the aquaculture and fisheries sector development plan Activity 11 3 strengthening fisheries management systems and capability (fisheries management plan development aquaculture implementation technical support and training) Activity 114 strengthening fisheries Information Systems (catch recording and monitoring systems statistical analysis and training)
Sub-component 12 introducing fishing rights
Activity 121 developing pilot stakeholder-based fisheries management initiatives around defined fisheries units (ie local management initiatives tighter defining fisheries resources in up to 6 selected Fisher communities) Activity 122 introducing and administering a licensing regime
Subcomponent 13 Adjusting fishing effort and capacity to more sustainable levels marine resource conservation and supporting alternative livelihood opportunities when needed Activity 131 vessel decommissioning Activity 132 compensation packages for crew of decommissioned industrialsemi-industrial vessels Activity 133 alternative livelihood development to incentivise voluntary capacity reduction in the canoe sector Activity 134 marine resources management and conservation
Subcomponent 14 social marketing communication and transparency Activity 141 communications stakeholder consultations and awareness raising programmes to support fishery development Component 2 reduction of illegal fishing Under the West Africa regional fisheries programme subcomponent 21 allows for enabling environment for reduction of illegal fishing These provisions already exist within Ghana and this subcomponent is therefore omitted Subcomponent 22 monitoring control and surveillance (MCS) systems Activity 221 developing compliant systems and capability
13
Component 3 increasing the contribution of the marine fish resources to the local economies Subcomponent 31 product diversificationvalue chain development (freshfrozen producttrade facilitation) Activity 311 landing site development Activity 312 Port development Subcomponent 32 fish product trade infrastructure information and systems - regional minimum integrated trade expansion platform (MITEP) Activity 321 export certification centre development Activity 322 fish processing technology improvements Activity 323 national fisheries advisory group Subcomponent 33 marine and inland aquaculture development Activity 331 space developing aquaculture policy and legal framework Activity 332 improving genetic policy of tilapia fingerlings and breedstock Activity 333 catalysing aquaculture development Component 4 Coordination monitoring and evaluation and program management Subcomponent 41 national implementation subcomponent 42 regional coordination Each of the components sub-components and activities are described in more detail in Chapter 5 which assesses the nature of environmental and social safeguards issues in terms of the World Bankrsquos planned investment
15
CHAPTER 3 BASELINE CONDITIONS
INTRODUCTION This chapter discusses the existing fishery resources of Ghana and describes recent environmental and social trends It identifies some of the pressures that led to the reduction in value of fishing activity and indicates the threats that could be posed if no action is taken in accordance with the planned fisheries and aquaculture program to deal with them FISHERY RESOURCES The continental and coastal waters of Ghana are potentially very rich due to a combination of warm waters and nutrients carried in ocean currents which up-well seasonally on the continental shelf The tonnage of fish caught in marine waters peaked in the mid-1990s around 500000 tonnes and currently averages around 400000 t(See Figure 1) Figure 1 Wild Capture Production in Ghana 1950-2005
2
Table31 Top 10 Species Exported (by value)
1 Canned tuna ($72000000) 2 Fresh tuna ($7200000) 3 Tilapia (no figure available) 4 Miscellaneous dried fish ($1000000) 5 Salmonids frozen ($900000) 6 Marine fish frozen ($600000) 7 Cuttlefish and squid ($600000) 8 Shrimps and prawns ($90000) 9 Sardines ($80000) 10 Crustaceans frozen ($50000) Source FAO Fishstat
The principal catch from deep waters is tuna Industrial vessels registered in Ghana target these species in international waters but also illegally in coastal waters Herring sardine and anchovies are fished in coastal waters by semi-industrial vessels and canoes Table 31 shows the top 10 species of fish exported from Ghana in 2005 PROFILE OF THE FISHING INDUSTRY Fishing is of vital importance in Ghana not only in terms of its contribution to gross domestic product (45 per annum) but because fish provides 65 of the countrys protein In recent years (between 2003-2008) and more specifically in 2004 the countryrsquos annual fish requirement has been estimated to be 882000 tonnes of which the country produces just about half (Tetteh 2007) Of the total population of 22 million people it has been estimated that between 15 and 22 million people are employed or gain their livelihoods from fishing (8-10) Of these there are 210000 men who are directly employed as
2 This figure is the Fisheries Departmentrsquos estimate for 2008
16
fishers The total export of seafood was valued US$824 billion in 2005 Ghanas fishing industry can be divided into three sections marine capture inland capture and aquaculture It can be further analysed by scale of operations distinguishing between industrial semi-industrial and artisanal sectors Marine fisheries Industrial sector Commercial fishing for tuna began in 1962 In the early 1980s Ghana sought to develop an industrial fishing fleet and there are currently 90 industrial trawlers and other vessels which are located in Tema and Takoradi Sekondi The port of Tema was expanded from 1962 to create four main areas the Inner Harbour Outer Harbour Canoe Basin and Commercial Area In 1999 fish landing facilities were improved at the Albert Bosumtwi Sam Fishing Harbour built in Sekondi This harbour is equipped with a cold store an ice-making plant offices a berthing bay for inshore vessels a jetty for canoes and a net drying area Under Ghanaian law more than 50 of the ownership of industrial vessels must be registered with a Ghanaian company or individuals However in practice many vessels are owned by foreign nationals with token Ghanaian ownership Relatively few of these large vessels regularly put to sea and a number are in poor condition or obsolete Nevertheless the impact of trawling activities by Ghanaian registered and foreign owned vessels has been very considerable in coastal waters in recent years Fish landed from industrial vessels is usually transferred directly to Canning factories in Tema and Takoradi Ghana has the largest canning industry in West Africa In the region of 30000 tonnes of tuna are landed In addition to trawling some industrial vessels are engaged in shrimping the use of tuna lines and polls purse seining and demersal trawling Semi-industrial sector in addition to deep sea trawlers there are around 230 large semi-industrial ships propelled by inboard motors which are used for trawling in shallow waters during the off-season and purse seining during upwelling seasons There are currently reported to be 48 bottom trawlers 14 pair trawlers 2 shrimpers 33 pole and line vessels and 10 tuna purse seiners operating from 2 of the 7 landing sites Canoe sector Ghanas artisanal fishing sector is based on between 10000 and 12000 wooden canoes Fifty seven per cent of the fleet is powered by outboard motors supported by paddle and occasionally sail Each Canoe carries a crew of between three and 20 men depending on size and length There are over 334 landing sites along the 550 km coast of Ghana and the majority of fish caught by canoe (180000 tonnes) is returned to these sites accounting for 70 of Ghanarsquos fish production The principal landing sites are at Teshie Jamestown Chorkor Shama Axim Elmina Winneba Mumford Akplabonya Adina Atiteti Abutiakope and more Fishing is undertaken by men but the majority of canoes are owned by women who pre-finance fishing trips (purchasing gear and premixed fuel) and purchase the catch Women also predominate in processing and marketing fish and fish products Only about 20 of fish sold fresh a further 20 is salted and the majority (60) is smoked It is estimated that up to 30 of the catch is spoilt through lack of ice for storage or alternative processing facilities
17
Inland fisheries Water Resources Ghanarsquos inland fishery resources consist of a natural lake( Lake Bosomtwe) and nine major river basins which from east to west of the country are
bull the Volta bull Densu bull Ayensu bull Ochi bull Kakum bull Pra bull Ankobra and bull the Tano
The River Tano forms the border between Ghana and Cote drsquo Ivoire The largest of the rivers is the Volta which drains more than two-thirds of the country through several large tributaries in virtually all regions of the country The Volta river system also incorporates the Volta reservoir generally known as the Volta Lake which has a surface area of around 8400 km2 The Volta lake discharges through the Akosombo dam before flowing through a delta into the Atlantic Ocean The eight other river systems are relatively smaller simpler and open more directly into the Atlantic There are also several reservoirs created on the smaller river systems mainly for potable water production irrigation and flood control These reservoirs irrespective of their primary purposes enhance availability of more permanent aquatic habitable space for fish and therefore support some fisheries Finally with all the river systems opening into the Atlantic there are a series of lagoons and estuaries which act as interfaces between the rivers and the sea These water areas constitute another type of inland water resource for salt and brackish water fishes Inland Fish resources Within the inland water resources of Ghana there are over 150 fish species more than 90 of which are fished for food
In commenting on inland fisheries in Ghana it must be noted that virtually all available information on inland fisheries is obtained from the Volta Lake No national fish production records have been kept on the fisheries of the eight smaller river systems and the lagoons and estuaries Thus the usual statement that inland fish production constitutes about 20 of what the country produces should refer to fish production from the Volta Lake In practice the total inland fish contribution could more realistically be estimated at about 30-35 of national fish production This is a very considerable but understated contribution to national food security and nutrition
Fishing vessels The dominant fishing vessel on the Volta Lake is the canoe the majority of which are built from wooden planks On some other river systems while plank canoes predominate a small number are carved as dug-outs from single tree trunks There is some variety in sizes of the canoes depending on how many planks are used to build the boat and the size of tree trunk used in building a canoe The total number of canoes estimated on the Volta Lake during a survey in 2000 was 24035 On the tributary rivers of the Volta Lake and other river systems in the country the planked canoe is the main vessel used in fishing
18
Fishing gear There are about eleven main kinds of gear used for fishing on the Volta Lake They are Gill Nets Cast Nets Hook and Line Basket and wire mesh traps Winch net Beach seine Bamboo Nifa-nifa Wangara Spears and Atidzas On other rivers in the country Gill nets Cast nets Hook and Line and traps are the fishing gear used On both the lake and rivers the Gill net is the main gear
People Involved In the 2000 frame survey of the Volta Lake conducted by the Fisheries Directorate of Ghana the estimate of fishers on the Volta Lake was put at 71861 Fishers on the lake work in collaboration with a host of fishmongers or handlers who also function as wholesalers for individual fishing groups Assuming that the fisher population on the lake has increased by a modest 3 in the ten years from 1998 to 2010 a fisher population of about 93500 could be considered to be on the Volta Lake now If again it is estimated that number of fishers on rivers in the country were to be a tenth of those on the lake this would put the fisher population on inland waters (apart from the Volta Lake) at about 9350 fishers A very conservative estimate therefore puts the total number of individuals who are directly engaged in inland fishing at over 100000 This excludes all directly associated groups such as fish handlers processors and traders An estimate of secondary fisheries operators such as boat builders out-board motor operators and mechanics as well as bulk salt and fuel wood sellers and those engaged in buying selling and distributing fish would have to be considered in developing estimates for both direct and indirect employment in inland fisheries but the number can be assumed to lie between 125000 and 150000 people
Aquaculture Under Ghanarsquos legal framework aquaculture is defined as ldquoany activity designed to cultivate or farm fish and other aquatic living resourcesrdquo Currently only fin fishes are involved in aquaculture in Ghana
Current culture media and environment Currently fish culture takes place almost exclusively in fresh water in Ghana either in cages brush parks or dugouts Dug-outs are excavations made in floodplains in the savannah parts of the country were water scarcity has been a major hindrance to development in general and food security in particular Dug-outs get filled with flood waters and whatever the water carries during major wet periods of a year in the savannah areas Waters that fill Dug-outs invariably contain fish which are trapped in the Dug-out after the wet period These water bodies are managed until the end of the dry period and the fish are harvested before the next flood period Since the 1960rsquos various strategies to augment fish production from Dug-outs have been developed and tested These involve adding fingerlings of selected fish species to those which are lsquonaturally stockedrsquo in Dug-outs by floods Dug-outs are the major fish culture production approach in the savannah parts of the country which accounts for a little more than half the area of the country The Environment of fish culture Currently fish culture is taking place mainly in freshwater environments Brackish water fish culture and mari-culture activities which will bring lagoons estuaries and the sea into fish culture production have long term potential for development Fishes in culture Fishes being cultivated in Ghana In order of importance are Nile tilapia Oreochromis niloticus the African catfish Clarias gariepinus species of the catfish Heterobranchus and the Bony tongue Heterotis niloticus Scale of Culture Based on level of production fish culture operations can be categorized as follows
bull Large scale commercial where an enterprise produces up to 10000 tonnes per year
19
bull Medium scale commercial where a single enterprise produces between 50 and 500 tonnes bull Small scale commercial where an enterprise produces between one and 20 tonnes and bull Very small scale commercial with productions below 20 tonnes
Fish culture production Cultured fish contribution to national production was officially stated as 9000 tonnes for the year 2009 However informed opinion amongst fish farmers indicates that a figure of between 16000 and 20000 tonnes in 2010 would be closer to reality This statement is based on the facts that most producersrsquo published figures are underestimates several small to medium scale producers are not recorded in official lists and the recording of newly established fish farms has lagged actual establishment especially since 2009 Although cultured production up till 2009 may not have been significant considering a shortfall of about 460000 mt (as recorded in 2004) between captured fish production and national demand this reflected the fact that there were only two large scale commercial producers in the country each of which had had less than ten years of operation Anticipated growth in fish culture production within the next five years is expected to be dramatic as some of the critical challenges of the industry are resolved
CHALLENGES AND PROSPECTS Marine Fisheries The fishing sector is vital for food security and job creation to help alleviate rural poverty in Ghana However the levels of fisheries harvests are generally considered to be close to or to have exceeded the maximum sustained yield Future sustainability in the industry will depend upon the restriction of open access to fisheries and the introduction of management systems which allow fish stocks to recover and the establishment of consistent yields in both marine and inland waters Inland Fisheries Environmental conditions on the Volta Lake constitute the major environmental and social challenges for fisheries its sustainability and profitability In terms of future prospects success will depend heavily on implementation of the lsquoGhana Fisheries and Aquaculture Sector Development Planrsquo and the capacity of the system in Ghana to enforce the Fisheries Regulations passed by parliament in August 2010 Aspects of the Development plan that offers great prospects for the lakes fisheries include the provisions for eventually licensing boats (although the scale of this task should not be underestimated) and measures to involve communities in management of fisheries resources of the Lake
Aquaculture The main challenges facing aquaculture development in Ghana relate to bull The high cost of fish feed (significantly due to its importation from other countries) bull None availability of commercial fish hatcheries as enterprises bull Lack of a nation-wide distribution network for fish seed and cultured fish producers Most
sources of fingerlings are concentrated in one part of the country and since farms all over Ghana obtain their fingerlings individually transportation costs add significantly to overall production costs
bull Now emerging certification and monitoring to check the health and safety of aquaculture processes and products
bull The absence of adequate regulations regarding establishment of an aquaculture enterprise until August 2010 (In the absence of regulations only the large and medium scale commercial farms worked towards conforming to international performance Standards and operational regulations for certification of farms and their products still remain in a draft state)
bull Low national support for research to support expansion and systematic development of aquaculture
20
The prospects for development of aquaculture as an industry in Ghana are good since a number of practical policy and legal frameworks have been put in place to resolve the basic challenges to the industry listed above These include
bull Construction of the first local fish feed plant by an international fish feed company with the expectation of having initial products on the Ghanaian market during 2011
bull A lsquoLarge scale commercial fish farmrsquo with great capacity for fingerling production is shifting emphasis to fish seed production And several localized fish seed producers are expanding operations
bull Distribution strategies by cultured fish producers have started to emerge on a limited scale and are expected to evolve with increasing production as existing commercial farms expand and new ones join in
Now that regulations regarding establishment of aquaculture enterprises have been gazetted there is likely to be a positive response amongst fish farmers of all size categories New operational standards are being prepared which will introduce minimum standards for local certification This should set the stage for preparation of fish culture products and the broadening of choice for consumers while also qualifying Ghanaian producers to enter external markets
ENVIRONMENTAL CONDITIONS The coastal and marine environment a critical zone of influence for this study comprises a 550 km coastline a coastal belt ranging from 1 to 20 km in width and coastal waters extending to 200 nautical mile limit which was established in 1977(under the territorial waters and continental shelf act 1973 as amended by the territorial waters and continental shelf amendment decree 1977) The Coastal Belt The coastal belt accounts for only 65 of the land mass of Ghana but it is one of the most densely settled areas accounting for 25 of the population and80 of the industrial establishments in Ghana Historically the coastal zone was cultivated for coconut (copra) but this industry is in decline Vegetables and other agricultural produce are grown on better soils but the principal economic activities are fishing transportation salt production and sand and stone winning Tourism also offers great potential There is considerable expectation that the discovery of offshore oil and gas deposits will bring new wealth to parts of the coastal corridor However present plans to transfer crude products to tankers at sea and then export them directly will limit industrial activity to a support role A high percentage of industrial and municipal wastes is dumped at landfill sites within the coastal zone which creates pollution risks The coastal belt is generally a low-lying area less than 200 m above sea level Vegetation types reflect the rainfall gradient and consist of coastal shrub and Savannah to Winneba southern marginal forest to the east of Sekondi dry semi-deciduous and moist semi-deciduous forest to the east of Cape Three Points estuary and wet evergreen forest in the extreme south Soils are variable within this area ranging from fertile pockets river valleys to Sandy poorer quality soils close to the sea The Coast The coast line divides into three sections (Ly 1980)
bull West of Cape Three Points this area has a wide and flat beaches backed by coastal lagoons and
21
wave heights are generally low bull Between Cape three points and Tema the coast consists of a series of rock headlands enclosing
shallow bays together with sandbars or spits enclosing coastal lagoons The surf zone is a medium to high energy environment with wave heights often exceeding 1 m South-westerly prevailing winds give rise to longshore drift in an easterly direction
bull Between Tema and Aflao most of the shore is sandy although there are rocky outlets The coastal zone is important internationally in providing feeding roosting and nesting sites for thousands of migratory birds Environmental degradation is significant in Ghana and is recognized in the countryrsquos environmental action plan It contributes to rising poverty levels coupled with poor human health and inadequately planned urbanization which fuel a vicious cycle inhibiting human development The core issues include
bull Domestic sanitation bull Increased urbanization without appropriate infrastructure bull Wetlands and mangrove degradation bull Coastal erosion and bull General biodiversity loss
Briefly each of the above could directly or indirectly adversely influence fisheries and aquaculture separately or together For example in a recently completed study of water quality scenarios of the Volta Lake in relation to fish production as a component of a comprehensive study (The Challenge Program Project of Water amp Food) it was concluded among others that poor sanitation in highly populated fisheries communities adversely influenced water quality to the detriment of fish life and thus fish production With reference to aquaculture the same unsanitary conditions in highly populated shore communities adversely influenced water quality especially in terms of oxygen depletion when lake waters extend to the shore in high water periods This is a situation which has caused fish kills in cages because caged fish cannot escape lsquopollutedrsquo waters Degradation of wetlands and mangroves leads directly to a reduction in their capacities as spawning and nursery zones for both marine and inland water fishes which reduce fish production in both environments The situation outlined above is often contributed to by anthropogenic and industrial pollution due to urbanization without appropriate infrastructure Another issue linking human activity to a deteriorating environment is demonstrated by the encroachment of aquatic weeds on inland waters such as the Volta Lake Weed growth is accelerated by farming reservoir catchments which increases nutrient levels and the building of dams which reduce or cut off intrusion of sea water into rivers Currently as climatic change observable impacts such as floods seem to escape predictions The project could possibly contribute to mitigating against direct and indirect effects of climate change on fishing and aquaculture through investment into climate change orientation and education of fishers and fish farmers to mainly influence reasonable precautions they take Marine waters The continental shelf is relatively narrow projecting out to 25-35 km except in the area of Cape Coast to Salt Pond where it extends to almost 80 kms Sandy and rocky substrates which previously supported coral and seaweeds have been severely affected by former trawling activity which indiscriminately
22
dredges material from the seabed Coastal waters are enriched by freshwater discharges from the relatively small number of rivers and by two seasonal up-wellings which occur between late June and early October (the main upwelling) and January and March (the minor upwelling) The origin and driving mechanisms of these up-wellings are not fully understood and both their location and strength varies from year to year
Lake Volta and other inland water
Major environmental issues on the Volta Lake which might also be considered as challenges to sustainable fisheries on the major inland fisheries resource can be summarised as follows
bull The Volta Lake is known to be low in nutrients It therefore has low standing crops of phytoplankton and zoo plankton to support high fish production
bull The northern segment of the lake together with tributary rivers constitute the spawning and feeding grounds for majority of fish species in the lake during the wet season however these segments are intensely fished during the same period
bull The Volta Lake is divided into eight unequal strata with different distribution of boats per Km2 At the last estimation of carrying capacity in 2000 stratum V and II had the highest (527) and lowest(157) number of boatsKm2 respectively
bull The rate of siltation in the lake is considered to be increasing due to erosion associated with high rates of deforestation
bull A major challenge exists in getting fishers fishing communities and fishing entrepreneurs to understand and comply with fishing regulations aimed at conserving fish and fisheries resources
bull There is a lack of resources studies and research to support fisheries management of the Lake
bull High illiteracy exists amongst lake shore communities
bull Open access to the fish resources of the Lake has been in operation since its formation
bull Declining fish yields are occurring in the lake (468 Kgha in 1976 to 320 Kgha in 2003-MOFA) brought about by the constraints listed above
bull The commonly assumed estimate of potential fish production from the lake of around 75500 mtyr) is considered to be a serious underestimate since Stratum VII alone was estimated to produce 33800mtyr in 1996
bull The policy environment for aquaculture is currently strongly supportive of the industry and related enterprises
bull There is good quality and more than sufficient water to allow some kind of aquaculture to be developed in every region of the country with the Volta lake (about 8400 Km2) as the single most important water unit for fish culture Currently it appears that the free access to the fish resources of the lake has to some extent been applied to establishment of small scale caged fish culture enterprises a situation constituting environmental risk to investments of large scale commercial fish culture establishments in the lake
bull The Volta Lake is low in nutrients (Obeng 1964) resulting in a situation where higher fish yields could be sustained if greater quantities of fish feed were available
23
bull In Ghana the Nile tilapia O niloticus occurred naturally only in the Volta system Due to positive culture characteristics of the fish it has been moved into virtually all other river basins in the country The situation provides opportunities for hybridization of the Nile tilapia with other tilapia species native to the river basin into which the Nile tilapia has been moved
25
CHAPTER 4 POLICY AND LEGAL FRAMEWORK FOR ENVIRONMENTAL AND SOCIAL ISSUES
41 INTRODUCTION
Development and implementation of the Ghana Fisheries and Aquaculture Sector Development Plan and the World Bankrsquos supporting program need to be developed with full regard to existing international conventions national legislation policies and regulations This chapter highlights the main legislative and policy considerations for the protection of the environment natural resources fisheries and social and economic development It begins with reference to the World Bankrsquos safeguard framework and those of other donors This is followed by a section on the governance framework in Ghana
42 WORLD BANK AND OTHER DONORSrsquo SAFEGUARDS POLICIES
The World Bankrsquos safeguard policies exist to ensure that all projects which it finances are developed and implemented on environmentally and socially sound principles A range of different policies exist and these have been carefully considered to ensure that the Ghana Fisheries and Aquaculture Development Sector Development Plan complies with these safeguards All policies have been screened and those that have no bearing on the fisheries programme have been excluded from Table 41 below Table 41 lists policies which could have some applicability to the FASDP even if this interaction might be very slight It is important to stress that the comments in the third column of Table 41 relate to the entirety of the Fisheries and Aquaculture Sector Development Plan whose effects will continue to be experienced long after the World Bankrsquos financial support has been expended Most of the activities in the FASDP will have no effect in relation to safeguard objectives and where there are implications these are likely to occur at precise locations (for example at fish landing sites) rather than throughout the industry Where potential interactions have been noted the necessary mitigating measures are incorporated in the Draft Process Framework
Table 41 World Bank Safeguard Policies in Context
Safeguard Policy
Safeguard Policy Objective Brief Description and relevance to FASDP
OP 401 Environmental Assessment
This policy aims to ensure that Bank-financed projects are environmentally sound and sustainable and that the decision-making process is improved through appropriate analysis of actions and mitigation of their likely environmental impacts This policy is triggered if a project is likely to carry potentially adverse environmental risks and impacts on its area of influence OP 401 covers impacts on the natural environment (air water and land)
The majority of actions planned under FASDP will be beneficial to the marine environment and to inland waters However new construction activities could have impacts and depending on the project and the nature of impacts a range of instruments can be used to ameliorate and mitigate adverse effects while enhancing beneficial effects These include EIA environmental audit risk assessment and environmental management plans (EMP) The need for EIA and EMP is considered in this report
26
OP 404 Natural Habitats
This policy recognizes that conservation of natural habitats is essential to safeguard their unique biodiversity and to maintain environmental services and goods for human society and for long-term sustainable development The Bank therefore supports the protection management and restoration of natural habitats in its project financing as well as policy dialogue and economic and sectoral work Natural habitats comprise many types of terrestrial freshwater coastal and marine ecosystems They include areas lightly modified by human activities but retaining their ecological functions and most native species
This policy is triggered by any project (including any sub-project under a sector investment or financial intermediary) with the potential to cause significant conversion (loss) or degradation of natural habitats whether directly (through construction) or indirectly (through human activities induced by the project) This policy is applicable to the Ghana Fisheries Programme because the project focuses on the integrated management of natural habitats However by screening all proposals under the ESMF any sub-projects that might impact these habitats will not be funded
OP 409 Pest Management
The objective of this project is to (i) promote the use of biological or environmental control and reduce reliance on synthetic chemical pesticides and (ii) strengthen the capacity of the countryrsquos regulatory framework and institutions to promote and support safe effective and environmentally sound pest management
The policy is triggered if (i) procurement of pesticides or pesticide application equipment is envisaged either directly through the project or indirectly through on-lending co-financing or government counterpart funding (ii) the project supports an activity requiring the use of pesticides that may have negative effects on the environment The only instance in which this policy might be triggered by the Ghana Fisheries Programme is if aquatic herbicides or antibiotics were to be used in connection with aquaculture This is most unlikely but can be monitored through the implementation programme
OP 411 Physical Cultural Resources
The policy objective is to assist countries in avoiding or mitigating adverse impacts of development projects on physical cultural resources For the purposes of this policy ldquophysical cultural resourcesrdquo are defined as movable or immovable objects sites structures groups of structures natural features and landscapes that have
Under the Ghana Fisheries Programme construction and rehabilitation activities that could have negative impacts on cultural property will be avoided In the case of discovery of remains national procedures will be applied
27
archaeological paleontological historical architectural religious aesthetic or other cultural significance
OP 412 Involuntary Resettlement
The objective of this policy is to (i) avoid or minimize involuntary resettlement where feasible while exploring all viable alternative project designs (ii) to assist displaced persons in raising their former living standards income-earning capacity and production levels or at least in restoring them (iii) encourage community participation in planning and implementing resettlement and (iv) provide assistance to affected people regardless of the legality of land tenure
The policy covers not only physical relocation but any loss of land or other assets resulting in (i) relocation or loss of shelter (ii) loss of assets or access to assets (iii) loss of income sources or means of livelihood whether or not the affected people must move to another location The activities of the Ghana Fisheries Programme are likely to result in loss of assets or access to assets and loss of income sources or means of livelihood for some groups and individuals The potential for such losses will be carefully scrutinised and compensated for through the National Process Framework and Resettlement Policy Framework described in this report and appropriate procedures will be followed where necessary
Other donors and aid agencies including International and National NGOs play an active role within the fisheries sector in Ghana and their safeguards standards will be observed through operation of the Environmental and Social Safeguards Management Plan
28
43 THE GOVERNANCE FRAMEWORK IN GHANA
The Ministry of Food and Agriculture (MOFA) Preparation of Fisheries laws and policies fall under the responsibilities of the Minister of Food and Agriculture who in turn delegates functions including implementation to a semi-autonomous body the Fisheries Commission
The Fisheries Commission (FC) was established under the Fisheries Commission Act (625 2002) It oversees management regulation and utilisation of the fisheries resources of Ghana drawing on powers set out in the Fisheries Law (PNDC 256 1991) Fisheries Act 625 provided for the establishment of a more robust Fisheries Commission (FC) which is an amalgamation of the erstwhile FC and Department of Fisheries
Ten individuals constitute the Board which is led by a chairman (appointed by the President of Ghana in consultation with the Council of State) supported by three members drawn from the ministries of transport defence and environment There are three representatives from the following parastatal organizations - the Ghana Marine Fishing Officers Association Water Research Institute and Ghana Irrigation Development Authority- and two representatives (one from the artisanal and one from the industrial sections )of the National Fisheries Association of Ghana Finally the tenth member is a person with requisite knowledge of the fishing industry or natural resources renewal management
The day to day work of the Fisheries Commission is undertaken by the Department of Fisheries (DOF) which serves as the implementation secretariat of the Fisheries Commission as stipulated by the Fisheries Act 625 of 2002 Specific tasks that are undertaken by the Department of Fisheries include
bull preparing fishery resource management plans bull developing regulations for the fishing industry bull organizing monitoring surveillance and enforcement for the national fishery resources and
ensuring compliance with national fisheries law and institutionalizing co-management concepts
The MCS Division of the DoF (established under the Fisheries Sub sector Capacity Building project) works in conjunction with the Ghana Navy and undertakes sea patrols to exclude industrial fishing vessels from the 30-metre depth IEZ reserved for artisanal fisheries The MCS also conducts inspection of industrial vessels at the fishing ports of Tema and Takoradi for
bull valid fishing licences bull legality of fishing gear bull skipperrsquos certificate bull log book and crew composition
The MCS undertakes similar functions for inland fisheries on Lake Volta
The Ministry of Local Government and Rural Development (MLGRD) is responsible for managing fishers fish processors and fishery resources at district and sub-district levels which it undertakes through the District Assemblies In 2002 the District Assemblies in collaboration with DoF were mandated to facilitate fishery resource management by
bull helping to form and sustain Community Based Fisheries Management Committees (CBFMCs) bull cooperating with the DoF MCS units bull providing legal and financial support to the CBFMCs and bull approving levies proposed by the CBFMCs
29
Community-Based Fisheries Management Committees are charged with the responsibility of enforcing national fisheries laws at community level as well as initiating and enforcing their own by-laws
44 THE LEGAL FRAMEWORK
441 International Conventions
Ghana has ratified a number of international conventions and treaties which have an important bearing on the state of its marine and inland waters and the condition of the fisheries These are listed in Box 1 below
Box 1 International Conventions treaties and agreements to which Ghana is a signatory 1 International Convention for the Prevention of Pollution of the sea by Oil 21 October 1962 2 Convention on the Africa Migratory Locust 25 May 1962 3 Treaty Banning Nuclear Weapon Tests in the Atmosphere in Outer Space and Under Water 5th August 1963 4 International Convention for the Conservation of Atlantic Tunas 4 May 1966 5 Africa Convention on the Conservation of Nature and Natural Resources 15 September 1968 6 International Convention on Civil Liability for Oil Pollution Damage 29 November 1969 7 International Convention Relating to Intervention on the High Seas in Cases of Oil Pollution Causalities 8 Convention on Wetlands of International Importance Especially as Waterfowl Habitats 2 February 1971 9 Treaty and Prohibition of the Emplacement of Nuclear Weapons of Mass Destruction on the Seabed and the Ocean Floor and in the Subsoil Thereof 11 January 1971 10 International Convention on the Establishment of an International Fund for Compensation of Oil Pollution Damage 18th December 1971 11 Convention Concerning the Protection of World Cultural and Natural Heritage 16 November 1972 12 Convention on International Trade on Endangered Species of Wild Fauna and For a 3 March 1973 13 Convention on the Military or Any other Hostile Use of the Environmental Modification Techniques 10 December 1976 14 Convention on the Conservation of Migratory Species of Wild Animals 23 June 1979 15 Convention for the Cooperation in the Protection and Development of the Marine and Coastal Environment of the West and Central African Region1981(Abidjan Convention) 16 United Nation Convention on the Law of the Sea 10 December 1982 17 Montreal Protocol on Substances that Deplete the Ozone Layer 24 July 1989 18 Convention to Combat Drought and Desertification 19 Framework Convention on Climate Change June 1992 20 Convention on Biological Diversity1992 442 Environmental-Related Conventions Environmentally related conventions ratified by Ghana include
bull International Convention for the Prevention of Pollution of the sea by Oil 21 October 1962
bull Convention on the Africa Migratory Locust 25 May 1962 Treaty Banning Nuclear Weapon Tests in the Atmosphere in Outer Space and Under Water 5th August 1963
bull International Convention for the Conservation of Atlantic Tunas 4 May 1966 bull Africa Convention on the Conservation of Nature and Natural Resources 15 September 1968 bull 992256International Convention on Civil Liability for Oil Pollution Damage 29 November
1969 bull International Convention Relating to Intervention on the High Seas in Cases of Oil
30
Pollution Causalities bull Convention on Wetlands of International Importance Especially as Waterfowl Habitats
2 February 1971 bull Treaty and Prohibition of the Emplacement of Nuclear Weapons of Mass Destruction
on the Seabed and the Ocean Floor and in the Subsoil Thereof 11 January 1971 bull International Convention on the Establishment of an International Fund for
Compensation of Oil Pollution Damage 18th December 1971 bull Convention Concerning the Protection of World Cultural and Natural Heritage 16
November 1972 bull Convention on International Trade on Endangered Species of Wild Fauna and For a 3
March 1973 bull Convention on the Military or Any other Hostile Use of the Environmental
Modification Techniques 10 December 1976 bull Convention on the Conservation of Migratory Species of Wild Animals 23 June 1979 bull Convention for the Cooperation in the Protection and Development of the Marine and
Coastal Environment of the West and Central African Region1981(Abidjan Convention)
bull United Nation Convention on the Law of the Sea 10 December 1982 bull Montreal Protocol on Substances that Deplete the Ozone Layer 24 July 1989 bull Convention to Combat Drought and Desertification bull Framework Convention on Climate Change June 1992 bull Convention on Biological Diversity1992
443 National Legislation
The principal national legislation that affects fisheries in Ghana is listed below
1 Fisheries Regulation 1984 LI 1294 2 Fisheries (Amendment) Regulation 1977 3 Maritime Zones (Delimitation) Law 1986 4 PNDC Law 256 of 1991 5 Fisheries Commission Act of 1993 and 6 Fisheries Act 625 of 2002 7 Fisheries Regulations passed in 2010 LI 1968
Other laws that have relevance to the fisheries sector include
1 Wild Animals Preservation Act 1961 (Act 43) 2 Volta River Development Act 1961 (Act 46) 3 Ghana Water and Sewerage Corporation Act 1965 (Act 310) 4 Oil in Navigable Waters Act 1964 (Act 235) 5 Irrigation Development Authority Decree 1977 (SMCD 85) 6 Minerals and Mining Law 1986 (PNDCL 153) 7 Environmental Protection Agency Act 1994 (Act 490) 8 Ghana Highway Authority Act 1997 (Act 540) 9 Timber Resources Management Act 1998 (Act 547) and 10 Minerals and Mining Act 2006 (Act 703
31
434 Policies A number of Environmental related Policies exist in Ghana however there is no specific policy on the coastal zone These include
bull The National Environment Policy bull National Wetlands Policy bull Agricultural Policy bull Tourism Development Policy bull Land Management Policy bull National Health Policy bull Energy Policy bull Minerals Policy bull Wildlife Conservation Policy
The main thrust and orientation of national policies on the protection management and development of the marine and coastal environment focuses on the following three major areas
bull Integrated coastal zone management and sustainable development bull Marine environmental protection both from land-based activities and from sea-based
activities and bull Sustainable use and conservation of marine living resources (both of the high seas and
under national jurisdiction) Specific plans have been developed to ensure the realization of prudent management of the marine and coastal environment These include
bull Coastal Zone Management Indicative Plan 1990 bull National Environmental Action Plan 1994 bull Draft Integrated Coastal Zone Plan 1998 bull Coastal Zone Profile of Ghana 1998 bull National Oil Spill Contingency Plan with specific reference to the marine environment
2002 bull Environmental sensitivity map of the coastal areas of Ghana 1999 and 2004
Despite the existence of these plans active integration and coordination has been lacking in practice at local level 434 Regulations Though several legislations exist on coastal protection and sustainable development there is no omnibus legislation on the environment Legislation relating to the area include the following
bull Beaches Obstruction Ordinance 1897 (Cap 240) bull The Mineral and Mining Law 1986 (PNDC 153) bull Rivers Ordinance 1903 (Cap 226) bull Land Planning and Soil Conservation Ordinance No 32 of 1953 as Amended by the bull Land Planning and Soil Conservation (Amendment) Act 1957 (No 35 of 1957) bull Maritime Zones (Delimitation) Law 1986 (PNDCL 159) urban planning and
32
bull development bull Town and Country Planning Ordinance (Cap 84) bull Wild Animals Preservation Act Act 235 1964 bull The Towns Ordinance (Cap 86) bull National Building Regulations 1996 (LI 1630) bull Volta River Development Act 1961 bull Fisheries Act 2002 Act 625 bull Fisheries Law 1991 (PNDC 256) bull Fisheries (Amended) Regulations 1977 and 1984
The sustainable use and conservation of marine resources is encouraged through legislation regulations education and awareness creation programmes as well as the enforcement of existing regulations and legislation The legal framework for coastal zones issues and management in the country are contained in the following documents
bull The 1992 constitution bull EPA Act 1994 (Act 490) bull Environmental Assessment Regulations 1999 (LI 1652) bull Local Government Act 1993 (Act 462) bull Environmental Standards and Guidelines bull
In addition there are other specific legal frameworks which include a) The legal framework for Ecosystem Protection which are
bull Wild Animals Preservation Act 1961 (Act 43) bull Wildlife Conservation Regulations 1971 (LI685) bull Wild Reserves Regulations 1971 (LI 740) bull The Wetland Management (Ramsar sites) Regulation 1999 bull Oil in Navigable Waters Act 1964 (Act 235)
b) The legal framework for Fisheries Resources which are bull Fisheries Law 1971 (PNDCL 256) bull Fisheries Act 2000
c) The legal framework for Oil and Gas Industry bull Petroleum (Exploration and production) Law 1984 (PNDCL 84) bull Mineral (Offshore) Regulations 1963 (LI 257) bull Mineral (Oil and Gas) Regulations 1963 (LI 256) bull Oil and Mining Regulations 1957 (LI 221)
d) The legal framework for Tourism Promotion (including coastal tourism) bull Ghana investment Promotion Centre Act 1994 (Act 478) bull Companies Code 1963 (Act 179) bull Free Zone Act 1995 (Act 504) bull Ghana Tourism Board bull Ghana Commission on Culture
44 ACTIVITIES RELATING TO FISHERIES INTERESTS
33
Over the years several activities have been undertaken which are of relevance to protection of the marine environment and fisheries These include
bull Ghana Environmental Resource Management Project in Coastal Wetlands Management Component
bull Gulf of Guinea Large Marine Ecosystem Project bull Fisheries Sub-sector Capacity Building Project bull Establishment of a Protected Wetland Ecosystem on the coast bull Development and Implementation of Oil Spill Contingency Plan bull Monitoring of fish stock levels and associated oceanographic parameters bull Institution of a programme of Monitoring Compliance and Surveillance of the marine
environment bull Development of industrial pollution standards bull Development of University course on Coastal Zone Management bull Increased public education on sound coastal and marine environmental practices
45 RELEVANT INSTITUTIONS With regards to protection management and development of the marine and coastal environment a number of ministries and agencies have been identified as potential stakeholders Those shown with an asterisk are likely to have a particularly active role
bull Ministry of Environment and Science bull The Environmental Protection Agency bull Ministry of Tourism bull Ministry of Local Government and Rural Development bull Ministry of Ports bull District Assemblies bull Ghana Ports and Harbours Authority bull Hydrological Services Department bull Ministry of Food and Agriculture bull Ghana Tourist Board bull Ghana Investment Promotion Centre bull Fisheries Commission Ministry of trade Industries and PSI bull Ministry of Lands and Natural Resources Forestry and Mines bull Ministry of Energy bull Ministry of Health bull Ministry of Education Youth and Sports bull Ministry of Defence bull Ghana Navy bull Ministry of Works and Housing bull Ministry of Women and Childrenrsquos Affairs bull Ministry of Roads and Transport bull National Development Planning Commission bull Council for Scientific and Industrial Research bull Universities and Research Institutions bull Ghana Meteorological Agency bull Town and Country Planning Department bull Water Resources Commission
34
bull Ghana National Petroleum Corporation bull Volta River Authority bull Geological Survey Department bull Forestry Commission (Forestry and Wildlife Division) bull Traditional Rulers and their analogous ministry and laws
Non-Governmental Organisations including Resource Development amp Environmental Oriented Development Organisation
bull Friends of the Earth bull Green Earth bull Wildlife Society bull Recerca e Cooperazione bull Centre for African Wetlands bull And many others
46 PARTNERSHIPS Few formal partnerships exist However support for coastal conservation activities has been received from the private sector as well as from Government Regional and sub-regional collaboration efforts occur at various levels although the level of practical intervention is sometimes limited The science and technology unit of ECOWAS is engaged on issues relating to the management of the Gulf of Guinea In addition a bilateral arrangement exists between Ghana and Cote drsquoIvoire for the management of and datasharing on Sardinella stocks which migrate between the two countries The NEPAD framework among the coastal states of Africa is also developing an interest in marine and coastal management 461 Technical and financial support Ghana receives technical support in the form of training research and project implementation from national bilateral and multi-lateral sources Financing of activities in the sector is primarily supported from the national budget However donor support from both bilateral and multilateral sources has also been obtained for specific programmes such as the World Bank sponsored Fisheries Sub-sector Capacity Building Project UNOPS sponsored Environmental Sensitivity Map for Coastal Areas The Ghana Coastal Wetland Project of the World Bank UNEPrsquos WACAF Programmes and The Darwin Marine Biodiversity of West Africa Project by DFID implemented by the University of Ghana 47 ACTIVITIES Activities undertaken in the country with importance to the marine and coastal area are outlined in the following sections 471 Environment-related activities
bull Ecological Baseline studies of Korle Lagoon (1990-2000) This was carried out to satisfy EIA requirement and as a result pollution status of the lagoon was established
bull Lower Volta Mangrove Project (1996-1998) The objective is to ensure sustainable management of mangrove stands and as such baseline information was documented
bull Save the Seashore Birds Project (1985-1995) This was to protect the seashore birds and as a result conservation awareness of seashore birds was achieved
bull Ghana coastal wetlands management project (1996-1999) In this management of the five coastal wetlands designated as Ramsar Site was put in place
bull Darwin Marine Biodiversity of West Africa Project It is a training project in marine biodiversity assessment
35
472 Social-related activities bull A considerable amount of attention is currently being given to the potential impact of oil-related
development in coastal regions following the publication of Environmental and Social Impact Assessments and Management Plans relating to the Jubilee Oil Field discoveries
473 Coastal area management bull Climate and vulnerability and adaptation assessment on water resources agriculture and the
coastal zone Projects (1997-1999) The projects assessed the vulnerability of the coastal zone to climate change
bull Coastal area management plan for Princess Town (1998-2000) which aimed at providing a plan for the management of Princess Town
bull Keta Sea Defence Project Work (2000-2004) The project aimed at protecting the Keta and its environs from the episodes of erosion faced in the area and also to ensure improvement in environmental and socio-economic conditions at Keta and its immediate surroundings
474 Regional Programmes bull Gulf of Guinea Large Marine Ecosystems Project (1996-1999) The project developed an
effective approach to prevent and control pollution in the Gulf of Guinea and conserve its biodiversity As a result regional institutional capacities were strengthened and also a coastal zone management profile and plans produced
bull UNEP WACAF Projects 1 amp 2 This aims at institutionalising and coordination of national contingency plans monitoring of pollution in the marine environment and control of coastal erosion
475 Other major programmes Other recent programmes and activities in the marine and coastal environments have included
bull Ghana Environmental Resources Management Project in Coastal Wetlands bull Fisheries sub-sector Capacity Building Project bull Establishment of a Protected Wetland Ecosystem on the coast bull Development and Implementation of Oil Spill Contingency Plan bull
48 ONGOING PROJECTS Ghana is currently implementing several projects in the marine and coastal area Some of these projects are linked to developmental projects for which impact assessments are required under the Environmental Assessment Regulations of 1999 Some of the projects are large scale in nature with extensive baseline and monitoring studies like the Keta Sea Defence Project and the West Africa Gas Pipeline project Others are projects being implemented under the auspices of the United Nations agencies and non-governmental organisations include
bull Combating Living Resource Depletion and Coastal Area Degradation in the Guinea Current LME through Ecosystem-based Regional Actions
bull Amansuri Conservation and Integrated Development Project (ACID) bull Danida Water and Sanitation Sector Programme II Support to Integrated Water Resources
Management (IWRM) Component (2004-2008)The Densu Basin aspect of the IWRM component
bull Reduction of Environmental Impact from coastal tourism
bull Bui Hydro Power Project
bull Sea Defence Project at Atorkor
bull Sea Defence Projects in selected towns in the Western Region of Ghana
36
49 CONCLUDING REMARKS
This chapter has highlighted the wide range of conventions laws policies regulations and activities affecting the inland and coastal regions and inland freshwater and marine environment of Ghana It will be important to keep all of these processes and procedures under review as the Fisheries and Aquaculture Sector Development Plan is taken forward to the implementation stage
The main responsibility for ensuring delivery of the Fisheries and Aquaculture Sector Development Programme will rest with the Fisheries Department of the Ministry of Food and Agriculture and the Fisheries Commission supported by the MCS Division and Ghana Navy However a key part of the programme is the development of local co-management arrangements and the Ministry of Local Government and Rural Development and individual District Assemblies will play a key role in helping to form and sustain Community Based Fisheries Management Committees
Over time a significant number of fishermen and individual fish processors are likely to leave the sector as harvesting landing and processing of the catch becomes more efficient Management of these changes especially where disadvantaged and vulnerable sections of the community are affected will need substantial support and investment and a high degree of coordination amongst government ministries and agencies NGOs and international partners to ensure that development assistance is effectively targeted
37
CHAPTER 5 WORLD BANK SAFEGUARD ISSUES
51 INTRODUCTION
The World Bankrsquos proposed funding support to the Government of Ghana covers an initial five yearsrsquo period which could potentially be extended at a later date As the Government of the Republic of Ghana notes in the draft FASDP ldquoimproving the management of the countryrsquos fisheries and ensuring that the impacts on individuals and communities are properly addressed will take 20 or more years to effectrdquo It has therefore been judged important in this report to distinguish between changes that might occur as a direct result of the World Bankrsquos financial assistance thereby triggering the Bankrsquos environmental and social safeguards and changes that could result from longer term adjustments to fisheries and other sectors of Ghanarsquos economy as a result of wider influences by Government other donors and world-wide factors (for example international progress in world trade agreements)
The aim in this chapter is to identify changes which are likely to fall within the purview of the World Banks reputational risks and responsibilities under the first five years of the Fisheries and Aquaculture Sector Development Plan (FASDP) It should be clearly understood that the views expressed are those of the consultancy team and it will be for the World Bankrsquos internal advisors to decide what formal recommendations are made to the World Bank Board
Trends that may emerge in later stages of the implementation of FASDP ndash subsequent to the initial five year period - are discussed in chapter 6
52 THE CURRENT SITUATION
The general status of Ghanarsquos fisheries has been described in Chapters 3 while the legal and policy context has been set out in Chapter 4 The World Bankrsquos investment is being planned specifically to support government policy with the aim of providing a more efficient and better regulated fisheries sector Currently open access is leading to progressive deterioration in fish stocks and lower economic returns Based on many international examples of successful intervention the current proposals (see Chapter 2) are to provide support to introduce formal licensing of all vessels and proper monitoring and control over the seasonal timing and location of fishing activity use of gear and approved nets and self regulation through co-management structures under which the Government and fishing communities will work together to achieve recovery of fish stocks higher income levels for fishers and better returns on catches by reducing post harvest losses and improving processing and marketing operations
53 ANTICIPATED OUTCOMES
It is expected that the proposed reforms and changes will eventually lead to significant improvement in the marine environment restoration of fisheries and enhanced incomes In this respect the provision of grants and loans from the World Bank will bring about major benefits to the economy livelihoods and the environment in the longer term The question that has to be addressed however is - are there likely to be any short term adverse environmental or social consequences from the Bankrsquos own investment strategy Answers are considered in relation to each of the planned components sub-components and activities which are summarised in Table 51 A colour coding and numbering system has been adopted to distinguish those activities that are seen as particularly relevant from the standpoint of the environmental and social assessment Elements highlighted in green are those likely to have positive and beneficial effects on the environment and social conditions those highlighted in orange red have potentially negative or adverse consequences if not handled properly
38
Component 1 Good Governance and Sustainable Management of the Fisheries
Sub-Component 11 seeks to develop the capacity rules procedures and practices that will lead to better governance As such these procedural interventions will have no direct effect on the environment or social conditions of fishing communities However it will be important to ensure that the drafting agencies (government departments and consultants) give due attention to environmental and social objectives during this phase of work Three specific areas are highlighted including undertaking a socio-economic impact assessment with mitigation measures as part of the plan for fishing capacity reduction reviewing the economic and social implications of subsidies and fish import tariffs in the fisheries sector and developing the policy for the development and operation of community-based management networks built around defined fisheries management units
In developing regulations and guidelines it will be important to consider how less able individuals and vulnerable sectors are going to adapt to new systems For example the new regulations on licensing canoes including completion of registration forms the display of registration numbers on vessels and demonstration of basic competence in health and safety standards may prove taxing demands for owners and crew lacking any formal education Similarly legal instruments that are used to remove fuel subsidies or other benefits will need to be carefully explained A socio-economic impact assessment is proposed in the draft PAD to be accompanied by appropriate mitigation measures This assessment should consider amongst other things
bull whether support should be offered and if so under what conditions to any company community or individual who fails to secure a license for a particular class of vessel
bull how the transfer or sale of licenses will be regulated in the wider public interest to ensure transparent processes and avoid the creation of monopolistic and oligopolistic elites
bull who wins and who loses from any planned changes to subsidies and fish import tariff adjustments
bull how the performance of community-based management networks will be judged bull what action will be taken to mitigate the loss of any traditional fishing grounds that become the
subject of marine protected area development or are subject to exclusion zones to protect oil drilling and production platforms
Sub-Component 12 introduces the concept of fishing rights This is to be initiated through a series of four pilot stakeholder-based fishery initiatives and the rolling out of licensing procedures Discussions with stakeholders have made it very clear that the credibility of the entire fisheries policy and programme could be challenged if these pilots do not show positive and constructive ways of moving forward with fisheries reform There is a great deal of distrust for new procedures amongst the fishing communities based on the knowledge that many previous initiatives have failed It is therefore essential that the pilots are led by a strong implementation team are adequately financed and include a credible transparent and inclusive process for debate discussion and consultation Co-operation from the selected communities will be more likely to be achieved if they can see early results in terms of income generating activities
Sub-Component 13 is targeted at adjusting fishing effort and capacity to more sustainable levels and supporting alternative livelihood opportunities These activities are critical in giving effect to the policy decisions that have already been taken to reduce the size of the industrial and semi-industrial fishing fleet and to strengthen the role of the canoe sector Specific measures are proposed for compensating crew members who lose their jobs and for providing training to young men who are willing to transfer
39
out of the fishing sector The scale of this task should not be under-estimated however since there are currently few alternative employment opportunities in the coastal belt for manual workers with low education and skill levels which typify the status of many young fishermen The concept of creating some additional employment with conservation of the coastal littoral and marine ecosystems is strongly supported since this can be linked with development of tourism
Sub-Component 14 is another element that is strongly focused on delivering improved livelihoods with its emphasis on social marketing communication and transparency The focus on stakeholder participation is particularly welcome and should lead to positive response providing it is backed with direct financial support to participating communities
Component 2 - Reduction of Illegal Fishing
There is no Sub-Component 21 within the Ghana Fisheries Programme
Sub-Component 22 aims to develop monitoring control and surveillance (MCS) systems These measures are largely procedural and apart from the relatively small team that will be recruited to operationalise the systems it will have minimal effects on either the environment or social conditions One element that is highlighted in Table 51 relates to provision of facilities and training for participatory coastal surveillance of small-scale fisheries This should have direct and strongly positive benefits for participants and the communities who are enrolled in the training programmes
Component 3 increasing the contribution of the marine fish resources to the local economies
Sub-Component 31 will support the development of basic infrastructure at nine marine fish landing sites and two inland sites The scale of physical construction will be restricted to repair and minor extension of roads and jetties wharves and construction of net mending screens and storage sheds These activities are unlikely to have any significant adverse environmental impacts and should lead to positive social effects
Sub-Component 32 will underpin efforts to improve fish product trade infrastructure information and systems Introduction of new technology for smoking and curing fish and the extension of existing ice preparation plants will start to have positive beneficial effects within the selected communities
Sub-Component 33 provides a modest level of support to marine and inland aquaculture development Aquaculture development should include finalization establishment and enforcement of current draft operational standards to cater for environmental friendliness of fish culture industry for its own survival The main focus will be on developing policy and legal frameworks together with support for stock improvement These measures will have some impact on affected communities in the short term but are clearly aimed at longer term benefits
40
Component 4 Coordination Monitoring and Evaluation and Program Management
Sub-Components 41 and 42 are directed specifically at strengthening the capacity of the Governmentrsquos institutions for national implementation and regional co-ordination As such they will have no direct environmental or social impacts
54 SUMMARY AND CONCLUSIONS
This review of potential environmental and social safeguard issues under the World Bankrsquos targeted programme concludes that there are unlikely to be any significant adverse environmental or social effects as a result of the planned investments
The only possible exception relates to the effectiveness of measures that are put in place under Sub-Component 12 to support pilot stakeholder-based fishery initiatives It is of paramount importance that these pilots are successful and win the confidence of all participants since failure to achieve positive results could set back the entire fisheries programme For this reason it is essential that planning of the pilot initiatives is linked closely with measures for supporting alternative livelihoods and strengthening processing and marketing initiatives under Sub-Components 13 and 14
A number of the planned interventions may have longer term consequences as policies regulations and bye-laws are put into effect but these will be addressed in subsequent work by the Government of Ghana (see Chapter 6)
Table 51 Elements of the World Bank Programme and assessment of potential environmental and social risks
Description of Component Sub-Component and Activities
Measure of Likely Effects
Large (3)
Moderate (2)
Small (1)
None
Beneficial
3
2
1
Adverse
3
2
1
Component 1 Good Governance amp Sustainable Management of the Fisheries
Sub-Component 11 Developing the Capacity Rules Procedures amp Practices for Good Governance of the Fisheries
Reviewing developing programmes and projects designed to support the Fisheries and Aquaculture Development Sector Plan (FASDEP)
Developing an operational policy to enable implementation of the Aquaculture and Fisheries
Plan for fishing capacity reduction (including socio-economic impact assessment and mitigation) 3 2
Commercial vessel and fishing activity licensing plan including allocation criteria rules for transfer of licenses
41
Sector Development Plan and timetable and schedule of license fees
Compliance strategy and plan
Regulations for the management of fisheries including the identification and specification of fisheries management units (ie stocks species areas)
Recommendations for environmental and social safeguards arising from the review of the economic and social implications of subsidies and fish import tariffs in the fisheries sector
3
Policy for the development and operation of community-based management networks built around defined fisheries management units
3
Policy on adaptation strategies for climate change and marine protected area development
2 2
Review of the Ghana Tuna Industry to identify policy or infrastructure needs that threaten Ghanarsquos hub status
Strengthening capture fisheries management systems and capability
Development of fisheries and aquaculture management systems and processes and training
Strengthening fisheries information systems
Installation and operation of fisheries lsquodashboardrsquo database and information collection
Sub-Component 12 Introducing Fishing Rights ($15 M GEF)
Developing 4 pilot Stakeholder-Based Fisheries Management initiatives around defined fisheries units (ie local management initiatives tied to defined fisheries resources including demand-side governance initiatives)
3 2
Introducing and administering a licensing regime (registry establishment training stakeholder education) 2 2
Sub-Component 13 Adjusting Fishing Effort and Capacity to more Sustainable Levels and Supporting Alternative Livelihood Opportunities where Needed
Vessel decommissioning Decommissioning of 60 to 80 industrial trawlers in an environmentally friendly manner
2
Developing alternative livelihoods for crew of decommissioned industrialsemi-industrial
Skills training and small business development training and support for young (18-30 yrs) industrialsemi-industrial crew members willing to transition out of the sector
3
42
vessels
Alternative livelihood development to incentivize voluntary capacity reduction in canoe sector
Alternative livelihoods fund and CDD support to targeted fishing communities
3 2
Marine Resource Conservation
Would include confirming conservation priorities and management regimes and possible provision of support for alternative livelihood options (funded under 133) associated with conservation of coastal littoral and marine ecosystems as well as de facto protected areas associated with the development of oil and gas extraction
3
Sub-Component 14 Social Marketing Communication and Transparency)
Communications stakeholder consultations and awareness raising programs to support fisheries development
3
Component 2 Reduction of Illegal Fishing
Sub-Component 21 does not apply to Ghana
Sub-Component 22 Monitoring Control and Surveillance (MCS) Systems
Developing compliance systems and capability
Development of judicial and policy capacity (training)
Compliance risk assessmentstrategy systems and process development
Enforcement Unit establishment (dedicated facility)
Coastal surveillance stations 2
Facilities and training for participatory coastal surveillance of small-scale fisheries
3
Training for surveillance officers
Operation of aerial and water patrols (vessel leases aerial patrols operational costs patrol vehicles)
Observer program
Compliance education (stakeholder training signage) 1
Upgrademaintenance of the Vessel Monitoring System (VMS)
43
Component 3 Increasing the Contribution of the Marine Fish Resources to the Local Economies
Sub-Component 31 Fish Landing Site Clusters
Product diversificationvalue chain development
9 marine landing sites (basic infrastructure) at Axim Dixcove Fete Jamestown Moree Mumford Senya-Beraku Teshi and Winneba
3 1
2 inland fish landing sites (improved access and berthing infrastructure) at Abotoase and Dzemeni
3 1
2 ports developed (technical studies for 1 new port at Axim and additional berthing space in existing port of Elmina)
3 2
Sub-Component 32 Fish Product Trade Infrastructure Information and Systems
Export certification center development
Fish processing technology improvements 1 1
Technical assistance training and goods to support the National Fisheries Advisory Group
Sub-Component 33 Marine and Inland Aquaculture Development
Developing aquaculture policy and legal framework
Improving genetic quality of Tilapia fingerlings and breedstock
Catalyzing aquaculture development 2
Component 4 Coordination Monitoring and Evaluation and Program Management
Sub-Component 41 National Implementation
Technical assistance for Secretariat to the Fisheries Commission to implement the Project
Sub-Component 42 Regional Coordination
Technical assistance for Regional Coordination Unit at the CSRP support to Fisheries Information Systems (lsquoDashboardrsquo)
45
CHAPTER 6 ENVIRONMENTAL AND SOCIAL ASSESSMENT OF DRAFT FISHERIES AND AQUACULTURE SECTOR DEVELOPMENT PLAN (FASDP)
61 INTRODUCTION
This chapter examines environmental and social issues which need to be considered as part of the overall structural and economic adjustments in Ghanarsquos fisheries sector in the longer term (ie 1-15 years) The assessment deliberately focuses on the longer term because it will take a number of years before current plans start to have their full effect However the same temporal considerations apply to measures that are designed to avoid or mitigate potentially harmful effects so it will be important to start planning remedial actions as part of the joint Government of Ghana and World Bank fisheries programme
611 Key sectors and activities The fishing industry is divided first into marine capture and inland capture fisheries and then aquaculture For each of these three sectors activities are then broken down as follows Marine Capture Fisheries CATEGORY ACTIVITY Stock Management Research Surveillance reef building Harvesting Vessels Gear Skills capacity Marketing Sellers Buyers Processing Fresh fish Sun dried Smoking Freezing Consumers By market sector Support Sectors Boat Canoe Building fuel supply net making kiln construction
refrigeration transport cold store management Legal Enforcement Financing Investment in all elements Infrastructure Harbour wharf processing plant construction
Inland Capture Fisheries CATEGORY ACTIVITY Stock Management Research Surveillance Harvesting Vessels Gear Skills capacity Marketing Sellers Buyers Processing Fresh fish Sun dried Smoking Freezing Support Sectors Boat Canoe Building fuel supply net making kiln construction
refrigeration transport cold store management Legal Enforcement Financing Investment in all elements Infrastructure Harbour wharf processing plant construction
46
Aquaculture and Mariculture CATEGORY ACTIVITY Stock Management Research Surveillance Rearing Roe fingerling production cage -pond rearing Harvesting Vessels Gear Skills capacity Marketing Sellers Buyers Processing Fresh fish Sun dried Smoking Freezing Support Sectors Boat Canoe Building fuel supply cage construction kiln construction
refrigeration transport cold store management Legal Enforcement Financing Investment in all elements Infrastructure Harbour wharf processing plant construction
612 Evaluation Criteria The environmental and social assessment has been undertaken using a matrix (See Annex 114) which analyses the key sectors and activities of the fishing industry and the changes that are envisaged against a set of evaluation criteria Evaluation Criteria are broken down into environmental and social issues distinguishing between beneficial and adverse effects Table 61 below shows the relationship between the groups of criteria Table 61 List of Evaluation Criteria
Environment Social
Positive Adverse Positive Adverse
bull Sea bed rejuvenated
bull Fish stocks recovered
bull Biodiversity enhanced
bull Sea bed degraded
bull Fish stocks reduced
bull Biodiversity reduced
bull Increased harvest (catch volume)
bull Increased catch value
bull Reduced costs of inputs
bull Increased profit
bull Enhanced livelihoods
bull Increased job opportunities
bull Increased local economic multiplier
bull Reduced harvest (catch volume)
bull Reduced catch value
bull Increased costs of inputs
bull Reduced profit
bull Reduced livelihoods
bull Reduced job opportunities
bull Reduced local economic multiplier
The assessment process has involved systematically considering each sectoractivity against the evaluation criteria and recording either positive or negative results by drawing on the judgement of the consultancy specialists The findings are discussed in the paragraphs that follow and are reflected in Table 81 forming part of the Draft Environmental and Social Management Plan
62 DETAILED ASSESSMENT OF THE MARINE AND AQUACULTURE SECTORS
47
TunaIndustrial fleet streamlined and catch per vessel improved At present industrial trawlers have to travel increasing distances to fishing grounds and while the level of catch is remaining broadly static costs are increasing against available economic returns A major shortcoming is lack of investment in re-equipping the aging fishing fleet Many of the 90 vessels that make up this sector are increasingly unseaworthy and need to be replaced with modern trawlers and gear The plan is to buy out owners of substandard vessels by offering compensation at market value based on a full commercial survey Vessels remaining in the fleet will be required to meet exacting standards By reducing the number of old and inefficient boats this will allow each of the remaining vessels to catch a higher proportion of fish The aim is to ensure that Ghana is equipped with the latest vessels and technology in order to preserve the countryrsquos position as the hub of the West African tuna fishing and processing industry (see also the section on canneries below) The effect of these measures on the environment will remain broadly neutral since the same number of fish will be caught Providing other policies and increased surveillance are successful in preventing trawling in inland waters the smaller fleet will have to fish in deep oceanic waters This could potentially transfer some environmental effects on fish populations to other parts of the migratory cycle However this would become part of the international effort through fishing quotas to regulate overall catches Reduction in the size of the industrial fleet will mean that fewer men are needed to crew and service the vessels However in practice many men who work in this sector have only part time work and since a significant percentage of boats no longer put to sea the number of crewmen who will be displaced could be in the range of 1000-30003
It will be important to set up support services for those losing their jobs including retraining and welfare assistance where necessary
Decommissioning will necessitate the sale of seaworthy vessels and their removal from Ghanaian waters Other boats will need to be broken up and scrapped This process requires heavy duty specialized equipment and can release significant quantities of waste oil other toxic chemicals including refrigerants and asbestos used in pipe and engine room cladding Measures will need to be taken to ensure that proper environmental and health safety precautions are taken that decommissioning takes place in properly equipped boatyards and that all waste products are disposed of without environmental risk Cannery sector optimized The Fisheries and Aquaculture Sector Development Plan seeks to maintain the port of Tema as the centre of the Tuna canning industry in Ghana At present a proportion of Ghanarsquos tuna catch is diverted to neighbouring countries due to constraints on processing capacity These limitations include poor port infrastructure ageing equipment and delays in handling catch for some operators due to preferential treatment of vessels that are part-owned by the existing canneries Options for improvement include encouraging upgrading of the capacity of one or more existing canneries or promoting more competition in the processing sector and improving the infrastructure Providing modern building designs and construction techniques are employed and a full environmental assessment is undertaken in accordance with Ghanarsquos EIA regulations there should be no significant environmental or social risks associated with these development possibilities The potential economic benefit resulting from encouraging investment in this sector is very high
Industrial fishing excluded from inshore waters A major longer-term intention under the new fisheries plan (FASDP) is to ensure that existing regulations that restrict industrial and semi-industrial vessels from trawling in inshore waters are properly enforced This requires provision of surveillance
3 Based on an average crew of 20
48
equipment fast patrol vessels capacity building and training and increased staffing within Government agencies together with a full programme of awareness raising training and financial support to local bodies providing self-governance under new co-management services Restriction of industrial trawling in coastal waters will greatly ease pressures on fish stocks and reduce environmental damage to the sea bed In time this should lead to healthier fish population with more fish to be caught by the canoe industry as a result However the task of policing and enforcing regulations will not be easy and will take a number of years to bring into full effect Reduction in fishing activity by inshore trawlers will displace a number of crew members and have a short-term impact on dependent families until these individuals are either absorbed into the canoe fleet or find alternative employment There will therefore be a need to assist genuinely deserving cases where crew members (and their families dependents) need to transfer to other sectors of the economy These measures will only be required in the short term since the anticipated improvement in fish stocks will lead to improved economic performance in the canoe sector within which the bulk of employment exists
Expansion of deep water fisheries The fisheries plan notes that there may be a potential for exploitation or increased exploitation of some deep sea fish resources However the status and population dynamics of some affected species is not well known so any such activities should be scientifically monitored through research and enforced by MCS
Tema Secondi Port infrastructure improvements (equipmentbuildings) Under present conditions the transfer of fish from commercial and industrial vessels to canneries is often delayed by the time taken to offload crates and manouvre within the port area where there are conflicting activities There are also difficulties that arise when vessels owned by the canneries are given priority for landing leaving other boats waiting for many hours which can result in quality deterioration At this stage no details are available about the precise improvements that could be introduced and this will need to be investigated as the fisheries plan is advanced Any environmental effects from infrastructure improvements would be contained within the existing port areas and should be largely positive in reducing fuel (energy) costs and increasing overall efficiency It will however be important to carry out an environmental review of specific development proposals at the design stage especially if these involve plans for any dredging or for altering facilities for discharging waste and disposing of bilge water Both of these activities can have damaging effects on the sea bed (The first through dispersal of silt and sediment and the second through release of potential contaminants) Socio-economic effects from the infrastructure improvements should also be beneficial by removing delays increasing efficiency and reducing waste However there could be some slight reduction in manpower requirements leading to the need for skills retraining Regulating the catch (eg Fishing for selected species reducing juvenile catch to improve value of catch in inshore waters) The fundamental aim of the fisheries plan is to reduce the harmful effects on fish stocks and low economic returns from fish catches by phasing out open access for all and introducing regulation of fishing activity This is to be achieved through close cooperation between the Fisheries Commission Monitoring and Surveillance Unit as well as marine fisheries management division and individual fishing communities working together under a co-management framework The practical details will need to be worked out through each individual co-management group and initially the World Bank is offering to assist in the establishment of four pilots These bodies will test exactly what is required to increase fishersrsquo awareness to build capacity in self regulation and agree on appropriate measures
49
From discussion with stakeholders it is clear that while the broad principles are accepted the majority of the fishing community simply do not believe that the new regulations will be enforced because they have witnessed the failure of so many previous efforts to introduce firm management A major issue for the planned programme is therefore how to change this critical mindset without which very little progress is likely to be made in practice It will be necessary to demonstrate through the pilots that by regulating fishing activity direct benefits will accrue to those participating fishing communities Unfortunately efforts to eliminate harmful practices are unlikely to result in an immediate gain in fish stocks Instead catches are likely to fall in the short term It will therefore be essential to introduce other forms of incentive to cushion short term losses Such measures might include the purchase of new nets and gear for sale at subsidized price to local cooperatives the introduction of cash incentives for canoes demonstrating best practice in the use of gear and nets preservation of the catch using ice and landing and marketing fish of the required size and quality As restriction of open access starts to take effect there should be positive environmental gains in terms of improving fish stocks and less damage of the sea bed On the other hand both fishers and fish processors will feel the adverse temporary effect of reduced catches These social and local economic impacts will need to be monitored closely and assistance provided to help foster alternative livelihoods Cephalopus (Octopus) harvesting encouraged in inshore waters Although most fish species are currently exploited to unacceptably high levels within coastal waters there is a specific opportunity to increase the number of octopus caught by pot fishing This fishery could be developed by both the semi-industrial and canoe sectors Taking octopus in pots would have no adverse physical impacts on the sea bed and could allow very slight expansion in fish species that are preyed on by octopus At the same time it is important to note that there is only limited information on species composition and functioning of selected marine habitats including those of the octopus and more research should be undertaken on this and other species that could be selected for expanded fishing activity There would be clear socio-economic benefits arising from the creation of this new fishery Focusing fish landing at specific landing sites (to improve opportunities for subsequent marketing processing) Plans are already being developed for the enhancement of landing and processing facilities at a number of existing locations along the coast These locations include the construction of harbours at Jamestown and Elmina and development of landing sites at Teshie Ada Axim Dixcove Winneba Mumford SenyaBeraku Gomoa Fetteh Moree Keta Dzemeni and Tapa Abotoase Two sets of issues need to be considered in relation to these improvements all of which affect existing fish landing and processing sites The first is the nature of the physical works and infrastructure and it s potential effect on the marine and terrestrial environment The second is the socio-economic impact Both Elmina and Jamestown are long established fishing ports where the catch is landed either directly onto the beach or shallow wharves It is understood that the primary aim of the improvements will be to increase the area of permanent wharves to make it easier for fish to be offloaded to reduce the time taken in transferring stock to processing plants and to introduce modern technology In the case of other smaller landing sites the scale of improvements will be quite modest involving improvement to existing short stretches of access road the erection of stores for nets and other gear and provision of covered areas to provide shade for net-mending With all proposals for physical infrastructure development there will be a need to consider possible
50
environmental implications Due to the existing nature of these sites there are no major industrial or other commercial processes in the vicinity which could give rise to cumulative impacts including contamination of fish products The scale of plant needed for ice-making and storage and commercial smokeries is commensurate with the artisanal nature of the fishing activity itself and would not give rise to any significant environmental effects on air or water quality Harbour works could potentially involve some small scale dredging (for example the removal of accumulated silt) Where dredging is required it will be important to identify disposal areas (either at sea or on land) where silt can be deposited without damage to sensitive habitats In terms of economic and social impacts it is not clear at this stage who are likely to be the major investors from the private sector although it may be assumed that existing operators who have access to finance will be the main beneficiaries Over time as landing marketing and processing become more efficient it is possible that individuals in the traditional fish smoking sector will lose a significant proportion of their trade as the product switches to fresh or frozen fish sales for transfer to the major urban markets and the beach price for fish rises The draft Ghana fisheries and aquaculture sector development Plan notes in annex 2 that proposed facilities associated with the ports and landing sites may not have support from fish mammies or at least formidable commercial advocates able to resist any opposition from that quarter Inspection of major fish landing areas like Elmina and Sekondi indicates that the existing social and commercial structure of support activities to fish harvesting is very complex and involves almost every member of the community including children and the elderly Such activities include net mending boatbuilding metalworking (for cooking pots stoves and grills supplies (ropes weights tar paint wood) fuel supplies ice crates transport etc Leaders of the fishing community confirmed that in principle the improvements of facilities is welcomed provided that safeguards are in place for those who may lose part or all of their current trading activity through rationalisation Stabilise fleet capacity at a sustainable level Fishery experts consider that there would be significant benefits in reducing the number of canoes from the present 10000-12000 to around 8000-9000 which correlates with the number operating in the mid 1990rsquos when catches were at optimum levels At the same time the Fisheries and Aquaculture Plan stresses that the canoe sector will remain at the heart of the Ghana fishing industry and this has strong political enforcement Consequently there is unlikely to be any enforced reduction in the number of canoes holding licenses and owners of all existing canoes will be able to register their vessels The ability of canoe owners to pay annual licence fees should rise as the overall measures to increase efficiency and improve catches take effect However many people anticipate that over time as the annual cost of holding licenses rises less efficient fishers will sell their licenses (and hence their rights to fish) There may therefore be a de facto reduction in the size of the canoe fleet Even if numbers do not decrease the fleet could be stabilized at its present size by taking a decision not to grant new licences The draft plan discusses the fact that under existing law (section 53) there is a requirement for licenses to be issued on demand (presumably to ensure that Ghanaians are not barred from subsistence fishing) It is argued in the plan that this is a misconception since canoe fishing is largely a commercial activity and it is concluded that lsquoit is therefore essential that the number of canoe licenses can be controlled in future and the legal basis for these controls must be reviewed as a matter of priorityrsquo Decisions of this nature will require the full support of local co-management groups if they are to be effective but committees could easily come under pressure to make exceptions as the coastal population continues to rise and families without alternative livelihoods start lobbying for assistance
51
Accusations of preferential treatment of certain individuals by committees (or committee officials) - possibly linked with suggestions of bribery and corruption -could cause a lot of social tension and start to undermine community trust in the need to work together to improve fisheries management It is therefore most important that the detailed proposals for co-management address this risk and include proposals for mitigating individual hardship of the less advantaged ndash for example by offering voluntary retirement with some form of incentive Influencing marketing to maximise value and reduce post harvest losses (marketing cooperatives strong market structures etc) FAO has estimated that physical post harvest losses in Ghana amount to between 3 and 17 of smoked fish production and 16-20 of gillnet landings The plan notes that introduction of lsquonew generationrsquo small scale fish smokers should be introduced to replace the traditional Chorkor model This would improve fish product quality by eliminating charring of fish over open flames and also protecting operatorsrsquo eyes from the damaging effect of smoke and particles The other major improvement in post harvest value and profits would arise from greater use of ice throughout the supply chain Developing Aquaculture A distinction needs to be made between aquaculture development in ponds and dugouts which are self-contained and fish rearing in cages within open water In the case of farm ponds the commercial rearing of fish is little different to other forms of intensive livestock rearing Providing there is no direct connection to rivers and streams there is little likelihood of interaction between farmed and wild stocks which could spread fish infections and parasites In the case of fish farms in open water (rivers and lakes) there are well known risks of the spread of disease which can arise if overstocking occurs Intensive feeding of large numbers of fish in a confined area can lead to significant deterioration in water quality through the build up of nutrients from wood and waste It is also possible for antibiotics and growth hormones to be dispersed beyond the area of farm cages Genetic modification of farmed fish can also affect the local fish population through escapes All of these issues are capable of being managed and mitigated through good initial planning and design and subsequent maintenance and supervision It will therefore be necessary to develop additional regulations and guidelines specifically for the aquaculture sector 63 SUMMARY OF ENVIRONMENTAL RISKS AND OPPORTUNITIES Review of the full range of governance and development activities suggests that there are no high levels of risk to the marine or littoral environment Successful implementation of the Policy and plan should in fact result in very significant environmental gains Over a timespan of 5-20 years five activities in particular should result in significant improvements in the condition of the sea bed in coastal waters (to a depth of 30 metres) reestablishment of benthic flora and niche habitats increased fish stock and enriched biodiversity These interlinked activities are bull The exclusion of industrial vessels and trawling within coastal waters bull Regulation of fish catches through zonation seasonal control of fishing and standards for vessels
gear bull Stabilisation of the fishing fleet within sustainable harvesting yields bull The adoption of management plans formulated and agreed with full cooperation of local
communities bull The introduction of fishing rights through co-management agreements and bull Well planned consultation and information dissemination throughout the fisheries sector
52
Three components of the development plan have been identified where minor to moderate risk to the physical and biological environment could arise if proper design and implementation standards are not adhered to These relate to bull A potential risk of over-exploitation of new catch species in deep water off the continental shelf if
such development is not accompanied by through research to establish the sustainable yield of target species
bull Strictly localized effects on the physical environment from construction of landing wharves or jetties and other harbour facilities and
bull Infrastructure development at the existing ports of Tema and Takoradi All of these risks are capable of being fully managed by improved governance in the fishing sector and EIA procedures that are well-established in Ghana 64 SUMMARY OF SOCIO-ECONOMIC RISKS AND OPPORTUNITIES Implementation of the Plan Project will bring about substantial change in the fisheries sector and over time increased revenue reduction of post[harvest losses and added value to fish products will bring major economic returns At the same time there will be some individuals who do not participate in direct gains and whose livelihoods could be adversely affected if appropriate safeguarding measures are not put in place The level and extent of these socio-economic risks will be determined by 1 the level of commitment that is entered into by Government and its development partners to
deliver incentives to vulnerable and disadvantaged groups and 2 the speed with which the sector is transformed Rapid change could cause significant
displacement of less-efficient operators especially within the semi-industrial and canoe sector which would have serious ramifications for dependent communities However these effects can be marginalized if the development programme is carefully phased to ensure that alternative livelihood and employment incentives are available
The main risks to local livelihoods relate to the potential for bull loss of employment for crews of unseaworthy obsolete vessels ( from all sectors including
industrial semi-industrial and canoes) that are withdrawn from the fishing fleet because they no longer comply with license regulations
bull the inability of vulnerable and disadvantaged groups including artisanal fishers vendors and individual fish processors in small fishing villages to adjust to new market conditions at selected landing sites
53
CHAPTER 7 ASSESSMENT OF POLICY OPTIONS
71 INTRODUCTION
In order to place the significance of the environmental and social safeguards assessment in context this chapter examines the possible consequences of different policy responses to the existing challenges that face the fisheries sector in Ghana These different policy responses range from a continuation of the status ndashquo effectively a ldquodo-nothingrdquo option (A) to full-scale commitment by all stakeholders to achieving a sustainable fisheries future the ldquoOptimum Solutionrdquo option (C) Various less sustainable outcomes lie in between these two ends of a continuum of policy choices and these are represented by the ldquoWeak Solutionrdquo option (B) 72 OPTION A ndash DO NOTHING Background research and discussion with stakeholders indicates that practical capacity to deliver on clearly stated national goals for sustainable fisheries livelihoods and the reduction of poverty is weak This situation exists despite the fact that Ghana has a strong legal framework for management of its fisheries including the Law Policies and Regulations There is inertia and strong resistance on the part of the majority of players to accept that it is largely their own actions which are responsible for present conditions This in turn leads to the attitude that it is only the lsquoGovernmentrsquo that must act by providing increased subsidies and cushioning the industry against further deterioration in catches Unfortunately there is overwhelming evidence from around the world that where fish stocks are exploited beyond their natural capacity to regenerate this can lead to sudden and near-total collapse Ghana has historically been one of the strongest fisheries in West Africa but the signs are ominous that current levels of exploitation are leading to progressive decreases in annual catches for most species in both marine and inland waters As fishing effort intensifies with an increasing number of all types of vessel using illegal methods and inappropriate gear the distinction between the traditional lsquopeak season and lean season (linked to migration patterns breeding cycles and upwelling) is becoming blurred This is clearly illustrated by a statement from one of Elminarsquos fish mammies ldquowe use to smoke the herring in the peak but now the fishers bring them all the yearrdquo Use of monofilament nets light dynamite and chemicals to obtain fish in the lean season is aggravating a situation where too many boats are chasing too few fish Many fishers blame the reduction of catch on global warming for increasing water temperature the emergent oil and gas industry for restricting access to traditional fishing grounds and industry and urban development for increasing pollution leading to deterioration in water quality Each of these assertions warrants careful consideration but the industry is generally in denial when it comes to the primary fact ndash too many fish including juveniles are caught to allow regeneration of the stock In addition weak governance and lack of resources to ensure implementation of policy result in a situation where the law can be ignored with impunity If collective failure to recognize the seriousness of the current position and lack of commitment to taking hard decisions continues the omens for the future are not good Within a period of 10-15 years fish catches could fall by 50 or more from their present level Impacts on each species would vary and catches of some fish with regional or global migration patterns could remain viable (although this depends on the international conservation effort) On the other hand stocks of fish that provide the mainstay of local food resources herring and sardine could be decimated
54
Complete collapse of all fish species is unlikely but it is possible to envisage a situation where catches might fall below 300000 tonnes a year by 2025 (a reduction of more than 25 from present levels) The most serious consequences would be felt as a result of the social and local economic impact on fishing communities Perhaps 30000 men representing the crews of 3000 canoes and semi industrial boats and 15000 women engaged in marketing and processing would lose their present livelihoods Population migration away from the coast could follow and severe social pressures and local economic hardship This is clearly a ldquoworst caserdquo scenario and if conditions were to worsen gradually it might be possible to intervene but the fact has to be accepted that fish stocks are dynamic and subject to rapid decline (as in the case of the North Sea Herring and Atlantic Cod) 73 OPTION B THE lsquoWEAKrsquo SOLUTION The bleak future painted in Option A is unlikely to arise if the present policy and draft fisheries development plan is followed since these are specifically directed to addressing the major challenges However realization of the aims is dependent upon delivery across a wide range of initiatives by multiple stakeholders The following paragraphs illustrate some of the ways in which delivery of policy objectives might be thwarted These may be summarized as
bull Commitment to good governance and institutional reform bull Political resolve to implement unpopular measures bull Availability of adequate technical and financial resources bull Inertia to necessary changes in fishing practice
Good Governance and Institutional Reform Fundamental reforms are required to fully equip the national fisheries management effort at government level This includes introduction of change management clarification of responsibilities for senior staff rationalization of financial management systems provision of equipment expansion of staff numbers additional training and capacity building As an illustration of the extent of the effort required reference can be made to just one topic area the issue of monitoring control and surveillance At present the Fisheries Commissionrsquos MCS Unit has only 10 employees to oversee implementation of the fisheries regulations throughout Ghana This number will be increased as other institutions are engaged in joint monitoring initiatives but it is obvious that staff numbers and capacity will need to be expanded if regulations on fishing activities are to be affected Enforcement is only one part of the equation however Much greater emphasis will need to be placed on voluntary controls and self-policing at community level through Co-management schemes
Failure to press ahead with governance and institutional reform could delay the process of introducing and registering licenses which represents a crucial first step in moving from open access to managed access in the fisheries sector Given the urgency for action the five years allowed in the current plan for completing the registration process seems very generous Political resolve to implement unpopular measures Stakeholder meetings have confirmed the significance of party political influence as a constraint on achieving progress in the reform of the fisheries sector The offer of incentives like subsidies or the promise of new facilities and equipment are regularly employed by individual politicians to garner votes whether or not these form part of party manifestos Examples have been quoted to the consultants where enabling regulations that might restrict fishing access and prove unpopular amongst the fishing community are quietly ignored and officers may be discouraged from pursuing breaches of the law where the offender has political influence These issues arise with governments of all political
55
persuasions and can apply at all levels from District Assemblies through to regional and national committees
A serious issue with fisheries sector reform is that once actions have been taken to conserve fish stocks it may be years before the full benefits are felt and the results are evident in terms of increased catches This makes it harder for governments to institute unpopular reforms ndash even though these are in the best interests of the nation fishing communities and individuals Fishermen and their families are used to seeing an instant lsquosame day returnrsquo on their catch and are less willing or able than stakeholders in other economic sectors to wait for gradual improvements There is an urgent need to establish cross-party support for the fisheries sector in Ghana and to seek agreements between the main political parties to support established policy and regulations where these are in the interests of delivering sustainable fish stocks Availability of Technical and Financial Resources The process of moving from complete open access to restricted use rights for both marine and inland capture fisheries will take many years to complete Progress will be heavily influenced by the level of political will availability of technical assistance and financial support Existing subsidies (pre-mix fuel and import tariffs) are seen as a deterrent to the encouragement of more efficient business practices However in order to reduce dependencies on these forms of government aid there is also a need to underwrite new forms of economic enterprise by giving help to start-up businesses developing training centres and promoting alternative livelihoods for those individuals who are either displaced or voluntarily give up work in the fisheries sector Inertia to Change Traditional fishing practices are quite literally a way of life for many Ghanaians and have been handed down from generation to generation These traditions are closely interlinked with cultural practices and power and influence resides in specific families with hereditary authority In order to change attitudes and gain acceptance of new approaches to fishing there is a need for a major awareness building and communications strategy targeting in particular the traditional leaders of the fishing industry Without such a plan it will be difficult to break down the internal resistance and inertia towards change The constraints that have been outlined above in relation to the lsquoweakrsquo option are very real and in combination they present a serious barrier to progress It will require real political commitment on the part of Government and strong financial support from international partners to break down these barriers 74 OPTION C THE lsquoOPTIMUMrsquo SOLUTION
The new Draft Fisheries and Aquaculture Plan together with the Act and Policies provide a solid foundation for revitalising the fisheries sector in Ghana However for the reasons discussed in relation to options A and B above there are a number of impediments that need to be overcome In addition to the measures in Option B an ldquoOptimumrdquo solution would also include
A coherent mix of Incentives (carrots) and Regulation (sticks) A top priority in developing existing strategies and plans will be to ensure that measures are in place to offer encouragement and practical assistance to fishers to convert to more sustainable practices while at the same time introducing effective enforcement There are some real challenges with both of these goals
56
New forms of incentive need to be developed to convince boat owners and their crews that it is worth their while to drop illegal methods (dynamiting use of monofilament nets etc) and to reduce the level of fishing effort (through close seasons introduction of restricted zones etc) Without these incentives it is highly unlikely that there will be significant take-up of the fisheries stock management and conservation message Special attention needs to be given to the role of chief fishermen and local community councils in developing effective local policing since it is impractical to rely on a national MCS team to regulate canoe activity in either the marine or inland capture fisheries The national MCS team will have its own responsibilities for policing local and international waters in relation to industrial and semi-industrial sized vessels Integrated Coastal Development The long term success of the fisheries strategy depends upon reducing fishing effort to a level at which catches become both sustainable and profitable for those who remain in the business This in turn requires that those displaced from the industry are able to find gainful employment and livelihoods in other sectors of the economy The fisheries industry is often seen as a separate economic sector which attracts its own funding and support but in order for the necessary reforms to take place these attitudes will need to change A new approach is required to lsquointegrated coastal developmentrsquo following the lessons from integrated rural development Many fishing inland and marine fishing communities are almost wholly dependent on fishing with less than 10 of the local economy being devoted to other industries Reform of the fishing sector therefore requires that as much ndash if not more ndash effort is devoted by government and its international partners to building up complementary economic activities in construction transportation manufacturing food processing environmental conservation and tourism There is a need to explore new state industry partnerships to establish appropriate economic development agencies and to coordinate activities between relevant state institutions ministries and departments under the current decentralisation initiatives with district assemblies taking a prominent role If initiatives of this sort are taken forward it will make the task much easier in persuading conservatively ndashminded fishing communities that they need to simultaneously develop their own entrepreneurial flair and impose their own discipline
57
Chapter 8 DRAFT ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK (ESMF) 81 INTRODUCTION Previous chapters of this report have described the principal environmental and social impacts that are likely to arise from reform in the fisheries sector This chapter sets out the Framework (ESMF) for an Environmental and Social Management Plan (ESMP)The first step has been to outline specific objectives to be achieved through implementation of the ESMF These objectives relate specifically to the issues described in earlier chapters Subsequent sections of the chapter detail the measures which are required to respond to specific areas of environmental and social impact through mitigation and amelioration works They also describe the types and level of environmental monitoring required together with the institutional aspects which need to be improved in order to support the fisheries sector 82 STRATEGY AND OBJECTIVES The basic aim of the environmental and social management plan is to set out guidelines for participatory programs under which members of local fishing communities and civil society in general can become involved in the design and implementation of local fishery co-management maintaining sustainable local livelihoods and achieving local monitoring of fishery efforts The basic principle for future fisheries management is that both marine and inland waters will be demarcated as territories for use rights to fisheries (TURFs) The principal goal of government policy in the fisheries sector is to ensure that the fisheries industry plays an increasingly important role in supporting the growth of the economy as outlined in the Ghana poverty reduction strategy (GPRS II) and the Republic of Ghana fisheries and aquaculture policy This goal will be supported by implementation of the fisheries and aquaculture sector development plan over the next five years In this timescale the aim will be to bull improve management of fisheries the conservation of aquatic resources and protection of the
natural environment bull promote value addition in the fisheries sector and the improvement of livelihoods in fisheries
communities bull encourage sustainable development of aquaculture bull improve the services provided to the fisheries sector by the fisheries commission and supporting
institutions The overall consequences of this strategy and the investments that are being made by the government and its aid partners will be stabilisation of fish stocks and sustainable catch levels a strengthening of the national economy and creation of a more robust fisheries industry with consequent benefits for fishing communities Impact assessment confirms that the result will be significant benefits for the marine environment and local economy However depending on the rate of transition from an open access to a fully regulated market a number of adverse effects could arise unless appropriate mitigation measures are put in place Specific issues which require attention in this plan are listed below bull potential risks of environmental degradation through development of new fishing targets in
deep water
58
bull localised environmental impacts at construction sites bull loss of resources for individual operators due to restricted or controlled access to fishing
grounds bull displacement of labour from crews of vessels that are withdrawn from the industrial and semi-
industrial fleet bull Decommissioning of obsolete industrial vessels may not necessarily lead to recovery of fish
stocks Catch Per Unit Effort (CPUE) may increase This could lead to loss of livelihoods to crew members and the owners of the decommissioned vessels it could increase catch for the few vessels remaining in the system
bull increase production costs due to idling time in closed seasons for fishing bull exclusion of some groups and individuals seeking entrance to the industry following completion
of licensing bull concentration of processing and marketing at selected landing sites leaving Fish Mammies and
their dependents in other smaller fishing communities at an economic disadvantage bull displacement of traditional canoe building and other ancillary support industries by more
efficient and modern methods of construction and the inability of some workers in these trades to train and re-skill in the use of modern materials
bull lack of employment opportunities in alternative sectors The ESMF will set out specific actions to address these concerns through a coordinated set of interlinked proposals as follows 1) Preparation of local management plans and close surveillance of all new fishing enterprises in
deep waters
2) Preparation of environmental protection clauses to be included in all contracts and agreements for physical development work
3) Regular inspection by environmental protection officers of construction work at harbours and landing sites
4) Establishment of community management plans to provide support to those groups and individuals who are adversely affected by any of the measures listed above
5) Creation of community liaison groups to actively support community development alternative livelihoods and conversion to new areas of economic activity for those Fisher families or individual fishers who are adversely impacted
6) Introduction of skills training centres and business advice for small and medium enterprise development
7) Establishment of a coastal development agency drawing on the resources of the ministry of local government agriculture and tourism (others to be added) to coordinate integrated projects and initiatives for economic development linked with the existing coastal zone management plans
8) Creation of a liaison group between the government of Ghana and its international development partners to ensure that investment in the fisheries sector is targeted in the most effective way to deliver plan objectives and avoid duplication of effort
59
83 COMPONENTS OF THE ESMF The following paragraphs provide a summary of the draft ESMF 831 Local Management Plans these plans will be prepared for discrete zones of influence around specified fishing settlements Each plan will contain the same standard list of relevant activities that are to be monitored 832 Environmental Protection In relation to construction activity a checklist will be prepared identifying precisely what level of environmental scrutiny is required for specific types of development This checklist will be prepared by the Fisheries Commission with the support and advice of the Environmental Protection Agency 833 Small-Scale Project Development and Livelihood Restoration a list of potential micro-projects will be prepared by the Fisheries Commission which are regarded as suitable for support funding Demand for these micro-projects will be determined at the local level (ie in villages and fishing communities) Applications for funding of micro-projects will be submitted to the community liaison group for vetting and recommendation based on pre-established eligibility criteria Recommended projects will be referred for formal approval at national level (or through the Coastal Development Agency) 84 POTENTIAL PROJECT IMPACTS ON ASSETS AND LIVELIHOODS The project will have some adverse impacts on assets and livelihoods Therefore provisions will be made under the ESMF to minimize all such impacts including those of socio- economic significance and on any environmentally sensitive sites Provisions are also made in the RPF to accommodate all potential situations including cases that may entail actual displacement and livelihood restoration assistance in accordance with the Governmentrsquos policy and World Bank Policy on Involuntary Resettlement OP412 (see Chapters 9 and 10) The potential social and environmental impacts associated with the project (see Chapters 5 and 6) are summarised in Table 81 and the approach to related mitigation measures is defined in section 85 and Table 82 below
Table 81 Potential Environmental impacts and Social issues
Type of Activity Description Environmental Significance
Social Significance
Decommissioning of obsolete industrial vessels
Scrapping of vessels may release toxic waste (contaminated oils asbestos pipe wrapping and insulation etc)
Contamination of landfill dumps
Related health hazards
Laying off of work force Recovery of fish stocks in areas currently over-fished by trawling
Decommissioning of excessovercapacity would result in loss of livelihoods for crew members
60
Plan for fishing capacity reduction
introduction of licensing system for canoes and enforcement of licensing system for semi industrial vessels
Reduced catch from the decline in the use of prohibited fishing methods (activities) as stipulated in the Fisheries Regulation 2010 (LI1968) eg use of light dynamite etc
Reduction in fishing capacity should lead to significant recovery of fish stocks with long term benefits for all
Short term reduction in fishing effort and increased regulation may prejudice vulnerable sectors (illiterate elderly fishers) Capping on new entrants may remove the safety net opportunity offered by fisheries to would-be fishers who may be without alternative livelihoods
Harbour development and landing site improvements
Construction of access road improvements Erection of fish processing and ice making plant The Project could give rise to a small level of physical displacement for some sectors of individual communities
Removal of shelters homes Displacement of boat repair and trading sites for local community
Possible non-voluntary resettlement including vulnerable groups (women children and the elderly)
Adaptation Strategies to climate change
Introduction over time of regulations relating to fishing activity in rivers lakes estuaries lagoons and lsquoareas of upwelling affected by climate change
Measures to combat tackle rising temperature and other climate induced changes should ameliorate environmental impacts
Both beneficial and adverse effects may result from changes in climate (eg faster growth rates from higher water temperature spread of invasive species)
Establishment of exclusion zones ndash oil production and marine protection areas
Restrictions on fishing in oil production areas and marine protection areas
Positive ndash recovery of fish stocks but also potential risks of pollution from oil leaks and human waste
Temporary loss of livelihood for those fishers displaced from lsquotraditionalrsquo fishing grounds
Development of Co-Management System
Creation of 4 pilot Stakeholder ndashbased Fisheries Management Initiatives
Demonstration of practical benefits for the marine environment resulting from elimination of damaging practices
Greater social cohesion and sense of purpose established
61
Type of Activity Description Environmental Significance
Social Significance
Support for PAPs Establishment of enterprise training programmes
Development of criteria for defining Project Affected Persons (PAP) Development of skills training schemes enterprise allowances alternative livelihoods fund
Major benefits for PAPs ndash but scope for misinterpretation mismanagement of programme at local level Jobs created under social significance should be familiar to the fishers ie things they will be willing to do
Developing Compliance Systems
Establishment of enforcement unit and development of facilities and training for participatory coastal surveillance of small-scale fisheries
This component will greatly improve controls over environmentally unfriendly damaging activities
A number of new jobs should be created under this programme
Improvements in fish processing technology
Development of more efficient fish processing plant
This measure should reduce significantly the proportion of fish lost or degraded post harvest Improved fish processing technology will also reduce wood used from the forest as firewood for fish smoking
Potential displacement of vulnerable groups (women children and the elderly)who currently participate in fish drying curing using basic equipment
Construction of fish ponds
Expanding areas of dug-outs and other farm ponds
Small scale impacts on vegetation stream flow
Displacement of existing land users
Catalysing aquaculture development
Encouragement of larger fish farming enterprises Installation of fish cage aquaculture
Localised deterioration in water quality increased nutrients leading to eutrophication potential spread of fish parasites disease
Potential competition with free capture fisheries displacing vulnerable groups in existing fishing villages
62
85 PROPOSED MITIGATION MEASURES AND COST ESTIMATES Mitigation measures The potential environmental and social impacts to be addressed within the context of preparing this Environmental and Social Management Framework are generalized as shown in Table 82 below It is not possible at this time to prepare specific mitigation measures It is expected though that environmental and social assessment studies will be carried out within specific localities as and when required The framework for compensationresettlement (See Chapters 9 and 10) will then be applied incorporating (1) specific institutional arrangements (2) resettlementcompensation eligibility criteria (3) implementation procedures (4) financial responsibilities and (5) monitoring and evaluation plan Livelihood restoration measures Furthermore the livelihood restoration measures will consider issues such as
(1) income levels of affected persons
(2) other non-monetary sources of livelihood
(3) constraints and opportunities for income generation
(4) number of persons not able to revert to previous occupation and
(5) existing skills of affected persons
Table 82 Proposed mitigation measures for some potential impacts
Type of Impact Description of mitigation measures
1 Decommissioning of obsolete industrial vessels
a) A register will be prepared of all industrial vessels that are due to be decommissioned recording the owner and location of each vessel b) A system will be introduced for tracking progress on decommissioning including the means of disposal and measures taken to dispose of all potentially toxic or hazardous materials c) Persons who lose their job or livelihood as a result of a decision to decommission any particular vessel will be entitled to benefit from the skills training schemes enterprise allowances alternative livelihoods fund being developed
2 Plan for fishing capacity reduction
a) A full Social and Environmental Impact Assessment will be carried out on the Plan for fishing capacity reduction and appropriate measures for ameliorating and mitigating adverse effects on affected sectors of the community and PAPs will be incorporated in a revised edition of this Fisheries Environmental and Social Management Framework
63
3 Harbour development and landing site improvements
a) All harbour development proposals will be subject to Environmental and Social Impact Assessment (ESSA) in accordance with EPA Regulations b) Proposals for improvement of individual landing sites will be assessed in accordance with the checklist (832) and submitted to EPA for a ruling on the level of environmental assessment that is required which will depend on the nature of the intended works
4 Adaptation Strategies to climate change
a) An adaptation Strategy shall include proposals for mitigating any impacts on the environment or social welfare of local communities
b) Any strategy for responding to potential effects of climate change on the fisheries sector will be submitted to EPA for review to determine whether an SEA or EIA is required
5 Establishment of exclusion zones ndash oil production and marine protection areas
a) Proposals for restricting access of fishing vessels to oil production areas and marine production areas shall be subject to an Environmental and Social Assessment which shall be submitted for approval to EPA b) In the event that restrictions are likely to adversely affect fishersrsquo livelihoods the provisions set out in 7 below will apply
6 Development of Co-Management System
a) Development of co-management systems will require full cooperation and engagement of all stakeholders In the unlikely event that the provisions of any scheme are challenged by local communities there shall be a right of appeal to the Minister of Food and Agriculture and the Fisheries Commission acting jointly
7 Support for PAPs
Establishment of enterprise training programmes
a) Identification of vulnerable people including women children and the elderly and identification of the cause and impacts of their vulnerability shall be established through direct interviews and procedures to be developed as part of 6 above b) A high priority within the Fisheries and Aquaculture Sector Development Plansrsquo first five year programme will be the development of specific proposals for the establishment of skills training programmes and the establishment of enterprise allowances and an alternative livelihoods fund c) The measures outlined in 7b) above will be targeted specifically at PAPs and vulnerable sectors of the community
8 Developing Compliance Systems
a) All proposals for securing compliance with fisheries regulations shall be subject to review by a fisheries stakeholder committee to be established by the Fisheries Commission with the remit of ensuring that the measures themselves and penalties for failure to comply are commensurate with the ability of offenders to make restitution and do not unfairly penalize vulnerable sectors of the community
9 Improvements in fish processing technology
a) All plans and proposals for the introduction of new fish processing technology shall be published and shall include a statement on the likely impact of the project on existing processors within the local community
64
b) Any members of the public who consider they are unfairly disadvantaged by proposals for the introduction of new technology may apply to the local co-management committee to determine whether or not they fall within the category of PAP (see 6 and 7 above)
10 Construction of fish ponds Proposals for the construction of new fish ponds shall be assessed in accordance with the checklist (see section 832)
11 Catalysing aquaculture development
a) All proposals for aquaculture development shall be in accordance with the provisions laid down in Local Management Plans applying to specific TURFs
65
1
EXECUTIVE SUMMARY
This report draws together the contents of two separate documents which examine a number of interrelated issues concerned with environmental and social safeguards for the development of the fisheries sector in Ghana
The first document (Part A) contains the Environmental and Social Assessment (ESA) of the Ghana Fisheries and Aquaculture Sector Development Plan (FASDP) together with a draft of the Environmental and Social Management Framework (ESMF) that will be adopted by the Government of Ghana This document is reproduced in Chapters 1-8 of the Composite Report
The second document (Part B) contains the outline structure of Ghanarsquos National Process Framework (NPF) for implementing the design and implementation of local fishery co-managementmaintaining sustainability of local livelihoods and local monitoring of fisheries efforts together with an outline Resettlement Policy Framework (RPF) These elements are covered in Chapters 9-10 of the Composite Report
This Composite Report and its individual components have been prepared on behalf of the Government of Ghana and the World Bank Following review by both parties it will be adopted as part of the framework leading to promotion of the Ghana Fisheries and Aquaculture Sector Development Plan
Chapter 1 of the Report describes the need for environmental and social safeguards in the fisheries sector It notes that the overall aim of FASDP is to improve fish stocks and increase the sustainability of fishing activity which will have long term environmental and social benefits for the Country
Chapter 2 summarises the basic aims of the Ghana Fisheries and Aquaculture Sector Development Plan and proposals for financial and technical aid which are being developed by the World Bank A decision on funding support will be taken by the World Bank in 2011 The World Bank is proposing to support FASDP under four key components These are Good Governance and Sustainable management of the fisheries reduction of illegal fishing increasing the contribution of the marine fish resources to the local economies and assisting with coordination monitoring evaluation and programme management
Chapter 3 provides a baseline description of the current nature and importance of Ghanarsquos marine and inland fisheries which provide 65 of the countries protein requirements and sustain the livelihoods of almost 10 of the Ghanarsquos population Unfortunately however fishing is approaching a crisis In recent years the annual volume of catch has fallen (from in excess of 500000 to under 400000 tonnes) but at the same time fishing effort has increased If it were not for government subsidy the economic returns could no longer be justified since it costs more to catch and land fish than they are actually worth in the market place Fishing activity (principally trawling) is causing substantial damage to the marine environment while illegal methods in the canoe sector including dynamiting and use of chemicals threaten fish stocks and human health
Chapter 4 examines the governance legislative and policy framework under which reforms in the fisheries sector will take place The chapter identifies five World Bank safeguard policies that are potentially triggered by FASDP These are OP 401 Environmental Assessment OP404 Natural Habitats OP 409 Pest Management and OP 411 Physical and Cultural Resources and OP 412 Involuntary Resettlement In most cases the range of projects proposed under FASDP would have minimal impacts under these safeguards but there is nevertheless a need to ensure that adequate
2
protection and mitigation is provided through implementation of an Environmental and Social Management Plan
Chapter 5 considers the four funding components under which the World Bank is proposing to support the Ghana Fisheries and Aquaculture Sector Development Plan These cover
1 Good governance and sustainable management of the fisheries 2 Reduction of illegal fishing 3 Increasing the contribution of the marine fish resources to the local economy and 4 Coordination Monitoring and Evaluation and Program Management The potential for investment to give rise to adverse effects on the environment andor social conditions is reviewed It is concluded that that there are unlikely to be any significant adverse environmental or social effects as a result of the planned investments The only possible exception relates to the effectiveness of measures that are put in place under Sub-Component 12 to support pilot stakeholder-based fishery initiatives The outcome of the overall program will depend heavily on the success of these pilots For this reason it is essential that planning of the pilot initiatives is linked closely with measures for supporting alternative livelihoods and strengthening processing and marketing initiatives under Sub-Components 13 and 14
Chapter 6 provides an analysis of the environmental and social issues raised by the wider fisheries and aquaculture programme and as such it constitutes the Environmental and Social Assessment (ESA) A matrix is used to identify potential interactions between elements of marine and inland fishery capture operations and the natural environment together with possible socio-economic effects A similar matrix is also used to examine the potential for aquaculture development The overall effects of the planned interventions are positive in terms of both environmental and socio-economic gains but there are potentially some adverse social and economic consequences for a limited number of individuals whose livelihoods will be affected by restrictions on access to fishing or from changes in economic conditions affecting the purchase processing and marketing of fish Mitigation measures are considered subsequently in Chapter 8
Chapter 7 briefly considers the possible consequences of taking no action to deal with the declining stocks and profitability of fishing (the do-nothing option A) This is a standard part of the methodology for conducting an Environmental and Social Assessment The conclusions are compared with the alternatives of taking limited action (a lsquoweakrsquo option B) or of implementing the full set of plans and proposals (the lsquooptimumrsquo option C) The comparison includes the conclusion that the fisheries industry is often studied and dealt with in isolation from other parts of the economy However in order for the planned reforms to have maximum beneficial impact a new approach is required to integrated coastal development in which a range of ministries and agencies should be involved
Chapter 8 sets out a draft Environmental and Social Management Framework (ESMF) This picks up areas of risk identified in the ESA Report and proposes remedial action The ESMF notes that the principal goals of government policy are to
bull Improve management of fisheries the conservation of aquatic resources and protection of the natural environment
bull Promote value addition in the fisheries sector and the improvement of livelihoods in fisheries communities
bull Encourage sustainable development of aquaculture
3
bull Improve the services provided to the fisheries sector by the Fisheries Commission and supporting institutions
The Draft ESMF sets out eight specific interlinked actions namely
1) Preparation of local management plans and close surveillance of all new fishing enterprises in deep waters
2) Preparation of environmental protection clauses to be included in all contracts and agreements for physical development work
3) Regular inspection by environmental protection officers of construction work at harbours and landing sites
4) Establishment of community management plans to provide support to those groups and individuals who are adversely affected by any of the measures listed above
5) Creation of community liaison groups to actively support community development alternative livelihoods and conversion to new areas of economic activity for those Fisher families or individual fishers who are adversely impacted
6) Introduction of skills training centres and business advice for small and medium enterprise development
7) Establishment of a coastal development approach drawing on the resources of the ministry of local government agriculture and tourism (others to be added) to coordinate integrated projects and initiatives for economic development linked with the existing coastal zone management plans
8) Creation of a liaison group between the government of Ghana and its international development partners to ensure that investment in the fisheries sector is targeted in the most effective way to deliver plan objectives and avoid duplication of effort
Chapter 9 provides a draft National Process Framework (NPF)) to implement the recommended process framework laid down by the West Africa Regional Fisheries Program (WARFP) which Ghana will become part of This framework explains how eligibility criteria will be employed to determine which settlements qualify as participating communities and what the responsibilities of these communities will be in terms of setting up Co-management Committees (CMCs) and selecting classes of Project Affected People (PAPs) who will be eligible for assistance under national guidelines to be prepared by the Fisheries Commission The ESMP also outlines proposals for income restoration measures in accordance with World Bank guidance as interpreted through the West Africa Regional Fisheries process framework that where open access to fishery resources is restricted for the common good any adversely affected individuals should not be penalized but should receive assistance to restore their livelihoods at least to the extent that they are impacted by the project activities and preferably to an improved state1
1 Extract from Executive Summary Process Framework West African Regionl Fisheries Program (P106063) Cape Verde Liberia Sierra Leone Senegal Commission sous Regionale des Peche Dakar Senegal
Measures are also outlined for conflicts or grievance resolution administrative and legal procedures and monitoring arrangements
ldquoSection V Livelihood Restoration Measures World Bank policy requires that livelihoods be restored at least to the extent that they are impacted directly by project activities and preferably inproved This policy prescription is based on the principle that people who give up most for the public good ndash the PAPs- should not be penalised and impoverished as a result of their loss for the greater good The aim thereopfre is to improve the public good (in this instance marine resources) while also ensuring that those who lose access to resources and income because of restrictions on marine resources are assisted effectively to restore that part of their income that is affected through alternative livelihood measuresrdquo
4
Chapter 10 looks in more detail at specific safeguards relating to possible involuntary relocation of people as a result of the long term fisheries programme It constitutes the Resettlement Policy Framework (RPF) which while not a formal legal requirement of the World Bankrsquos lending policy is nevertheless recommended as good practice
5
PART A ENVIRONMENTAL AND SOCIAL SAFEGUARDS ASSESSMENT
The Environmental and Social Safeguard Assessment comprises bull Three background chapters (1-3) bull Two chapters which deal with assessment of the potential effects of the World Bankrsquos financial
and technical support for the Ghana Fisheries Programme over the initial five years (Chapter 4) and the longer term effects of the overall Fisheries Programme which is expected to run for 10-15 years (Chapter 5)
bull Analysis of the consequences of taking no action (the do-nothing option) in Chapter 7 and bull A draft Environmental and Social Management Framework (Chapter 8)
7
CHAPTER 1 INTRODUCTION
11 INTRODUCTION The government of Ghana is embarking on a Fisheries and Aquaculture Sector Development Plan (FASDP) for restructuring its coastal and inland fisheries The aim is to reverse the current trend whereby fish stocks are increasingly diminishing and the current rate of fishing is unsustainable resulting in less productive fisheries increased costs with declining profitability and the risk of exacerbating nutritional deficiencies and poverty within fishing communities To date the government has enacted legislation (Fisheries Act 2002) prepared policies (2008 updated in 2010) and published regulations (August 2010) but the Ministry of Food and Agriculture and the Fisheries Commission lack the capacity and financial resources to implement all of these initiatives The World Bank is therefore considering a supporting programme of technical assistance and finance which will assist with governance reforms the introduction of licensing for all vessels a reduction in the size of the industrial and semi-industrial fishing fleets and the progressive transfer of fishing activity to the canoe sector International support for Ghanas fishing industry is being coordinated under the West Africa Regional Fisheries Programme (WARFP) This initiative began with four countries Cape Verde Liberia Sierra Leone and Senegal It is now being extended to the following countries Ghana Guinea Guinea Bissau and Gambia A process framework has been developed by the Commission sous Regionale des Peche (Based in Dakar Senegal) to assist member countries of WARFP to prepare their own national process frameworks together with accompanying environmental and social safeguards assessment an environmental management plan and resettlement policy This report has been designed to provide the outline structure and contents for these documents on behalf of the Government of Ghana Another important function of the report is to review the application of the World Banks own Environmental and Social Safeguard policy to the planned investment Both the governments development plan (FASDP) and preparation of the World Banks financial assistance package are at an early stage Consequently this report covers (and can only cover) the broad principles and sets out initial conclusions It will be necessary for further reviews to be undertaken when the Government of Ghanarsquos programme has been developed in more detail Objectives of the Environmental and Social Assessment (ESA) The overall aims of planned interventions in the fisheries industry of Ghana are to improve fish stocks and increase the sustainability of fishing activity which will have long-term environmental and social benefits for the country However the process of introducing change is likely to have some short-term adverse effects on individuals and particularly those who are vulnerable or disadvantaged within poorer fishing communities unless appropriate mitigation measures are taken The purpose of the environmental and social assessment set out in chapter 6 is to identify potential environmental and social impacts both individually and cumulatively and to assess their relative magnitude duration reversibility and importance Based on these findings the draft management framework (see chapter 8) sets out proposals for avoiding or mitigating unacceptable change The process of reforming the fisheries sector will take a number of years and the existing FASDP covers only the first five years With the exception of proposals to scale down the size of the industrial and semi-industrial fishing fleets it is unlikely that major changes will take effect in terms of fishing activity during this five-year period Consequently from the standpoint of the World Banks investment there are likely to be relatively few issues in terms of potential conflict with safeguarding policies Later
8
however significant change is within the fishing industry and particularly onshore processing and marketing of fish products An important element in this report has therefore been the need to define the point at which the banksrsquo responsibilities are seen to terminate and all liabilities are transferred to other supporting donors and the government of Ghana In the short term a reduction in the industrial fleet may lead to the loss of 1000 to 3000 jobs for crew members although in practice most of this work is only part time and many of the vessels that are due to be withdrawn are no longer seaworthy In the longer term it is intended to encourage more selective fishing by limiting open and unfettered access to fish stocks eliminating illegal and damaging processes including dynamiting uncontrolled light fishing and the use of small size monofilament nets and introducing seasonal restrictions to protect breeding cycles The intention is that these measures will be managed jointly by the government and communities through co-management systems At the same time major efforts will be made to reduce the level of post-harvest losses and to increase the value of fish products The expectation is that the number of industrial semi-industrial vessels and canoes will be stabilised at a fixed lower level within five years Once this point is reached and no further licences are granted individual licences will acquire higher values especially as fish stocks recover and the size and value of fish catches starts to increase Subsequently licenses are likely to be sold and traded as less efficient owners drop out of the market and sell on to stronger individuals and companies In terms of onshore activities fish landing processing and marketing will become more efficient and losses will be reduced through use of better smokers freezing and drying equipment Previous studies in West Africa and elsewhere (Bennett et al 2001) have shown that the transition away from open access to a more regulated system of access management can give rise to social risks Specifically older men are likely to be displaced when they are no longer fit enough to withstand the rigours of fishing while a rising number of young men may find it harder to enter a career in fishing Women who currently manage or assist with all areas of buying processing and marketing using traditional clay ovens may also experience competition as new companies and enterprises are established to take advantage of higher profitability in the fishing sector perhaps using better equipment newer technologies and different logistics arrangements or their own transportation Methodology This study has followed the methodology developed within the process framework for the West Africa regional fisheries programme (WARFP) Figure 1 sets out both sequence and timescale for the work
The range of jobs at risk is based on assumptions about the number of vessels and average crew size and cannot be determined with any degree of accuracy until the necessary surveys are undertaken
9
The report is based on three major areas of activity 1 documentary analysis and utilisation of the studies already carried out by the fisheries commission 2 meetings with institutional stakeholders principally affected by the project and 3 Consultations and visits to some of the key fishing villages and communities The planned presentation of findings to Stakeholders has been postponed at the Clientrsquos request due to other pressing commitments in the agriculture and fisheries sectors This presentation will however need to be subsequently undertaken by the Ministry and the Fisheries Commission
11
CHAPTER 2 PLAN AND PROGRAMME DESCRIPTION
INTRODUCTION This chapter is divided into two parts Part 1 sets out the progress which the government Ghana is making in giving effect to the legislation policy and regulations Part 2 describes the proposed programme of assistance being offered by the World Bank with the specific aims of strengthening governance and enforcement systems (Components 1 and 2) and in promoting value addition and reduction of post-harvest losses
PART 1- THE DRAFT FISHERIES AND AQUACULTURE SECTOR DEVELOPMENT PLAN (FASDP) This plan (FASDP) covers the period 2010-2015 It recognises the importance of Ghanarsquos fisheries which generate in the order of US$ 1 billion a year contribute 45 to GDP and indirectly support the livelihoods of 22 million people However through over-fishing and lack of investment in management and value addition the average income per canoe has dropped by up to 40 over the last ten years to the point where it costs as much to fish as the catch is worth By comparison well managed fisheries in other parts of the world are capable of generating economic returns of 30-60 on investment (equivalent to a potential income of US$ 300 million a year for Ghanarsquos fisheries) The Draft FASDP acknowledges that the fishing sector is expected to make a substantial contribution towards doubling the size of the Ghanaian economy by 2015 (GPRS II) as part of the Republic of Ghana Fisheries and Aquaculture Policy Seven targets are set in the draft FASDP 1 Maintaining capture fisheries production at current levels 2amp3 Increasing revenue and profitability in capture fisheries by at least US$ 50 million a year after
five years 4 Increasing aquaculture production to 35000 tonnes a year after five years 5 Retaining Ghana as a landing and processing hub for the West Africa tuna industry 6 Developing fisheries management to allow effective control of all commercial fishing effort in
Ghanaian waters and 7 Ensuring fisheries management costs are sustainable and that the fisheries sector overall make a
fiscal contribution to Government revenues There is an underlying presumption that the canoe sector will remain at the heart of Ghanarsquos fishing industry but the plan is not prescriptive and leaves open the ways of achieving the overall goals At the same time there is an underlying assumption that the long term sustainability of Ghanarsquos fisheries will depend upon discouraging further entry by new operators
PART 2 THE WORLD BANKrsquos CONTRIBUTION TO GHANA FISHERIESPLAN (FASDP)
The essential aim of the World Bankrsquos contribution to FASDP is to provide investment which will build the necessary policy and capacity for effective fisheries management designed to reduce fishing effort while maintaining approximately the same catch levels and to address the impacts of change for fishers
12
and the communities in which they live Based on the currently available draft Project Appraisal Document (PAD) each of the components is now described in turn Component 1 - Good governance and sustainable management of the fisheries This component on good governance comprises four subcomponents which are broken down in turn into a number of separate activities Sub-component 11 developing the capacity rules procedures and practices for good governance of the fisheries Activity 111 reviewing the Fisheries Act and developing regulations to support the Sector Policy and the Fisheries and Aquaculture Sector Development Plan Activity 112 Developing an operational policy to enable implementation of the aquaculture and fisheries sector development plan Activity 11 3 strengthening fisheries management systems and capability (fisheries management plan development aquaculture implementation technical support and training) Activity 114 strengthening fisheries Information Systems (catch recording and monitoring systems statistical analysis and training)
Sub-component 12 introducing fishing rights
Activity 121 developing pilot stakeholder-based fisheries management initiatives around defined fisheries units (ie local management initiatives tighter defining fisheries resources in up to 6 selected Fisher communities) Activity 122 introducing and administering a licensing regime
Subcomponent 13 Adjusting fishing effort and capacity to more sustainable levels marine resource conservation and supporting alternative livelihood opportunities when needed Activity 131 vessel decommissioning Activity 132 compensation packages for crew of decommissioned industrialsemi-industrial vessels Activity 133 alternative livelihood development to incentivise voluntary capacity reduction in the canoe sector Activity 134 marine resources management and conservation
Subcomponent 14 social marketing communication and transparency Activity 141 communications stakeholder consultations and awareness raising programmes to support fishery development Component 2 reduction of illegal fishing Under the West Africa regional fisheries programme subcomponent 21 allows for enabling environment for reduction of illegal fishing These provisions already exist within Ghana and this subcomponent is therefore omitted Subcomponent 22 monitoring control and surveillance (MCS) systems Activity 221 developing compliant systems and capability
13
Component 3 increasing the contribution of the marine fish resources to the local economies Subcomponent 31 product diversificationvalue chain development (freshfrozen producttrade facilitation) Activity 311 landing site development Activity 312 Port development Subcomponent 32 fish product trade infrastructure information and systems - regional minimum integrated trade expansion platform (MITEP) Activity 321 export certification centre development Activity 322 fish processing technology improvements Activity 323 national fisheries advisory group Subcomponent 33 marine and inland aquaculture development Activity 331 space developing aquaculture policy and legal framework Activity 332 improving genetic policy of tilapia fingerlings and breedstock Activity 333 catalysing aquaculture development Component 4 Coordination monitoring and evaluation and program management Subcomponent 41 national implementation subcomponent 42 regional coordination Each of the components sub-components and activities are described in more detail in Chapter 5 which assesses the nature of environmental and social safeguards issues in terms of the World Bankrsquos planned investment
15
CHAPTER 3 BASELINE CONDITIONS
INTRODUCTION This chapter discusses the existing fishery resources of Ghana and describes recent environmental and social trends It identifies some of the pressures that led to the reduction in value of fishing activity and indicates the threats that could be posed if no action is taken in accordance with the planned fisheries and aquaculture program to deal with them FISHERY RESOURCES The continental and coastal waters of Ghana are potentially very rich due to a combination of warm waters and nutrients carried in ocean currents which up-well seasonally on the continental shelf The tonnage of fish caught in marine waters peaked in the mid-1990s around 500000 tonnes and currently averages around 400000 t(See Figure 1) Figure 1 Wild Capture Production in Ghana 1950-2005
2
Table31 Top 10 Species Exported (by value)
1 Canned tuna ($72000000) 2 Fresh tuna ($7200000) 3 Tilapia (no figure available) 4 Miscellaneous dried fish ($1000000) 5 Salmonids frozen ($900000) 6 Marine fish frozen ($600000) 7 Cuttlefish and squid ($600000) 8 Shrimps and prawns ($90000) 9 Sardines ($80000) 10 Crustaceans frozen ($50000) Source FAO Fishstat
The principal catch from deep waters is tuna Industrial vessels registered in Ghana target these species in international waters but also illegally in coastal waters Herring sardine and anchovies are fished in coastal waters by semi-industrial vessels and canoes Table 31 shows the top 10 species of fish exported from Ghana in 2005 PROFILE OF THE FISHING INDUSTRY Fishing is of vital importance in Ghana not only in terms of its contribution to gross domestic product (45 per annum) but because fish provides 65 of the countrys protein In recent years (between 2003-2008) and more specifically in 2004 the countryrsquos annual fish requirement has been estimated to be 882000 tonnes of which the country produces just about half (Tetteh 2007) Of the total population of 22 million people it has been estimated that between 15 and 22 million people are employed or gain their livelihoods from fishing (8-10) Of these there are 210000 men who are directly employed as
2 This figure is the Fisheries Departmentrsquos estimate for 2008
16
fishers The total export of seafood was valued US$824 billion in 2005 Ghanas fishing industry can be divided into three sections marine capture inland capture and aquaculture It can be further analysed by scale of operations distinguishing between industrial semi-industrial and artisanal sectors Marine fisheries Industrial sector Commercial fishing for tuna began in 1962 In the early 1980s Ghana sought to develop an industrial fishing fleet and there are currently 90 industrial trawlers and other vessels which are located in Tema and Takoradi Sekondi The port of Tema was expanded from 1962 to create four main areas the Inner Harbour Outer Harbour Canoe Basin and Commercial Area In 1999 fish landing facilities were improved at the Albert Bosumtwi Sam Fishing Harbour built in Sekondi This harbour is equipped with a cold store an ice-making plant offices a berthing bay for inshore vessels a jetty for canoes and a net drying area Under Ghanaian law more than 50 of the ownership of industrial vessels must be registered with a Ghanaian company or individuals However in practice many vessels are owned by foreign nationals with token Ghanaian ownership Relatively few of these large vessels regularly put to sea and a number are in poor condition or obsolete Nevertheless the impact of trawling activities by Ghanaian registered and foreign owned vessels has been very considerable in coastal waters in recent years Fish landed from industrial vessels is usually transferred directly to Canning factories in Tema and Takoradi Ghana has the largest canning industry in West Africa In the region of 30000 tonnes of tuna are landed In addition to trawling some industrial vessels are engaged in shrimping the use of tuna lines and polls purse seining and demersal trawling Semi-industrial sector in addition to deep sea trawlers there are around 230 large semi-industrial ships propelled by inboard motors which are used for trawling in shallow waters during the off-season and purse seining during upwelling seasons There are currently reported to be 48 bottom trawlers 14 pair trawlers 2 shrimpers 33 pole and line vessels and 10 tuna purse seiners operating from 2 of the 7 landing sites Canoe sector Ghanas artisanal fishing sector is based on between 10000 and 12000 wooden canoes Fifty seven per cent of the fleet is powered by outboard motors supported by paddle and occasionally sail Each Canoe carries a crew of between three and 20 men depending on size and length There are over 334 landing sites along the 550 km coast of Ghana and the majority of fish caught by canoe (180000 tonnes) is returned to these sites accounting for 70 of Ghanarsquos fish production The principal landing sites are at Teshie Jamestown Chorkor Shama Axim Elmina Winneba Mumford Akplabonya Adina Atiteti Abutiakope and more Fishing is undertaken by men but the majority of canoes are owned by women who pre-finance fishing trips (purchasing gear and premixed fuel) and purchase the catch Women also predominate in processing and marketing fish and fish products Only about 20 of fish sold fresh a further 20 is salted and the majority (60) is smoked It is estimated that up to 30 of the catch is spoilt through lack of ice for storage or alternative processing facilities
17
Inland fisheries Water Resources Ghanarsquos inland fishery resources consist of a natural lake( Lake Bosomtwe) and nine major river basins which from east to west of the country are
bull the Volta bull Densu bull Ayensu bull Ochi bull Kakum bull Pra bull Ankobra and bull the Tano
The River Tano forms the border between Ghana and Cote drsquo Ivoire The largest of the rivers is the Volta which drains more than two-thirds of the country through several large tributaries in virtually all regions of the country The Volta river system also incorporates the Volta reservoir generally known as the Volta Lake which has a surface area of around 8400 km2 The Volta lake discharges through the Akosombo dam before flowing through a delta into the Atlantic Ocean The eight other river systems are relatively smaller simpler and open more directly into the Atlantic There are also several reservoirs created on the smaller river systems mainly for potable water production irrigation and flood control These reservoirs irrespective of their primary purposes enhance availability of more permanent aquatic habitable space for fish and therefore support some fisheries Finally with all the river systems opening into the Atlantic there are a series of lagoons and estuaries which act as interfaces between the rivers and the sea These water areas constitute another type of inland water resource for salt and brackish water fishes Inland Fish resources Within the inland water resources of Ghana there are over 150 fish species more than 90 of which are fished for food
In commenting on inland fisheries in Ghana it must be noted that virtually all available information on inland fisheries is obtained from the Volta Lake No national fish production records have been kept on the fisheries of the eight smaller river systems and the lagoons and estuaries Thus the usual statement that inland fish production constitutes about 20 of what the country produces should refer to fish production from the Volta Lake In practice the total inland fish contribution could more realistically be estimated at about 30-35 of national fish production This is a very considerable but understated contribution to national food security and nutrition
Fishing vessels The dominant fishing vessel on the Volta Lake is the canoe the majority of which are built from wooden planks On some other river systems while plank canoes predominate a small number are carved as dug-outs from single tree trunks There is some variety in sizes of the canoes depending on how many planks are used to build the boat and the size of tree trunk used in building a canoe The total number of canoes estimated on the Volta Lake during a survey in 2000 was 24035 On the tributary rivers of the Volta Lake and other river systems in the country the planked canoe is the main vessel used in fishing
18
Fishing gear There are about eleven main kinds of gear used for fishing on the Volta Lake They are Gill Nets Cast Nets Hook and Line Basket and wire mesh traps Winch net Beach seine Bamboo Nifa-nifa Wangara Spears and Atidzas On other rivers in the country Gill nets Cast nets Hook and Line and traps are the fishing gear used On both the lake and rivers the Gill net is the main gear
People Involved In the 2000 frame survey of the Volta Lake conducted by the Fisheries Directorate of Ghana the estimate of fishers on the Volta Lake was put at 71861 Fishers on the lake work in collaboration with a host of fishmongers or handlers who also function as wholesalers for individual fishing groups Assuming that the fisher population on the lake has increased by a modest 3 in the ten years from 1998 to 2010 a fisher population of about 93500 could be considered to be on the Volta Lake now If again it is estimated that number of fishers on rivers in the country were to be a tenth of those on the lake this would put the fisher population on inland waters (apart from the Volta Lake) at about 9350 fishers A very conservative estimate therefore puts the total number of individuals who are directly engaged in inland fishing at over 100000 This excludes all directly associated groups such as fish handlers processors and traders An estimate of secondary fisheries operators such as boat builders out-board motor operators and mechanics as well as bulk salt and fuel wood sellers and those engaged in buying selling and distributing fish would have to be considered in developing estimates for both direct and indirect employment in inland fisheries but the number can be assumed to lie between 125000 and 150000 people
Aquaculture Under Ghanarsquos legal framework aquaculture is defined as ldquoany activity designed to cultivate or farm fish and other aquatic living resourcesrdquo Currently only fin fishes are involved in aquaculture in Ghana
Current culture media and environment Currently fish culture takes place almost exclusively in fresh water in Ghana either in cages brush parks or dugouts Dug-outs are excavations made in floodplains in the savannah parts of the country were water scarcity has been a major hindrance to development in general and food security in particular Dug-outs get filled with flood waters and whatever the water carries during major wet periods of a year in the savannah areas Waters that fill Dug-outs invariably contain fish which are trapped in the Dug-out after the wet period These water bodies are managed until the end of the dry period and the fish are harvested before the next flood period Since the 1960rsquos various strategies to augment fish production from Dug-outs have been developed and tested These involve adding fingerlings of selected fish species to those which are lsquonaturally stockedrsquo in Dug-outs by floods Dug-outs are the major fish culture production approach in the savannah parts of the country which accounts for a little more than half the area of the country The Environment of fish culture Currently fish culture is taking place mainly in freshwater environments Brackish water fish culture and mari-culture activities which will bring lagoons estuaries and the sea into fish culture production have long term potential for development Fishes in culture Fishes being cultivated in Ghana In order of importance are Nile tilapia Oreochromis niloticus the African catfish Clarias gariepinus species of the catfish Heterobranchus and the Bony tongue Heterotis niloticus Scale of Culture Based on level of production fish culture operations can be categorized as follows
bull Large scale commercial where an enterprise produces up to 10000 tonnes per year
19
bull Medium scale commercial where a single enterprise produces between 50 and 500 tonnes bull Small scale commercial where an enterprise produces between one and 20 tonnes and bull Very small scale commercial with productions below 20 tonnes
Fish culture production Cultured fish contribution to national production was officially stated as 9000 tonnes for the year 2009 However informed opinion amongst fish farmers indicates that a figure of between 16000 and 20000 tonnes in 2010 would be closer to reality This statement is based on the facts that most producersrsquo published figures are underestimates several small to medium scale producers are not recorded in official lists and the recording of newly established fish farms has lagged actual establishment especially since 2009 Although cultured production up till 2009 may not have been significant considering a shortfall of about 460000 mt (as recorded in 2004) between captured fish production and national demand this reflected the fact that there were only two large scale commercial producers in the country each of which had had less than ten years of operation Anticipated growth in fish culture production within the next five years is expected to be dramatic as some of the critical challenges of the industry are resolved
CHALLENGES AND PROSPECTS Marine Fisheries The fishing sector is vital for food security and job creation to help alleviate rural poverty in Ghana However the levels of fisheries harvests are generally considered to be close to or to have exceeded the maximum sustained yield Future sustainability in the industry will depend upon the restriction of open access to fisheries and the introduction of management systems which allow fish stocks to recover and the establishment of consistent yields in both marine and inland waters Inland Fisheries Environmental conditions on the Volta Lake constitute the major environmental and social challenges for fisheries its sustainability and profitability In terms of future prospects success will depend heavily on implementation of the lsquoGhana Fisheries and Aquaculture Sector Development Planrsquo and the capacity of the system in Ghana to enforce the Fisheries Regulations passed by parliament in August 2010 Aspects of the Development plan that offers great prospects for the lakes fisheries include the provisions for eventually licensing boats (although the scale of this task should not be underestimated) and measures to involve communities in management of fisheries resources of the Lake
Aquaculture The main challenges facing aquaculture development in Ghana relate to bull The high cost of fish feed (significantly due to its importation from other countries) bull None availability of commercial fish hatcheries as enterprises bull Lack of a nation-wide distribution network for fish seed and cultured fish producers Most
sources of fingerlings are concentrated in one part of the country and since farms all over Ghana obtain their fingerlings individually transportation costs add significantly to overall production costs
bull Now emerging certification and monitoring to check the health and safety of aquaculture processes and products
bull The absence of adequate regulations regarding establishment of an aquaculture enterprise until August 2010 (In the absence of regulations only the large and medium scale commercial farms worked towards conforming to international performance Standards and operational regulations for certification of farms and their products still remain in a draft state)
bull Low national support for research to support expansion and systematic development of aquaculture
20
The prospects for development of aquaculture as an industry in Ghana are good since a number of practical policy and legal frameworks have been put in place to resolve the basic challenges to the industry listed above These include
bull Construction of the first local fish feed plant by an international fish feed company with the expectation of having initial products on the Ghanaian market during 2011
bull A lsquoLarge scale commercial fish farmrsquo with great capacity for fingerling production is shifting emphasis to fish seed production And several localized fish seed producers are expanding operations
bull Distribution strategies by cultured fish producers have started to emerge on a limited scale and are expected to evolve with increasing production as existing commercial farms expand and new ones join in
Now that regulations regarding establishment of aquaculture enterprises have been gazetted there is likely to be a positive response amongst fish farmers of all size categories New operational standards are being prepared which will introduce minimum standards for local certification This should set the stage for preparation of fish culture products and the broadening of choice for consumers while also qualifying Ghanaian producers to enter external markets
ENVIRONMENTAL CONDITIONS The coastal and marine environment a critical zone of influence for this study comprises a 550 km coastline a coastal belt ranging from 1 to 20 km in width and coastal waters extending to 200 nautical mile limit which was established in 1977(under the territorial waters and continental shelf act 1973 as amended by the territorial waters and continental shelf amendment decree 1977) The Coastal Belt The coastal belt accounts for only 65 of the land mass of Ghana but it is one of the most densely settled areas accounting for 25 of the population and80 of the industrial establishments in Ghana Historically the coastal zone was cultivated for coconut (copra) but this industry is in decline Vegetables and other agricultural produce are grown on better soils but the principal economic activities are fishing transportation salt production and sand and stone winning Tourism also offers great potential There is considerable expectation that the discovery of offshore oil and gas deposits will bring new wealth to parts of the coastal corridor However present plans to transfer crude products to tankers at sea and then export them directly will limit industrial activity to a support role A high percentage of industrial and municipal wastes is dumped at landfill sites within the coastal zone which creates pollution risks The coastal belt is generally a low-lying area less than 200 m above sea level Vegetation types reflect the rainfall gradient and consist of coastal shrub and Savannah to Winneba southern marginal forest to the east of Sekondi dry semi-deciduous and moist semi-deciduous forest to the east of Cape Three Points estuary and wet evergreen forest in the extreme south Soils are variable within this area ranging from fertile pockets river valleys to Sandy poorer quality soils close to the sea The Coast The coast line divides into three sections (Ly 1980)
bull West of Cape Three Points this area has a wide and flat beaches backed by coastal lagoons and
21
wave heights are generally low bull Between Cape three points and Tema the coast consists of a series of rock headlands enclosing
shallow bays together with sandbars or spits enclosing coastal lagoons The surf zone is a medium to high energy environment with wave heights often exceeding 1 m South-westerly prevailing winds give rise to longshore drift in an easterly direction
bull Between Tema and Aflao most of the shore is sandy although there are rocky outlets The coastal zone is important internationally in providing feeding roosting and nesting sites for thousands of migratory birds Environmental degradation is significant in Ghana and is recognized in the countryrsquos environmental action plan It contributes to rising poverty levels coupled with poor human health and inadequately planned urbanization which fuel a vicious cycle inhibiting human development The core issues include
bull Domestic sanitation bull Increased urbanization without appropriate infrastructure bull Wetlands and mangrove degradation bull Coastal erosion and bull General biodiversity loss
Briefly each of the above could directly or indirectly adversely influence fisheries and aquaculture separately or together For example in a recently completed study of water quality scenarios of the Volta Lake in relation to fish production as a component of a comprehensive study (The Challenge Program Project of Water amp Food) it was concluded among others that poor sanitation in highly populated fisheries communities adversely influenced water quality to the detriment of fish life and thus fish production With reference to aquaculture the same unsanitary conditions in highly populated shore communities adversely influenced water quality especially in terms of oxygen depletion when lake waters extend to the shore in high water periods This is a situation which has caused fish kills in cages because caged fish cannot escape lsquopollutedrsquo waters Degradation of wetlands and mangroves leads directly to a reduction in their capacities as spawning and nursery zones for both marine and inland water fishes which reduce fish production in both environments The situation outlined above is often contributed to by anthropogenic and industrial pollution due to urbanization without appropriate infrastructure Another issue linking human activity to a deteriorating environment is demonstrated by the encroachment of aquatic weeds on inland waters such as the Volta Lake Weed growth is accelerated by farming reservoir catchments which increases nutrient levels and the building of dams which reduce or cut off intrusion of sea water into rivers Currently as climatic change observable impacts such as floods seem to escape predictions The project could possibly contribute to mitigating against direct and indirect effects of climate change on fishing and aquaculture through investment into climate change orientation and education of fishers and fish farmers to mainly influence reasonable precautions they take Marine waters The continental shelf is relatively narrow projecting out to 25-35 km except in the area of Cape Coast to Salt Pond where it extends to almost 80 kms Sandy and rocky substrates which previously supported coral and seaweeds have been severely affected by former trawling activity which indiscriminately
22
dredges material from the seabed Coastal waters are enriched by freshwater discharges from the relatively small number of rivers and by two seasonal up-wellings which occur between late June and early October (the main upwelling) and January and March (the minor upwelling) The origin and driving mechanisms of these up-wellings are not fully understood and both their location and strength varies from year to year
Lake Volta and other inland water
Major environmental issues on the Volta Lake which might also be considered as challenges to sustainable fisheries on the major inland fisheries resource can be summarised as follows
bull The Volta Lake is known to be low in nutrients It therefore has low standing crops of phytoplankton and zoo plankton to support high fish production
bull The northern segment of the lake together with tributary rivers constitute the spawning and feeding grounds for majority of fish species in the lake during the wet season however these segments are intensely fished during the same period
bull The Volta Lake is divided into eight unequal strata with different distribution of boats per Km2 At the last estimation of carrying capacity in 2000 stratum V and II had the highest (527) and lowest(157) number of boatsKm2 respectively
bull The rate of siltation in the lake is considered to be increasing due to erosion associated with high rates of deforestation
bull A major challenge exists in getting fishers fishing communities and fishing entrepreneurs to understand and comply with fishing regulations aimed at conserving fish and fisheries resources
bull There is a lack of resources studies and research to support fisheries management of the Lake
bull High illiteracy exists amongst lake shore communities
bull Open access to the fish resources of the Lake has been in operation since its formation
bull Declining fish yields are occurring in the lake (468 Kgha in 1976 to 320 Kgha in 2003-MOFA) brought about by the constraints listed above
bull The commonly assumed estimate of potential fish production from the lake of around 75500 mtyr) is considered to be a serious underestimate since Stratum VII alone was estimated to produce 33800mtyr in 1996
bull The policy environment for aquaculture is currently strongly supportive of the industry and related enterprises
bull There is good quality and more than sufficient water to allow some kind of aquaculture to be developed in every region of the country with the Volta lake (about 8400 Km2) as the single most important water unit for fish culture Currently it appears that the free access to the fish resources of the lake has to some extent been applied to establishment of small scale caged fish culture enterprises a situation constituting environmental risk to investments of large scale commercial fish culture establishments in the lake
bull The Volta Lake is low in nutrients (Obeng 1964) resulting in a situation where higher fish yields could be sustained if greater quantities of fish feed were available
23
bull In Ghana the Nile tilapia O niloticus occurred naturally only in the Volta system Due to positive culture characteristics of the fish it has been moved into virtually all other river basins in the country The situation provides opportunities for hybridization of the Nile tilapia with other tilapia species native to the river basin into which the Nile tilapia has been moved
25
CHAPTER 4 POLICY AND LEGAL FRAMEWORK FOR ENVIRONMENTAL AND SOCIAL ISSUES
41 INTRODUCTION
Development and implementation of the Ghana Fisheries and Aquaculture Sector Development Plan and the World Bankrsquos supporting program need to be developed with full regard to existing international conventions national legislation policies and regulations This chapter highlights the main legislative and policy considerations for the protection of the environment natural resources fisheries and social and economic development It begins with reference to the World Bankrsquos safeguard framework and those of other donors This is followed by a section on the governance framework in Ghana
42 WORLD BANK AND OTHER DONORSrsquo SAFEGUARDS POLICIES
The World Bankrsquos safeguard policies exist to ensure that all projects which it finances are developed and implemented on environmentally and socially sound principles A range of different policies exist and these have been carefully considered to ensure that the Ghana Fisheries and Aquaculture Development Sector Development Plan complies with these safeguards All policies have been screened and those that have no bearing on the fisheries programme have been excluded from Table 41 below Table 41 lists policies which could have some applicability to the FASDP even if this interaction might be very slight It is important to stress that the comments in the third column of Table 41 relate to the entirety of the Fisheries and Aquaculture Sector Development Plan whose effects will continue to be experienced long after the World Bankrsquos financial support has been expended Most of the activities in the FASDP will have no effect in relation to safeguard objectives and where there are implications these are likely to occur at precise locations (for example at fish landing sites) rather than throughout the industry Where potential interactions have been noted the necessary mitigating measures are incorporated in the Draft Process Framework
Table 41 World Bank Safeguard Policies in Context
Safeguard Policy
Safeguard Policy Objective Brief Description and relevance to FASDP
OP 401 Environmental Assessment
This policy aims to ensure that Bank-financed projects are environmentally sound and sustainable and that the decision-making process is improved through appropriate analysis of actions and mitigation of their likely environmental impacts This policy is triggered if a project is likely to carry potentially adverse environmental risks and impacts on its area of influence OP 401 covers impacts on the natural environment (air water and land)
The majority of actions planned under FASDP will be beneficial to the marine environment and to inland waters However new construction activities could have impacts and depending on the project and the nature of impacts a range of instruments can be used to ameliorate and mitigate adverse effects while enhancing beneficial effects These include EIA environmental audit risk assessment and environmental management plans (EMP) The need for EIA and EMP is considered in this report
26
OP 404 Natural Habitats
This policy recognizes that conservation of natural habitats is essential to safeguard their unique biodiversity and to maintain environmental services and goods for human society and for long-term sustainable development The Bank therefore supports the protection management and restoration of natural habitats in its project financing as well as policy dialogue and economic and sectoral work Natural habitats comprise many types of terrestrial freshwater coastal and marine ecosystems They include areas lightly modified by human activities but retaining their ecological functions and most native species
This policy is triggered by any project (including any sub-project under a sector investment or financial intermediary) with the potential to cause significant conversion (loss) or degradation of natural habitats whether directly (through construction) or indirectly (through human activities induced by the project) This policy is applicable to the Ghana Fisheries Programme because the project focuses on the integrated management of natural habitats However by screening all proposals under the ESMF any sub-projects that might impact these habitats will not be funded
OP 409 Pest Management
The objective of this project is to (i) promote the use of biological or environmental control and reduce reliance on synthetic chemical pesticides and (ii) strengthen the capacity of the countryrsquos regulatory framework and institutions to promote and support safe effective and environmentally sound pest management
The policy is triggered if (i) procurement of pesticides or pesticide application equipment is envisaged either directly through the project or indirectly through on-lending co-financing or government counterpart funding (ii) the project supports an activity requiring the use of pesticides that may have negative effects on the environment The only instance in which this policy might be triggered by the Ghana Fisheries Programme is if aquatic herbicides or antibiotics were to be used in connection with aquaculture This is most unlikely but can be monitored through the implementation programme
OP 411 Physical Cultural Resources
The policy objective is to assist countries in avoiding or mitigating adverse impacts of development projects on physical cultural resources For the purposes of this policy ldquophysical cultural resourcesrdquo are defined as movable or immovable objects sites structures groups of structures natural features and landscapes that have
Under the Ghana Fisheries Programme construction and rehabilitation activities that could have negative impacts on cultural property will be avoided In the case of discovery of remains national procedures will be applied
27
archaeological paleontological historical architectural religious aesthetic or other cultural significance
OP 412 Involuntary Resettlement
The objective of this policy is to (i) avoid or minimize involuntary resettlement where feasible while exploring all viable alternative project designs (ii) to assist displaced persons in raising their former living standards income-earning capacity and production levels or at least in restoring them (iii) encourage community participation in planning and implementing resettlement and (iv) provide assistance to affected people regardless of the legality of land tenure
The policy covers not only physical relocation but any loss of land or other assets resulting in (i) relocation or loss of shelter (ii) loss of assets or access to assets (iii) loss of income sources or means of livelihood whether or not the affected people must move to another location The activities of the Ghana Fisheries Programme are likely to result in loss of assets or access to assets and loss of income sources or means of livelihood for some groups and individuals The potential for such losses will be carefully scrutinised and compensated for through the National Process Framework and Resettlement Policy Framework described in this report and appropriate procedures will be followed where necessary
Other donors and aid agencies including International and National NGOs play an active role within the fisheries sector in Ghana and their safeguards standards will be observed through operation of the Environmental and Social Safeguards Management Plan
28
43 THE GOVERNANCE FRAMEWORK IN GHANA
The Ministry of Food and Agriculture (MOFA) Preparation of Fisheries laws and policies fall under the responsibilities of the Minister of Food and Agriculture who in turn delegates functions including implementation to a semi-autonomous body the Fisheries Commission
The Fisheries Commission (FC) was established under the Fisheries Commission Act (625 2002) It oversees management regulation and utilisation of the fisheries resources of Ghana drawing on powers set out in the Fisheries Law (PNDC 256 1991) Fisheries Act 625 provided for the establishment of a more robust Fisheries Commission (FC) which is an amalgamation of the erstwhile FC and Department of Fisheries
Ten individuals constitute the Board which is led by a chairman (appointed by the President of Ghana in consultation with the Council of State) supported by three members drawn from the ministries of transport defence and environment There are three representatives from the following parastatal organizations - the Ghana Marine Fishing Officers Association Water Research Institute and Ghana Irrigation Development Authority- and two representatives (one from the artisanal and one from the industrial sections )of the National Fisheries Association of Ghana Finally the tenth member is a person with requisite knowledge of the fishing industry or natural resources renewal management
The day to day work of the Fisheries Commission is undertaken by the Department of Fisheries (DOF) which serves as the implementation secretariat of the Fisheries Commission as stipulated by the Fisheries Act 625 of 2002 Specific tasks that are undertaken by the Department of Fisheries include
bull preparing fishery resource management plans bull developing regulations for the fishing industry bull organizing monitoring surveillance and enforcement for the national fishery resources and
ensuring compliance with national fisheries law and institutionalizing co-management concepts
The MCS Division of the DoF (established under the Fisheries Sub sector Capacity Building project) works in conjunction with the Ghana Navy and undertakes sea patrols to exclude industrial fishing vessels from the 30-metre depth IEZ reserved for artisanal fisheries The MCS also conducts inspection of industrial vessels at the fishing ports of Tema and Takoradi for
bull valid fishing licences bull legality of fishing gear bull skipperrsquos certificate bull log book and crew composition
The MCS undertakes similar functions for inland fisheries on Lake Volta
The Ministry of Local Government and Rural Development (MLGRD) is responsible for managing fishers fish processors and fishery resources at district and sub-district levels which it undertakes through the District Assemblies In 2002 the District Assemblies in collaboration with DoF were mandated to facilitate fishery resource management by
bull helping to form and sustain Community Based Fisheries Management Committees (CBFMCs) bull cooperating with the DoF MCS units bull providing legal and financial support to the CBFMCs and bull approving levies proposed by the CBFMCs
29
Community-Based Fisheries Management Committees are charged with the responsibility of enforcing national fisheries laws at community level as well as initiating and enforcing their own by-laws
44 THE LEGAL FRAMEWORK
441 International Conventions
Ghana has ratified a number of international conventions and treaties which have an important bearing on the state of its marine and inland waters and the condition of the fisheries These are listed in Box 1 below
Box 1 International Conventions treaties and agreements to which Ghana is a signatory 1 International Convention for the Prevention of Pollution of the sea by Oil 21 October 1962 2 Convention on the Africa Migratory Locust 25 May 1962 3 Treaty Banning Nuclear Weapon Tests in the Atmosphere in Outer Space and Under Water 5th August 1963 4 International Convention for the Conservation of Atlantic Tunas 4 May 1966 5 Africa Convention on the Conservation of Nature and Natural Resources 15 September 1968 6 International Convention on Civil Liability for Oil Pollution Damage 29 November 1969 7 International Convention Relating to Intervention on the High Seas in Cases of Oil Pollution Causalities 8 Convention on Wetlands of International Importance Especially as Waterfowl Habitats 2 February 1971 9 Treaty and Prohibition of the Emplacement of Nuclear Weapons of Mass Destruction on the Seabed and the Ocean Floor and in the Subsoil Thereof 11 January 1971 10 International Convention on the Establishment of an International Fund for Compensation of Oil Pollution Damage 18th December 1971 11 Convention Concerning the Protection of World Cultural and Natural Heritage 16 November 1972 12 Convention on International Trade on Endangered Species of Wild Fauna and For a 3 March 1973 13 Convention on the Military or Any other Hostile Use of the Environmental Modification Techniques 10 December 1976 14 Convention on the Conservation of Migratory Species of Wild Animals 23 June 1979 15 Convention for the Cooperation in the Protection and Development of the Marine and Coastal Environment of the West and Central African Region1981(Abidjan Convention) 16 United Nation Convention on the Law of the Sea 10 December 1982 17 Montreal Protocol on Substances that Deplete the Ozone Layer 24 July 1989 18 Convention to Combat Drought and Desertification 19 Framework Convention on Climate Change June 1992 20 Convention on Biological Diversity1992 442 Environmental-Related Conventions Environmentally related conventions ratified by Ghana include
bull International Convention for the Prevention of Pollution of the sea by Oil 21 October 1962
bull Convention on the Africa Migratory Locust 25 May 1962 Treaty Banning Nuclear Weapon Tests in the Atmosphere in Outer Space and Under Water 5th August 1963
bull International Convention for the Conservation of Atlantic Tunas 4 May 1966 bull Africa Convention on the Conservation of Nature and Natural Resources 15 September 1968 bull 992256International Convention on Civil Liability for Oil Pollution Damage 29 November
1969 bull International Convention Relating to Intervention on the High Seas in Cases of Oil
30
Pollution Causalities bull Convention on Wetlands of International Importance Especially as Waterfowl Habitats
2 February 1971 bull Treaty and Prohibition of the Emplacement of Nuclear Weapons of Mass Destruction
on the Seabed and the Ocean Floor and in the Subsoil Thereof 11 January 1971 bull International Convention on the Establishment of an International Fund for
Compensation of Oil Pollution Damage 18th December 1971 bull Convention Concerning the Protection of World Cultural and Natural Heritage 16
November 1972 bull Convention on International Trade on Endangered Species of Wild Fauna and For a 3
March 1973 bull Convention on the Military or Any other Hostile Use of the Environmental
Modification Techniques 10 December 1976 bull Convention on the Conservation of Migratory Species of Wild Animals 23 June 1979 bull Convention for the Cooperation in the Protection and Development of the Marine and
Coastal Environment of the West and Central African Region1981(Abidjan Convention)
bull United Nation Convention on the Law of the Sea 10 December 1982 bull Montreal Protocol on Substances that Deplete the Ozone Layer 24 July 1989 bull Convention to Combat Drought and Desertification bull Framework Convention on Climate Change June 1992 bull Convention on Biological Diversity1992
443 National Legislation
The principal national legislation that affects fisheries in Ghana is listed below
1 Fisheries Regulation 1984 LI 1294 2 Fisheries (Amendment) Regulation 1977 3 Maritime Zones (Delimitation) Law 1986 4 PNDC Law 256 of 1991 5 Fisheries Commission Act of 1993 and 6 Fisheries Act 625 of 2002 7 Fisheries Regulations passed in 2010 LI 1968
Other laws that have relevance to the fisheries sector include
1 Wild Animals Preservation Act 1961 (Act 43) 2 Volta River Development Act 1961 (Act 46) 3 Ghana Water and Sewerage Corporation Act 1965 (Act 310) 4 Oil in Navigable Waters Act 1964 (Act 235) 5 Irrigation Development Authority Decree 1977 (SMCD 85) 6 Minerals and Mining Law 1986 (PNDCL 153) 7 Environmental Protection Agency Act 1994 (Act 490) 8 Ghana Highway Authority Act 1997 (Act 540) 9 Timber Resources Management Act 1998 (Act 547) and 10 Minerals and Mining Act 2006 (Act 703
31
434 Policies A number of Environmental related Policies exist in Ghana however there is no specific policy on the coastal zone These include
bull The National Environment Policy bull National Wetlands Policy bull Agricultural Policy bull Tourism Development Policy bull Land Management Policy bull National Health Policy bull Energy Policy bull Minerals Policy bull Wildlife Conservation Policy
The main thrust and orientation of national policies on the protection management and development of the marine and coastal environment focuses on the following three major areas
bull Integrated coastal zone management and sustainable development bull Marine environmental protection both from land-based activities and from sea-based
activities and bull Sustainable use and conservation of marine living resources (both of the high seas and
under national jurisdiction) Specific plans have been developed to ensure the realization of prudent management of the marine and coastal environment These include
bull Coastal Zone Management Indicative Plan 1990 bull National Environmental Action Plan 1994 bull Draft Integrated Coastal Zone Plan 1998 bull Coastal Zone Profile of Ghana 1998 bull National Oil Spill Contingency Plan with specific reference to the marine environment
2002 bull Environmental sensitivity map of the coastal areas of Ghana 1999 and 2004
Despite the existence of these plans active integration and coordination has been lacking in practice at local level 434 Regulations Though several legislations exist on coastal protection and sustainable development there is no omnibus legislation on the environment Legislation relating to the area include the following
bull Beaches Obstruction Ordinance 1897 (Cap 240) bull The Mineral and Mining Law 1986 (PNDC 153) bull Rivers Ordinance 1903 (Cap 226) bull Land Planning and Soil Conservation Ordinance No 32 of 1953 as Amended by the bull Land Planning and Soil Conservation (Amendment) Act 1957 (No 35 of 1957) bull Maritime Zones (Delimitation) Law 1986 (PNDCL 159) urban planning and
32
bull development bull Town and Country Planning Ordinance (Cap 84) bull Wild Animals Preservation Act Act 235 1964 bull The Towns Ordinance (Cap 86) bull National Building Regulations 1996 (LI 1630) bull Volta River Development Act 1961 bull Fisheries Act 2002 Act 625 bull Fisheries Law 1991 (PNDC 256) bull Fisheries (Amended) Regulations 1977 and 1984
The sustainable use and conservation of marine resources is encouraged through legislation regulations education and awareness creation programmes as well as the enforcement of existing regulations and legislation The legal framework for coastal zones issues and management in the country are contained in the following documents
bull The 1992 constitution bull EPA Act 1994 (Act 490) bull Environmental Assessment Regulations 1999 (LI 1652) bull Local Government Act 1993 (Act 462) bull Environmental Standards and Guidelines bull
In addition there are other specific legal frameworks which include a) The legal framework for Ecosystem Protection which are
bull Wild Animals Preservation Act 1961 (Act 43) bull Wildlife Conservation Regulations 1971 (LI685) bull Wild Reserves Regulations 1971 (LI 740) bull The Wetland Management (Ramsar sites) Regulation 1999 bull Oil in Navigable Waters Act 1964 (Act 235)
b) The legal framework for Fisheries Resources which are bull Fisheries Law 1971 (PNDCL 256) bull Fisheries Act 2000
c) The legal framework for Oil and Gas Industry bull Petroleum (Exploration and production) Law 1984 (PNDCL 84) bull Mineral (Offshore) Regulations 1963 (LI 257) bull Mineral (Oil and Gas) Regulations 1963 (LI 256) bull Oil and Mining Regulations 1957 (LI 221)
d) The legal framework for Tourism Promotion (including coastal tourism) bull Ghana investment Promotion Centre Act 1994 (Act 478) bull Companies Code 1963 (Act 179) bull Free Zone Act 1995 (Act 504) bull Ghana Tourism Board bull Ghana Commission on Culture
44 ACTIVITIES RELATING TO FISHERIES INTERESTS
33
Over the years several activities have been undertaken which are of relevance to protection of the marine environment and fisheries These include
bull Ghana Environmental Resource Management Project in Coastal Wetlands Management Component
bull Gulf of Guinea Large Marine Ecosystem Project bull Fisheries Sub-sector Capacity Building Project bull Establishment of a Protected Wetland Ecosystem on the coast bull Development and Implementation of Oil Spill Contingency Plan bull Monitoring of fish stock levels and associated oceanographic parameters bull Institution of a programme of Monitoring Compliance and Surveillance of the marine
environment bull Development of industrial pollution standards bull Development of University course on Coastal Zone Management bull Increased public education on sound coastal and marine environmental practices
45 RELEVANT INSTITUTIONS With regards to protection management and development of the marine and coastal environment a number of ministries and agencies have been identified as potential stakeholders Those shown with an asterisk are likely to have a particularly active role
bull Ministry of Environment and Science bull The Environmental Protection Agency bull Ministry of Tourism bull Ministry of Local Government and Rural Development bull Ministry of Ports bull District Assemblies bull Ghana Ports and Harbours Authority bull Hydrological Services Department bull Ministry of Food and Agriculture bull Ghana Tourist Board bull Ghana Investment Promotion Centre bull Fisheries Commission Ministry of trade Industries and PSI bull Ministry of Lands and Natural Resources Forestry and Mines bull Ministry of Energy bull Ministry of Health bull Ministry of Education Youth and Sports bull Ministry of Defence bull Ghana Navy bull Ministry of Works and Housing bull Ministry of Women and Childrenrsquos Affairs bull Ministry of Roads and Transport bull National Development Planning Commission bull Council for Scientific and Industrial Research bull Universities and Research Institutions bull Ghana Meteorological Agency bull Town and Country Planning Department bull Water Resources Commission
34
bull Ghana National Petroleum Corporation bull Volta River Authority bull Geological Survey Department bull Forestry Commission (Forestry and Wildlife Division) bull Traditional Rulers and their analogous ministry and laws
Non-Governmental Organisations including Resource Development amp Environmental Oriented Development Organisation
bull Friends of the Earth bull Green Earth bull Wildlife Society bull Recerca e Cooperazione bull Centre for African Wetlands bull And many others
46 PARTNERSHIPS Few formal partnerships exist However support for coastal conservation activities has been received from the private sector as well as from Government Regional and sub-regional collaboration efforts occur at various levels although the level of practical intervention is sometimes limited The science and technology unit of ECOWAS is engaged on issues relating to the management of the Gulf of Guinea In addition a bilateral arrangement exists between Ghana and Cote drsquoIvoire for the management of and datasharing on Sardinella stocks which migrate between the two countries The NEPAD framework among the coastal states of Africa is also developing an interest in marine and coastal management 461 Technical and financial support Ghana receives technical support in the form of training research and project implementation from national bilateral and multi-lateral sources Financing of activities in the sector is primarily supported from the national budget However donor support from both bilateral and multilateral sources has also been obtained for specific programmes such as the World Bank sponsored Fisheries Sub-sector Capacity Building Project UNOPS sponsored Environmental Sensitivity Map for Coastal Areas The Ghana Coastal Wetland Project of the World Bank UNEPrsquos WACAF Programmes and The Darwin Marine Biodiversity of West Africa Project by DFID implemented by the University of Ghana 47 ACTIVITIES Activities undertaken in the country with importance to the marine and coastal area are outlined in the following sections 471 Environment-related activities
bull Ecological Baseline studies of Korle Lagoon (1990-2000) This was carried out to satisfy EIA requirement and as a result pollution status of the lagoon was established
bull Lower Volta Mangrove Project (1996-1998) The objective is to ensure sustainable management of mangrove stands and as such baseline information was documented
bull Save the Seashore Birds Project (1985-1995) This was to protect the seashore birds and as a result conservation awareness of seashore birds was achieved
bull Ghana coastal wetlands management project (1996-1999) In this management of the five coastal wetlands designated as Ramsar Site was put in place
bull Darwin Marine Biodiversity of West Africa Project It is a training project in marine biodiversity assessment
35
472 Social-related activities bull A considerable amount of attention is currently being given to the potential impact of oil-related
development in coastal regions following the publication of Environmental and Social Impact Assessments and Management Plans relating to the Jubilee Oil Field discoveries
473 Coastal area management bull Climate and vulnerability and adaptation assessment on water resources agriculture and the
coastal zone Projects (1997-1999) The projects assessed the vulnerability of the coastal zone to climate change
bull Coastal area management plan for Princess Town (1998-2000) which aimed at providing a plan for the management of Princess Town
bull Keta Sea Defence Project Work (2000-2004) The project aimed at protecting the Keta and its environs from the episodes of erosion faced in the area and also to ensure improvement in environmental and socio-economic conditions at Keta and its immediate surroundings
474 Regional Programmes bull Gulf of Guinea Large Marine Ecosystems Project (1996-1999) The project developed an
effective approach to prevent and control pollution in the Gulf of Guinea and conserve its biodiversity As a result regional institutional capacities were strengthened and also a coastal zone management profile and plans produced
bull UNEP WACAF Projects 1 amp 2 This aims at institutionalising and coordination of national contingency plans monitoring of pollution in the marine environment and control of coastal erosion
475 Other major programmes Other recent programmes and activities in the marine and coastal environments have included
bull Ghana Environmental Resources Management Project in Coastal Wetlands bull Fisheries sub-sector Capacity Building Project bull Establishment of a Protected Wetland Ecosystem on the coast bull Development and Implementation of Oil Spill Contingency Plan bull
48 ONGOING PROJECTS Ghana is currently implementing several projects in the marine and coastal area Some of these projects are linked to developmental projects for which impact assessments are required under the Environmental Assessment Regulations of 1999 Some of the projects are large scale in nature with extensive baseline and monitoring studies like the Keta Sea Defence Project and the West Africa Gas Pipeline project Others are projects being implemented under the auspices of the United Nations agencies and non-governmental organisations include
bull Combating Living Resource Depletion and Coastal Area Degradation in the Guinea Current LME through Ecosystem-based Regional Actions
bull Amansuri Conservation and Integrated Development Project (ACID) bull Danida Water and Sanitation Sector Programme II Support to Integrated Water Resources
Management (IWRM) Component (2004-2008)The Densu Basin aspect of the IWRM component
bull Reduction of Environmental Impact from coastal tourism
bull Bui Hydro Power Project
bull Sea Defence Project at Atorkor
bull Sea Defence Projects in selected towns in the Western Region of Ghana
36
49 CONCLUDING REMARKS
This chapter has highlighted the wide range of conventions laws policies regulations and activities affecting the inland and coastal regions and inland freshwater and marine environment of Ghana It will be important to keep all of these processes and procedures under review as the Fisheries and Aquaculture Sector Development Plan is taken forward to the implementation stage
The main responsibility for ensuring delivery of the Fisheries and Aquaculture Sector Development Programme will rest with the Fisheries Department of the Ministry of Food and Agriculture and the Fisheries Commission supported by the MCS Division and Ghana Navy However a key part of the programme is the development of local co-management arrangements and the Ministry of Local Government and Rural Development and individual District Assemblies will play a key role in helping to form and sustain Community Based Fisheries Management Committees
Over time a significant number of fishermen and individual fish processors are likely to leave the sector as harvesting landing and processing of the catch becomes more efficient Management of these changes especially where disadvantaged and vulnerable sections of the community are affected will need substantial support and investment and a high degree of coordination amongst government ministries and agencies NGOs and international partners to ensure that development assistance is effectively targeted
37
CHAPTER 5 WORLD BANK SAFEGUARD ISSUES
51 INTRODUCTION
The World Bankrsquos proposed funding support to the Government of Ghana covers an initial five yearsrsquo period which could potentially be extended at a later date As the Government of the Republic of Ghana notes in the draft FASDP ldquoimproving the management of the countryrsquos fisheries and ensuring that the impacts on individuals and communities are properly addressed will take 20 or more years to effectrdquo It has therefore been judged important in this report to distinguish between changes that might occur as a direct result of the World Bankrsquos financial assistance thereby triggering the Bankrsquos environmental and social safeguards and changes that could result from longer term adjustments to fisheries and other sectors of Ghanarsquos economy as a result of wider influences by Government other donors and world-wide factors (for example international progress in world trade agreements)
The aim in this chapter is to identify changes which are likely to fall within the purview of the World Banks reputational risks and responsibilities under the first five years of the Fisheries and Aquaculture Sector Development Plan (FASDP) It should be clearly understood that the views expressed are those of the consultancy team and it will be for the World Bankrsquos internal advisors to decide what formal recommendations are made to the World Bank Board
Trends that may emerge in later stages of the implementation of FASDP ndash subsequent to the initial five year period - are discussed in chapter 6
52 THE CURRENT SITUATION
The general status of Ghanarsquos fisheries has been described in Chapters 3 while the legal and policy context has been set out in Chapter 4 The World Bankrsquos investment is being planned specifically to support government policy with the aim of providing a more efficient and better regulated fisheries sector Currently open access is leading to progressive deterioration in fish stocks and lower economic returns Based on many international examples of successful intervention the current proposals (see Chapter 2) are to provide support to introduce formal licensing of all vessels and proper monitoring and control over the seasonal timing and location of fishing activity use of gear and approved nets and self regulation through co-management structures under which the Government and fishing communities will work together to achieve recovery of fish stocks higher income levels for fishers and better returns on catches by reducing post harvest losses and improving processing and marketing operations
53 ANTICIPATED OUTCOMES
It is expected that the proposed reforms and changes will eventually lead to significant improvement in the marine environment restoration of fisheries and enhanced incomes In this respect the provision of grants and loans from the World Bank will bring about major benefits to the economy livelihoods and the environment in the longer term The question that has to be addressed however is - are there likely to be any short term adverse environmental or social consequences from the Bankrsquos own investment strategy Answers are considered in relation to each of the planned components sub-components and activities which are summarised in Table 51 A colour coding and numbering system has been adopted to distinguish those activities that are seen as particularly relevant from the standpoint of the environmental and social assessment Elements highlighted in green are those likely to have positive and beneficial effects on the environment and social conditions those highlighted in orange red have potentially negative or adverse consequences if not handled properly
38
Component 1 Good Governance and Sustainable Management of the Fisheries
Sub-Component 11 seeks to develop the capacity rules procedures and practices that will lead to better governance As such these procedural interventions will have no direct effect on the environment or social conditions of fishing communities However it will be important to ensure that the drafting agencies (government departments and consultants) give due attention to environmental and social objectives during this phase of work Three specific areas are highlighted including undertaking a socio-economic impact assessment with mitigation measures as part of the plan for fishing capacity reduction reviewing the economic and social implications of subsidies and fish import tariffs in the fisheries sector and developing the policy for the development and operation of community-based management networks built around defined fisheries management units
In developing regulations and guidelines it will be important to consider how less able individuals and vulnerable sectors are going to adapt to new systems For example the new regulations on licensing canoes including completion of registration forms the display of registration numbers on vessels and demonstration of basic competence in health and safety standards may prove taxing demands for owners and crew lacking any formal education Similarly legal instruments that are used to remove fuel subsidies or other benefits will need to be carefully explained A socio-economic impact assessment is proposed in the draft PAD to be accompanied by appropriate mitigation measures This assessment should consider amongst other things
bull whether support should be offered and if so under what conditions to any company community or individual who fails to secure a license for a particular class of vessel
bull how the transfer or sale of licenses will be regulated in the wider public interest to ensure transparent processes and avoid the creation of monopolistic and oligopolistic elites
bull who wins and who loses from any planned changes to subsidies and fish import tariff adjustments
bull how the performance of community-based management networks will be judged bull what action will be taken to mitigate the loss of any traditional fishing grounds that become the
subject of marine protected area development or are subject to exclusion zones to protect oil drilling and production platforms
Sub-Component 12 introduces the concept of fishing rights This is to be initiated through a series of four pilot stakeholder-based fishery initiatives and the rolling out of licensing procedures Discussions with stakeholders have made it very clear that the credibility of the entire fisheries policy and programme could be challenged if these pilots do not show positive and constructive ways of moving forward with fisheries reform There is a great deal of distrust for new procedures amongst the fishing communities based on the knowledge that many previous initiatives have failed It is therefore essential that the pilots are led by a strong implementation team are adequately financed and include a credible transparent and inclusive process for debate discussion and consultation Co-operation from the selected communities will be more likely to be achieved if they can see early results in terms of income generating activities
Sub-Component 13 is targeted at adjusting fishing effort and capacity to more sustainable levels and supporting alternative livelihood opportunities These activities are critical in giving effect to the policy decisions that have already been taken to reduce the size of the industrial and semi-industrial fishing fleet and to strengthen the role of the canoe sector Specific measures are proposed for compensating crew members who lose their jobs and for providing training to young men who are willing to transfer
39
out of the fishing sector The scale of this task should not be under-estimated however since there are currently few alternative employment opportunities in the coastal belt for manual workers with low education and skill levels which typify the status of many young fishermen The concept of creating some additional employment with conservation of the coastal littoral and marine ecosystems is strongly supported since this can be linked with development of tourism
Sub-Component 14 is another element that is strongly focused on delivering improved livelihoods with its emphasis on social marketing communication and transparency The focus on stakeholder participation is particularly welcome and should lead to positive response providing it is backed with direct financial support to participating communities
Component 2 - Reduction of Illegal Fishing
There is no Sub-Component 21 within the Ghana Fisheries Programme
Sub-Component 22 aims to develop monitoring control and surveillance (MCS) systems These measures are largely procedural and apart from the relatively small team that will be recruited to operationalise the systems it will have minimal effects on either the environment or social conditions One element that is highlighted in Table 51 relates to provision of facilities and training for participatory coastal surveillance of small-scale fisheries This should have direct and strongly positive benefits for participants and the communities who are enrolled in the training programmes
Component 3 increasing the contribution of the marine fish resources to the local economies
Sub-Component 31 will support the development of basic infrastructure at nine marine fish landing sites and two inland sites The scale of physical construction will be restricted to repair and minor extension of roads and jetties wharves and construction of net mending screens and storage sheds These activities are unlikely to have any significant adverse environmental impacts and should lead to positive social effects
Sub-Component 32 will underpin efforts to improve fish product trade infrastructure information and systems Introduction of new technology for smoking and curing fish and the extension of existing ice preparation plants will start to have positive beneficial effects within the selected communities
Sub-Component 33 provides a modest level of support to marine and inland aquaculture development Aquaculture development should include finalization establishment and enforcement of current draft operational standards to cater for environmental friendliness of fish culture industry for its own survival The main focus will be on developing policy and legal frameworks together with support for stock improvement These measures will have some impact on affected communities in the short term but are clearly aimed at longer term benefits
40
Component 4 Coordination Monitoring and Evaluation and Program Management
Sub-Components 41 and 42 are directed specifically at strengthening the capacity of the Governmentrsquos institutions for national implementation and regional co-ordination As such they will have no direct environmental or social impacts
54 SUMMARY AND CONCLUSIONS
This review of potential environmental and social safeguard issues under the World Bankrsquos targeted programme concludes that there are unlikely to be any significant adverse environmental or social effects as a result of the planned investments
The only possible exception relates to the effectiveness of measures that are put in place under Sub-Component 12 to support pilot stakeholder-based fishery initiatives It is of paramount importance that these pilots are successful and win the confidence of all participants since failure to achieve positive results could set back the entire fisheries programme For this reason it is essential that planning of the pilot initiatives is linked closely with measures for supporting alternative livelihoods and strengthening processing and marketing initiatives under Sub-Components 13 and 14
A number of the planned interventions may have longer term consequences as policies regulations and bye-laws are put into effect but these will be addressed in subsequent work by the Government of Ghana (see Chapter 6)
Table 51 Elements of the World Bank Programme and assessment of potential environmental and social risks
Description of Component Sub-Component and Activities
Measure of Likely Effects
Large (3)
Moderate (2)
Small (1)
None
Beneficial
3
2
1
Adverse
3
2
1
Component 1 Good Governance amp Sustainable Management of the Fisheries
Sub-Component 11 Developing the Capacity Rules Procedures amp Practices for Good Governance of the Fisheries
Reviewing developing programmes and projects designed to support the Fisheries and Aquaculture Development Sector Plan (FASDEP)
Developing an operational policy to enable implementation of the Aquaculture and Fisheries
Plan for fishing capacity reduction (including socio-economic impact assessment and mitigation) 3 2
Commercial vessel and fishing activity licensing plan including allocation criteria rules for transfer of licenses
41
Sector Development Plan and timetable and schedule of license fees
Compliance strategy and plan
Regulations for the management of fisheries including the identification and specification of fisheries management units (ie stocks species areas)
Recommendations for environmental and social safeguards arising from the review of the economic and social implications of subsidies and fish import tariffs in the fisheries sector
3
Policy for the development and operation of community-based management networks built around defined fisheries management units
3
Policy on adaptation strategies for climate change and marine protected area development
2 2
Review of the Ghana Tuna Industry to identify policy or infrastructure needs that threaten Ghanarsquos hub status
Strengthening capture fisheries management systems and capability
Development of fisheries and aquaculture management systems and processes and training
Strengthening fisheries information systems
Installation and operation of fisheries lsquodashboardrsquo database and information collection
Sub-Component 12 Introducing Fishing Rights ($15 M GEF)
Developing 4 pilot Stakeholder-Based Fisheries Management initiatives around defined fisheries units (ie local management initiatives tied to defined fisheries resources including demand-side governance initiatives)
3 2
Introducing and administering a licensing regime (registry establishment training stakeholder education) 2 2
Sub-Component 13 Adjusting Fishing Effort and Capacity to more Sustainable Levels and Supporting Alternative Livelihood Opportunities where Needed
Vessel decommissioning Decommissioning of 60 to 80 industrial trawlers in an environmentally friendly manner
2
Developing alternative livelihoods for crew of decommissioned industrialsemi-industrial
Skills training and small business development training and support for young (18-30 yrs) industrialsemi-industrial crew members willing to transition out of the sector
3
42
vessels
Alternative livelihood development to incentivize voluntary capacity reduction in canoe sector
Alternative livelihoods fund and CDD support to targeted fishing communities
3 2
Marine Resource Conservation
Would include confirming conservation priorities and management regimes and possible provision of support for alternative livelihood options (funded under 133) associated with conservation of coastal littoral and marine ecosystems as well as de facto protected areas associated with the development of oil and gas extraction
3
Sub-Component 14 Social Marketing Communication and Transparency)
Communications stakeholder consultations and awareness raising programs to support fisheries development
3
Component 2 Reduction of Illegal Fishing
Sub-Component 21 does not apply to Ghana
Sub-Component 22 Monitoring Control and Surveillance (MCS) Systems
Developing compliance systems and capability
Development of judicial and policy capacity (training)
Compliance risk assessmentstrategy systems and process development
Enforcement Unit establishment (dedicated facility)
Coastal surveillance stations 2
Facilities and training for participatory coastal surveillance of small-scale fisheries
3
Training for surveillance officers
Operation of aerial and water patrols (vessel leases aerial patrols operational costs patrol vehicles)
Observer program
Compliance education (stakeholder training signage) 1
Upgrademaintenance of the Vessel Monitoring System (VMS)
43
Component 3 Increasing the Contribution of the Marine Fish Resources to the Local Economies
Sub-Component 31 Fish Landing Site Clusters
Product diversificationvalue chain development
9 marine landing sites (basic infrastructure) at Axim Dixcove Fete Jamestown Moree Mumford Senya-Beraku Teshi and Winneba
3 1
2 inland fish landing sites (improved access and berthing infrastructure) at Abotoase and Dzemeni
3 1
2 ports developed (technical studies for 1 new port at Axim and additional berthing space in existing port of Elmina)
3 2
Sub-Component 32 Fish Product Trade Infrastructure Information and Systems
Export certification center development
Fish processing technology improvements 1 1
Technical assistance training and goods to support the National Fisheries Advisory Group
Sub-Component 33 Marine and Inland Aquaculture Development
Developing aquaculture policy and legal framework
Improving genetic quality of Tilapia fingerlings and breedstock
Catalyzing aquaculture development 2
Component 4 Coordination Monitoring and Evaluation and Program Management
Sub-Component 41 National Implementation
Technical assistance for Secretariat to the Fisheries Commission to implement the Project
Sub-Component 42 Regional Coordination
Technical assistance for Regional Coordination Unit at the CSRP support to Fisheries Information Systems (lsquoDashboardrsquo)
45
CHAPTER 6 ENVIRONMENTAL AND SOCIAL ASSESSMENT OF DRAFT FISHERIES AND AQUACULTURE SECTOR DEVELOPMENT PLAN (FASDP)
61 INTRODUCTION
This chapter examines environmental and social issues which need to be considered as part of the overall structural and economic adjustments in Ghanarsquos fisheries sector in the longer term (ie 1-15 years) The assessment deliberately focuses on the longer term because it will take a number of years before current plans start to have their full effect However the same temporal considerations apply to measures that are designed to avoid or mitigate potentially harmful effects so it will be important to start planning remedial actions as part of the joint Government of Ghana and World Bank fisheries programme
611 Key sectors and activities The fishing industry is divided first into marine capture and inland capture fisheries and then aquaculture For each of these three sectors activities are then broken down as follows Marine Capture Fisheries CATEGORY ACTIVITY Stock Management Research Surveillance reef building Harvesting Vessels Gear Skills capacity Marketing Sellers Buyers Processing Fresh fish Sun dried Smoking Freezing Consumers By market sector Support Sectors Boat Canoe Building fuel supply net making kiln construction
refrigeration transport cold store management Legal Enforcement Financing Investment in all elements Infrastructure Harbour wharf processing plant construction
Inland Capture Fisheries CATEGORY ACTIVITY Stock Management Research Surveillance Harvesting Vessels Gear Skills capacity Marketing Sellers Buyers Processing Fresh fish Sun dried Smoking Freezing Support Sectors Boat Canoe Building fuel supply net making kiln construction
refrigeration transport cold store management Legal Enforcement Financing Investment in all elements Infrastructure Harbour wharf processing plant construction
46
Aquaculture and Mariculture CATEGORY ACTIVITY Stock Management Research Surveillance Rearing Roe fingerling production cage -pond rearing Harvesting Vessels Gear Skills capacity Marketing Sellers Buyers Processing Fresh fish Sun dried Smoking Freezing Support Sectors Boat Canoe Building fuel supply cage construction kiln construction
refrigeration transport cold store management Legal Enforcement Financing Investment in all elements Infrastructure Harbour wharf processing plant construction
612 Evaluation Criteria The environmental and social assessment has been undertaken using a matrix (See Annex 114) which analyses the key sectors and activities of the fishing industry and the changes that are envisaged against a set of evaluation criteria Evaluation Criteria are broken down into environmental and social issues distinguishing between beneficial and adverse effects Table 61 below shows the relationship between the groups of criteria Table 61 List of Evaluation Criteria
Environment Social
Positive Adverse Positive Adverse
bull Sea bed rejuvenated
bull Fish stocks recovered
bull Biodiversity enhanced
bull Sea bed degraded
bull Fish stocks reduced
bull Biodiversity reduced
bull Increased harvest (catch volume)
bull Increased catch value
bull Reduced costs of inputs
bull Increased profit
bull Enhanced livelihoods
bull Increased job opportunities
bull Increased local economic multiplier
bull Reduced harvest (catch volume)
bull Reduced catch value
bull Increased costs of inputs
bull Reduced profit
bull Reduced livelihoods
bull Reduced job opportunities
bull Reduced local economic multiplier
The assessment process has involved systematically considering each sectoractivity against the evaluation criteria and recording either positive or negative results by drawing on the judgement of the consultancy specialists The findings are discussed in the paragraphs that follow and are reflected in Table 81 forming part of the Draft Environmental and Social Management Plan
62 DETAILED ASSESSMENT OF THE MARINE AND AQUACULTURE SECTORS
47
TunaIndustrial fleet streamlined and catch per vessel improved At present industrial trawlers have to travel increasing distances to fishing grounds and while the level of catch is remaining broadly static costs are increasing against available economic returns A major shortcoming is lack of investment in re-equipping the aging fishing fleet Many of the 90 vessels that make up this sector are increasingly unseaworthy and need to be replaced with modern trawlers and gear The plan is to buy out owners of substandard vessels by offering compensation at market value based on a full commercial survey Vessels remaining in the fleet will be required to meet exacting standards By reducing the number of old and inefficient boats this will allow each of the remaining vessels to catch a higher proportion of fish The aim is to ensure that Ghana is equipped with the latest vessels and technology in order to preserve the countryrsquos position as the hub of the West African tuna fishing and processing industry (see also the section on canneries below) The effect of these measures on the environment will remain broadly neutral since the same number of fish will be caught Providing other policies and increased surveillance are successful in preventing trawling in inland waters the smaller fleet will have to fish in deep oceanic waters This could potentially transfer some environmental effects on fish populations to other parts of the migratory cycle However this would become part of the international effort through fishing quotas to regulate overall catches Reduction in the size of the industrial fleet will mean that fewer men are needed to crew and service the vessels However in practice many men who work in this sector have only part time work and since a significant percentage of boats no longer put to sea the number of crewmen who will be displaced could be in the range of 1000-30003
It will be important to set up support services for those losing their jobs including retraining and welfare assistance where necessary
Decommissioning will necessitate the sale of seaworthy vessels and their removal from Ghanaian waters Other boats will need to be broken up and scrapped This process requires heavy duty specialized equipment and can release significant quantities of waste oil other toxic chemicals including refrigerants and asbestos used in pipe and engine room cladding Measures will need to be taken to ensure that proper environmental and health safety precautions are taken that decommissioning takes place in properly equipped boatyards and that all waste products are disposed of without environmental risk Cannery sector optimized The Fisheries and Aquaculture Sector Development Plan seeks to maintain the port of Tema as the centre of the Tuna canning industry in Ghana At present a proportion of Ghanarsquos tuna catch is diverted to neighbouring countries due to constraints on processing capacity These limitations include poor port infrastructure ageing equipment and delays in handling catch for some operators due to preferential treatment of vessels that are part-owned by the existing canneries Options for improvement include encouraging upgrading of the capacity of one or more existing canneries or promoting more competition in the processing sector and improving the infrastructure Providing modern building designs and construction techniques are employed and a full environmental assessment is undertaken in accordance with Ghanarsquos EIA regulations there should be no significant environmental or social risks associated with these development possibilities The potential economic benefit resulting from encouraging investment in this sector is very high
Industrial fishing excluded from inshore waters A major longer-term intention under the new fisheries plan (FASDP) is to ensure that existing regulations that restrict industrial and semi-industrial vessels from trawling in inshore waters are properly enforced This requires provision of surveillance
3 Based on an average crew of 20
48
equipment fast patrol vessels capacity building and training and increased staffing within Government agencies together with a full programme of awareness raising training and financial support to local bodies providing self-governance under new co-management services Restriction of industrial trawling in coastal waters will greatly ease pressures on fish stocks and reduce environmental damage to the sea bed In time this should lead to healthier fish population with more fish to be caught by the canoe industry as a result However the task of policing and enforcing regulations will not be easy and will take a number of years to bring into full effect Reduction in fishing activity by inshore trawlers will displace a number of crew members and have a short-term impact on dependent families until these individuals are either absorbed into the canoe fleet or find alternative employment There will therefore be a need to assist genuinely deserving cases where crew members (and their families dependents) need to transfer to other sectors of the economy These measures will only be required in the short term since the anticipated improvement in fish stocks will lead to improved economic performance in the canoe sector within which the bulk of employment exists
Expansion of deep water fisheries The fisheries plan notes that there may be a potential for exploitation or increased exploitation of some deep sea fish resources However the status and population dynamics of some affected species is not well known so any such activities should be scientifically monitored through research and enforced by MCS
Tema Secondi Port infrastructure improvements (equipmentbuildings) Under present conditions the transfer of fish from commercial and industrial vessels to canneries is often delayed by the time taken to offload crates and manouvre within the port area where there are conflicting activities There are also difficulties that arise when vessels owned by the canneries are given priority for landing leaving other boats waiting for many hours which can result in quality deterioration At this stage no details are available about the precise improvements that could be introduced and this will need to be investigated as the fisheries plan is advanced Any environmental effects from infrastructure improvements would be contained within the existing port areas and should be largely positive in reducing fuel (energy) costs and increasing overall efficiency It will however be important to carry out an environmental review of specific development proposals at the design stage especially if these involve plans for any dredging or for altering facilities for discharging waste and disposing of bilge water Both of these activities can have damaging effects on the sea bed (The first through dispersal of silt and sediment and the second through release of potential contaminants) Socio-economic effects from the infrastructure improvements should also be beneficial by removing delays increasing efficiency and reducing waste However there could be some slight reduction in manpower requirements leading to the need for skills retraining Regulating the catch (eg Fishing for selected species reducing juvenile catch to improve value of catch in inshore waters) The fundamental aim of the fisheries plan is to reduce the harmful effects on fish stocks and low economic returns from fish catches by phasing out open access for all and introducing regulation of fishing activity This is to be achieved through close cooperation between the Fisheries Commission Monitoring and Surveillance Unit as well as marine fisheries management division and individual fishing communities working together under a co-management framework The practical details will need to be worked out through each individual co-management group and initially the World Bank is offering to assist in the establishment of four pilots These bodies will test exactly what is required to increase fishersrsquo awareness to build capacity in self regulation and agree on appropriate measures
49
From discussion with stakeholders it is clear that while the broad principles are accepted the majority of the fishing community simply do not believe that the new regulations will be enforced because they have witnessed the failure of so many previous efforts to introduce firm management A major issue for the planned programme is therefore how to change this critical mindset without which very little progress is likely to be made in practice It will be necessary to demonstrate through the pilots that by regulating fishing activity direct benefits will accrue to those participating fishing communities Unfortunately efforts to eliminate harmful practices are unlikely to result in an immediate gain in fish stocks Instead catches are likely to fall in the short term It will therefore be essential to introduce other forms of incentive to cushion short term losses Such measures might include the purchase of new nets and gear for sale at subsidized price to local cooperatives the introduction of cash incentives for canoes demonstrating best practice in the use of gear and nets preservation of the catch using ice and landing and marketing fish of the required size and quality As restriction of open access starts to take effect there should be positive environmental gains in terms of improving fish stocks and less damage of the sea bed On the other hand both fishers and fish processors will feel the adverse temporary effect of reduced catches These social and local economic impacts will need to be monitored closely and assistance provided to help foster alternative livelihoods Cephalopus (Octopus) harvesting encouraged in inshore waters Although most fish species are currently exploited to unacceptably high levels within coastal waters there is a specific opportunity to increase the number of octopus caught by pot fishing This fishery could be developed by both the semi-industrial and canoe sectors Taking octopus in pots would have no adverse physical impacts on the sea bed and could allow very slight expansion in fish species that are preyed on by octopus At the same time it is important to note that there is only limited information on species composition and functioning of selected marine habitats including those of the octopus and more research should be undertaken on this and other species that could be selected for expanded fishing activity There would be clear socio-economic benefits arising from the creation of this new fishery Focusing fish landing at specific landing sites (to improve opportunities for subsequent marketing processing) Plans are already being developed for the enhancement of landing and processing facilities at a number of existing locations along the coast These locations include the construction of harbours at Jamestown and Elmina and development of landing sites at Teshie Ada Axim Dixcove Winneba Mumford SenyaBeraku Gomoa Fetteh Moree Keta Dzemeni and Tapa Abotoase Two sets of issues need to be considered in relation to these improvements all of which affect existing fish landing and processing sites The first is the nature of the physical works and infrastructure and it s potential effect on the marine and terrestrial environment The second is the socio-economic impact Both Elmina and Jamestown are long established fishing ports where the catch is landed either directly onto the beach or shallow wharves It is understood that the primary aim of the improvements will be to increase the area of permanent wharves to make it easier for fish to be offloaded to reduce the time taken in transferring stock to processing plants and to introduce modern technology In the case of other smaller landing sites the scale of improvements will be quite modest involving improvement to existing short stretches of access road the erection of stores for nets and other gear and provision of covered areas to provide shade for net-mending With all proposals for physical infrastructure development there will be a need to consider possible
50
environmental implications Due to the existing nature of these sites there are no major industrial or other commercial processes in the vicinity which could give rise to cumulative impacts including contamination of fish products The scale of plant needed for ice-making and storage and commercial smokeries is commensurate with the artisanal nature of the fishing activity itself and would not give rise to any significant environmental effects on air or water quality Harbour works could potentially involve some small scale dredging (for example the removal of accumulated silt) Where dredging is required it will be important to identify disposal areas (either at sea or on land) where silt can be deposited without damage to sensitive habitats In terms of economic and social impacts it is not clear at this stage who are likely to be the major investors from the private sector although it may be assumed that existing operators who have access to finance will be the main beneficiaries Over time as landing marketing and processing become more efficient it is possible that individuals in the traditional fish smoking sector will lose a significant proportion of their trade as the product switches to fresh or frozen fish sales for transfer to the major urban markets and the beach price for fish rises The draft Ghana fisheries and aquaculture sector development Plan notes in annex 2 that proposed facilities associated with the ports and landing sites may not have support from fish mammies or at least formidable commercial advocates able to resist any opposition from that quarter Inspection of major fish landing areas like Elmina and Sekondi indicates that the existing social and commercial structure of support activities to fish harvesting is very complex and involves almost every member of the community including children and the elderly Such activities include net mending boatbuilding metalworking (for cooking pots stoves and grills supplies (ropes weights tar paint wood) fuel supplies ice crates transport etc Leaders of the fishing community confirmed that in principle the improvements of facilities is welcomed provided that safeguards are in place for those who may lose part or all of their current trading activity through rationalisation Stabilise fleet capacity at a sustainable level Fishery experts consider that there would be significant benefits in reducing the number of canoes from the present 10000-12000 to around 8000-9000 which correlates with the number operating in the mid 1990rsquos when catches were at optimum levels At the same time the Fisheries and Aquaculture Plan stresses that the canoe sector will remain at the heart of the Ghana fishing industry and this has strong political enforcement Consequently there is unlikely to be any enforced reduction in the number of canoes holding licenses and owners of all existing canoes will be able to register their vessels The ability of canoe owners to pay annual licence fees should rise as the overall measures to increase efficiency and improve catches take effect However many people anticipate that over time as the annual cost of holding licenses rises less efficient fishers will sell their licenses (and hence their rights to fish) There may therefore be a de facto reduction in the size of the canoe fleet Even if numbers do not decrease the fleet could be stabilized at its present size by taking a decision not to grant new licences The draft plan discusses the fact that under existing law (section 53) there is a requirement for licenses to be issued on demand (presumably to ensure that Ghanaians are not barred from subsistence fishing) It is argued in the plan that this is a misconception since canoe fishing is largely a commercial activity and it is concluded that lsquoit is therefore essential that the number of canoe licenses can be controlled in future and the legal basis for these controls must be reviewed as a matter of priorityrsquo Decisions of this nature will require the full support of local co-management groups if they are to be effective but committees could easily come under pressure to make exceptions as the coastal population continues to rise and families without alternative livelihoods start lobbying for assistance
51
Accusations of preferential treatment of certain individuals by committees (or committee officials) - possibly linked with suggestions of bribery and corruption -could cause a lot of social tension and start to undermine community trust in the need to work together to improve fisheries management It is therefore most important that the detailed proposals for co-management address this risk and include proposals for mitigating individual hardship of the less advantaged ndash for example by offering voluntary retirement with some form of incentive Influencing marketing to maximise value and reduce post harvest losses (marketing cooperatives strong market structures etc) FAO has estimated that physical post harvest losses in Ghana amount to between 3 and 17 of smoked fish production and 16-20 of gillnet landings The plan notes that introduction of lsquonew generationrsquo small scale fish smokers should be introduced to replace the traditional Chorkor model This would improve fish product quality by eliminating charring of fish over open flames and also protecting operatorsrsquo eyes from the damaging effect of smoke and particles The other major improvement in post harvest value and profits would arise from greater use of ice throughout the supply chain Developing Aquaculture A distinction needs to be made between aquaculture development in ponds and dugouts which are self-contained and fish rearing in cages within open water In the case of farm ponds the commercial rearing of fish is little different to other forms of intensive livestock rearing Providing there is no direct connection to rivers and streams there is little likelihood of interaction between farmed and wild stocks which could spread fish infections and parasites In the case of fish farms in open water (rivers and lakes) there are well known risks of the spread of disease which can arise if overstocking occurs Intensive feeding of large numbers of fish in a confined area can lead to significant deterioration in water quality through the build up of nutrients from wood and waste It is also possible for antibiotics and growth hormones to be dispersed beyond the area of farm cages Genetic modification of farmed fish can also affect the local fish population through escapes All of these issues are capable of being managed and mitigated through good initial planning and design and subsequent maintenance and supervision It will therefore be necessary to develop additional regulations and guidelines specifically for the aquaculture sector 63 SUMMARY OF ENVIRONMENTAL RISKS AND OPPORTUNITIES Review of the full range of governance and development activities suggests that there are no high levels of risk to the marine or littoral environment Successful implementation of the Policy and plan should in fact result in very significant environmental gains Over a timespan of 5-20 years five activities in particular should result in significant improvements in the condition of the sea bed in coastal waters (to a depth of 30 metres) reestablishment of benthic flora and niche habitats increased fish stock and enriched biodiversity These interlinked activities are bull The exclusion of industrial vessels and trawling within coastal waters bull Regulation of fish catches through zonation seasonal control of fishing and standards for vessels
gear bull Stabilisation of the fishing fleet within sustainable harvesting yields bull The adoption of management plans formulated and agreed with full cooperation of local
communities bull The introduction of fishing rights through co-management agreements and bull Well planned consultation and information dissemination throughout the fisheries sector
52
Three components of the development plan have been identified where minor to moderate risk to the physical and biological environment could arise if proper design and implementation standards are not adhered to These relate to bull A potential risk of over-exploitation of new catch species in deep water off the continental shelf if
such development is not accompanied by through research to establish the sustainable yield of target species
bull Strictly localized effects on the physical environment from construction of landing wharves or jetties and other harbour facilities and
bull Infrastructure development at the existing ports of Tema and Takoradi All of these risks are capable of being fully managed by improved governance in the fishing sector and EIA procedures that are well-established in Ghana 64 SUMMARY OF SOCIO-ECONOMIC RISKS AND OPPORTUNITIES Implementation of the Plan Project will bring about substantial change in the fisheries sector and over time increased revenue reduction of post[harvest losses and added value to fish products will bring major economic returns At the same time there will be some individuals who do not participate in direct gains and whose livelihoods could be adversely affected if appropriate safeguarding measures are not put in place The level and extent of these socio-economic risks will be determined by 1 the level of commitment that is entered into by Government and its development partners to
deliver incentives to vulnerable and disadvantaged groups and 2 the speed with which the sector is transformed Rapid change could cause significant
displacement of less-efficient operators especially within the semi-industrial and canoe sector which would have serious ramifications for dependent communities However these effects can be marginalized if the development programme is carefully phased to ensure that alternative livelihood and employment incentives are available
The main risks to local livelihoods relate to the potential for bull loss of employment for crews of unseaworthy obsolete vessels ( from all sectors including
industrial semi-industrial and canoes) that are withdrawn from the fishing fleet because they no longer comply with license regulations
bull the inability of vulnerable and disadvantaged groups including artisanal fishers vendors and individual fish processors in small fishing villages to adjust to new market conditions at selected landing sites
53
CHAPTER 7 ASSESSMENT OF POLICY OPTIONS
71 INTRODUCTION
In order to place the significance of the environmental and social safeguards assessment in context this chapter examines the possible consequences of different policy responses to the existing challenges that face the fisheries sector in Ghana These different policy responses range from a continuation of the status ndashquo effectively a ldquodo-nothingrdquo option (A) to full-scale commitment by all stakeholders to achieving a sustainable fisheries future the ldquoOptimum Solutionrdquo option (C) Various less sustainable outcomes lie in between these two ends of a continuum of policy choices and these are represented by the ldquoWeak Solutionrdquo option (B) 72 OPTION A ndash DO NOTHING Background research and discussion with stakeholders indicates that practical capacity to deliver on clearly stated national goals for sustainable fisheries livelihoods and the reduction of poverty is weak This situation exists despite the fact that Ghana has a strong legal framework for management of its fisheries including the Law Policies and Regulations There is inertia and strong resistance on the part of the majority of players to accept that it is largely their own actions which are responsible for present conditions This in turn leads to the attitude that it is only the lsquoGovernmentrsquo that must act by providing increased subsidies and cushioning the industry against further deterioration in catches Unfortunately there is overwhelming evidence from around the world that where fish stocks are exploited beyond their natural capacity to regenerate this can lead to sudden and near-total collapse Ghana has historically been one of the strongest fisheries in West Africa but the signs are ominous that current levels of exploitation are leading to progressive decreases in annual catches for most species in both marine and inland waters As fishing effort intensifies with an increasing number of all types of vessel using illegal methods and inappropriate gear the distinction between the traditional lsquopeak season and lean season (linked to migration patterns breeding cycles and upwelling) is becoming blurred This is clearly illustrated by a statement from one of Elminarsquos fish mammies ldquowe use to smoke the herring in the peak but now the fishers bring them all the yearrdquo Use of monofilament nets light dynamite and chemicals to obtain fish in the lean season is aggravating a situation where too many boats are chasing too few fish Many fishers blame the reduction of catch on global warming for increasing water temperature the emergent oil and gas industry for restricting access to traditional fishing grounds and industry and urban development for increasing pollution leading to deterioration in water quality Each of these assertions warrants careful consideration but the industry is generally in denial when it comes to the primary fact ndash too many fish including juveniles are caught to allow regeneration of the stock In addition weak governance and lack of resources to ensure implementation of policy result in a situation where the law can be ignored with impunity If collective failure to recognize the seriousness of the current position and lack of commitment to taking hard decisions continues the omens for the future are not good Within a period of 10-15 years fish catches could fall by 50 or more from their present level Impacts on each species would vary and catches of some fish with regional or global migration patterns could remain viable (although this depends on the international conservation effort) On the other hand stocks of fish that provide the mainstay of local food resources herring and sardine could be decimated
54
Complete collapse of all fish species is unlikely but it is possible to envisage a situation where catches might fall below 300000 tonnes a year by 2025 (a reduction of more than 25 from present levels) The most serious consequences would be felt as a result of the social and local economic impact on fishing communities Perhaps 30000 men representing the crews of 3000 canoes and semi industrial boats and 15000 women engaged in marketing and processing would lose their present livelihoods Population migration away from the coast could follow and severe social pressures and local economic hardship This is clearly a ldquoworst caserdquo scenario and if conditions were to worsen gradually it might be possible to intervene but the fact has to be accepted that fish stocks are dynamic and subject to rapid decline (as in the case of the North Sea Herring and Atlantic Cod) 73 OPTION B THE lsquoWEAKrsquo SOLUTION The bleak future painted in Option A is unlikely to arise if the present policy and draft fisheries development plan is followed since these are specifically directed to addressing the major challenges However realization of the aims is dependent upon delivery across a wide range of initiatives by multiple stakeholders The following paragraphs illustrate some of the ways in which delivery of policy objectives might be thwarted These may be summarized as
bull Commitment to good governance and institutional reform bull Political resolve to implement unpopular measures bull Availability of adequate technical and financial resources bull Inertia to necessary changes in fishing practice
Good Governance and Institutional Reform Fundamental reforms are required to fully equip the national fisheries management effort at government level This includes introduction of change management clarification of responsibilities for senior staff rationalization of financial management systems provision of equipment expansion of staff numbers additional training and capacity building As an illustration of the extent of the effort required reference can be made to just one topic area the issue of monitoring control and surveillance At present the Fisheries Commissionrsquos MCS Unit has only 10 employees to oversee implementation of the fisheries regulations throughout Ghana This number will be increased as other institutions are engaged in joint monitoring initiatives but it is obvious that staff numbers and capacity will need to be expanded if regulations on fishing activities are to be affected Enforcement is only one part of the equation however Much greater emphasis will need to be placed on voluntary controls and self-policing at community level through Co-management schemes
Failure to press ahead with governance and institutional reform could delay the process of introducing and registering licenses which represents a crucial first step in moving from open access to managed access in the fisheries sector Given the urgency for action the five years allowed in the current plan for completing the registration process seems very generous Political resolve to implement unpopular measures Stakeholder meetings have confirmed the significance of party political influence as a constraint on achieving progress in the reform of the fisheries sector The offer of incentives like subsidies or the promise of new facilities and equipment are regularly employed by individual politicians to garner votes whether or not these form part of party manifestos Examples have been quoted to the consultants where enabling regulations that might restrict fishing access and prove unpopular amongst the fishing community are quietly ignored and officers may be discouraged from pursuing breaches of the law where the offender has political influence These issues arise with governments of all political
55
persuasions and can apply at all levels from District Assemblies through to regional and national committees
A serious issue with fisheries sector reform is that once actions have been taken to conserve fish stocks it may be years before the full benefits are felt and the results are evident in terms of increased catches This makes it harder for governments to institute unpopular reforms ndash even though these are in the best interests of the nation fishing communities and individuals Fishermen and their families are used to seeing an instant lsquosame day returnrsquo on their catch and are less willing or able than stakeholders in other economic sectors to wait for gradual improvements There is an urgent need to establish cross-party support for the fisheries sector in Ghana and to seek agreements between the main political parties to support established policy and regulations where these are in the interests of delivering sustainable fish stocks Availability of Technical and Financial Resources The process of moving from complete open access to restricted use rights for both marine and inland capture fisheries will take many years to complete Progress will be heavily influenced by the level of political will availability of technical assistance and financial support Existing subsidies (pre-mix fuel and import tariffs) are seen as a deterrent to the encouragement of more efficient business practices However in order to reduce dependencies on these forms of government aid there is also a need to underwrite new forms of economic enterprise by giving help to start-up businesses developing training centres and promoting alternative livelihoods for those individuals who are either displaced or voluntarily give up work in the fisheries sector Inertia to Change Traditional fishing practices are quite literally a way of life for many Ghanaians and have been handed down from generation to generation These traditions are closely interlinked with cultural practices and power and influence resides in specific families with hereditary authority In order to change attitudes and gain acceptance of new approaches to fishing there is a need for a major awareness building and communications strategy targeting in particular the traditional leaders of the fishing industry Without such a plan it will be difficult to break down the internal resistance and inertia towards change The constraints that have been outlined above in relation to the lsquoweakrsquo option are very real and in combination they present a serious barrier to progress It will require real political commitment on the part of Government and strong financial support from international partners to break down these barriers 74 OPTION C THE lsquoOPTIMUMrsquo SOLUTION
The new Draft Fisheries and Aquaculture Plan together with the Act and Policies provide a solid foundation for revitalising the fisheries sector in Ghana However for the reasons discussed in relation to options A and B above there are a number of impediments that need to be overcome In addition to the measures in Option B an ldquoOptimumrdquo solution would also include
A coherent mix of Incentives (carrots) and Regulation (sticks) A top priority in developing existing strategies and plans will be to ensure that measures are in place to offer encouragement and practical assistance to fishers to convert to more sustainable practices while at the same time introducing effective enforcement There are some real challenges with both of these goals
56
New forms of incentive need to be developed to convince boat owners and their crews that it is worth their while to drop illegal methods (dynamiting use of monofilament nets etc) and to reduce the level of fishing effort (through close seasons introduction of restricted zones etc) Without these incentives it is highly unlikely that there will be significant take-up of the fisheries stock management and conservation message Special attention needs to be given to the role of chief fishermen and local community councils in developing effective local policing since it is impractical to rely on a national MCS team to regulate canoe activity in either the marine or inland capture fisheries The national MCS team will have its own responsibilities for policing local and international waters in relation to industrial and semi-industrial sized vessels Integrated Coastal Development The long term success of the fisheries strategy depends upon reducing fishing effort to a level at which catches become both sustainable and profitable for those who remain in the business This in turn requires that those displaced from the industry are able to find gainful employment and livelihoods in other sectors of the economy The fisheries industry is often seen as a separate economic sector which attracts its own funding and support but in order for the necessary reforms to take place these attitudes will need to change A new approach is required to lsquointegrated coastal developmentrsquo following the lessons from integrated rural development Many fishing inland and marine fishing communities are almost wholly dependent on fishing with less than 10 of the local economy being devoted to other industries Reform of the fishing sector therefore requires that as much ndash if not more ndash effort is devoted by government and its international partners to building up complementary economic activities in construction transportation manufacturing food processing environmental conservation and tourism There is a need to explore new state industry partnerships to establish appropriate economic development agencies and to coordinate activities between relevant state institutions ministries and departments under the current decentralisation initiatives with district assemblies taking a prominent role If initiatives of this sort are taken forward it will make the task much easier in persuading conservatively ndashminded fishing communities that they need to simultaneously develop their own entrepreneurial flair and impose their own discipline
57
Chapter 8 DRAFT ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK (ESMF) 81 INTRODUCTION Previous chapters of this report have described the principal environmental and social impacts that are likely to arise from reform in the fisheries sector This chapter sets out the Framework (ESMF) for an Environmental and Social Management Plan (ESMP)The first step has been to outline specific objectives to be achieved through implementation of the ESMF These objectives relate specifically to the issues described in earlier chapters Subsequent sections of the chapter detail the measures which are required to respond to specific areas of environmental and social impact through mitigation and amelioration works They also describe the types and level of environmental monitoring required together with the institutional aspects which need to be improved in order to support the fisheries sector 82 STRATEGY AND OBJECTIVES The basic aim of the environmental and social management plan is to set out guidelines for participatory programs under which members of local fishing communities and civil society in general can become involved in the design and implementation of local fishery co-management maintaining sustainable local livelihoods and achieving local monitoring of fishery efforts The basic principle for future fisheries management is that both marine and inland waters will be demarcated as territories for use rights to fisheries (TURFs) The principal goal of government policy in the fisheries sector is to ensure that the fisheries industry plays an increasingly important role in supporting the growth of the economy as outlined in the Ghana poverty reduction strategy (GPRS II) and the Republic of Ghana fisheries and aquaculture policy This goal will be supported by implementation of the fisheries and aquaculture sector development plan over the next five years In this timescale the aim will be to bull improve management of fisheries the conservation of aquatic resources and protection of the
natural environment bull promote value addition in the fisheries sector and the improvement of livelihoods in fisheries
communities bull encourage sustainable development of aquaculture bull improve the services provided to the fisheries sector by the fisheries commission and supporting
institutions The overall consequences of this strategy and the investments that are being made by the government and its aid partners will be stabilisation of fish stocks and sustainable catch levels a strengthening of the national economy and creation of a more robust fisheries industry with consequent benefits for fishing communities Impact assessment confirms that the result will be significant benefits for the marine environment and local economy However depending on the rate of transition from an open access to a fully regulated market a number of adverse effects could arise unless appropriate mitigation measures are put in place Specific issues which require attention in this plan are listed below bull potential risks of environmental degradation through development of new fishing targets in
deep water
58
bull localised environmental impacts at construction sites bull loss of resources for individual operators due to restricted or controlled access to fishing
grounds bull displacement of labour from crews of vessels that are withdrawn from the industrial and semi-
industrial fleet bull Decommissioning of obsolete industrial vessels may not necessarily lead to recovery of fish
stocks Catch Per Unit Effort (CPUE) may increase This could lead to loss of livelihoods to crew members and the owners of the decommissioned vessels it could increase catch for the few vessels remaining in the system
bull increase production costs due to idling time in closed seasons for fishing bull exclusion of some groups and individuals seeking entrance to the industry following completion
of licensing bull concentration of processing and marketing at selected landing sites leaving Fish Mammies and
their dependents in other smaller fishing communities at an economic disadvantage bull displacement of traditional canoe building and other ancillary support industries by more
efficient and modern methods of construction and the inability of some workers in these trades to train and re-skill in the use of modern materials
bull lack of employment opportunities in alternative sectors The ESMF will set out specific actions to address these concerns through a coordinated set of interlinked proposals as follows 1) Preparation of local management plans and close surveillance of all new fishing enterprises in
deep waters
2) Preparation of environmental protection clauses to be included in all contracts and agreements for physical development work
3) Regular inspection by environmental protection officers of construction work at harbours and landing sites
4) Establishment of community management plans to provide support to those groups and individuals who are adversely affected by any of the measures listed above
5) Creation of community liaison groups to actively support community development alternative livelihoods and conversion to new areas of economic activity for those Fisher families or individual fishers who are adversely impacted
6) Introduction of skills training centres and business advice for small and medium enterprise development
7) Establishment of a coastal development agency drawing on the resources of the ministry of local government agriculture and tourism (others to be added) to coordinate integrated projects and initiatives for economic development linked with the existing coastal zone management plans
8) Creation of a liaison group between the government of Ghana and its international development partners to ensure that investment in the fisheries sector is targeted in the most effective way to deliver plan objectives and avoid duplication of effort
59
83 COMPONENTS OF THE ESMF The following paragraphs provide a summary of the draft ESMF 831 Local Management Plans these plans will be prepared for discrete zones of influence around specified fishing settlements Each plan will contain the same standard list of relevant activities that are to be monitored 832 Environmental Protection In relation to construction activity a checklist will be prepared identifying precisely what level of environmental scrutiny is required for specific types of development This checklist will be prepared by the Fisheries Commission with the support and advice of the Environmental Protection Agency 833 Small-Scale Project Development and Livelihood Restoration a list of potential micro-projects will be prepared by the Fisheries Commission which are regarded as suitable for support funding Demand for these micro-projects will be determined at the local level (ie in villages and fishing communities) Applications for funding of micro-projects will be submitted to the community liaison group for vetting and recommendation based on pre-established eligibility criteria Recommended projects will be referred for formal approval at national level (or through the Coastal Development Agency) 84 POTENTIAL PROJECT IMPACTS ON ASSETS AND LIVELIHOODS The project will have some adverse impacts on assets and livelihoods Therefore provisions will be made under the ESMF to minimize all such impacts including those of socio- economic significance and on any environmentally sensitive sites Provisions are also made in the RPF to accommodate all potential situations including cases that may entail actual displacement and livelihood restoration assistance in accordance with the Governmentrsquos policy and World Bank Policy on Involuntary Resettlement OP412 (see Chapters 9 and 10) The potential social and environmental impacts associated with the project (see Chapters 5 and 6) are summarised in Table 81 and the approach to related mitigation measures is defined in section 85 and Table 82 below
Table 81 Potential Environmental impacts and Social issues
Type of Activity Description Environmental Significance
Social Significance
Decommissioning of obsolete industrial vessels
Scrapping of vessels may release toxic waste (contaminated oils asbestos pipe wrapping and insulation etc)
Contamination of landfill dumps
Related health hazards
Laying off of work force Recovery of fish stocks in areas currently over-fished by trawling
Decommissioning of excessovercapacity would result in loss of livelihoods for crew members
60
Plan for fishing capacity reduction
introduction of licensing system for canoes and enforcement of licensing system for semi industrial vessels
Reduced catch from the decline in the use of prohibited fishing methods (activities) as stipulated in the Fisheries Regulation 2010 (LI1968) eg use of light dynamite etc
Reduction in fishing capacity should lead to significant recovery of fish stocks with long term benefits for all
Short term reduction in fishing effort and increased regulation may prejudice vulnerable sectors (illiterate elderly fishers) Capping on new entrants may remove the safety net opportunity offered by fisheries to would-be fishers who may be without alternative livelihoods
Harbour development and landing site improvements
Construction of access road improvements Erection of fish processing and ice making plant The Project could give rise to a small level of physical displacement for some sectors of individual communities
Removal of shelters homes Displacement of boat repair and trading sites for local community
Possible non-voluntary resettlement including vulnerable groups (women children and the elderly)
Adaptation Strategies to climate change
Introduction over time of regulations relating to fishing activity in rivers lakes estuaries lagoons and lsquoareas of upwelling affected by climate change
Measures to combat tackle rising temperature and other climate induced changes should ameliorate environmental impacts
Both beneficial and adverse effects may result from changes in climate (eg faster growth rates from higher water temperature spread of invasive species)
Establishment of exclusion zones ndash oil production and marine protection areas
Restrictions on fishing in oil production areas and marine protection areas
Positive ndash recovery of fish stocks but also potential risks of pollution from oil leaks and human waste
Temporary loss of livelihood for those fishers displaced from lsquotraditionalrsquo fishing grounds
Development of Co-Management System
Creation of 4 pilot Stakeholder ndashbased Fisheries Management Initiatives
Demonstration of practical benefits for the marine environment resulting from elimination of damaging practices
Greater social cohesion and sense of purpose established
61
Type of Activity Description Environmental Significance
Social Significance
Support for PAPs Establishment of enterprise training programmes
Development of criteria for defining Project Affected Persons (PAP) Development of skills training schemes enterprise allowances alternative livelihoods fund
Major benefits for PAPs ndash but scope for misinterpretation mismanagement of programme at local level Jobs created under social significance should be familiar to the fishers ie things they will be willing to do
Developing Compliance Systems
Establishment of enforcement unit and development of facilities and training for participatory coastal surveillance of small-scale fisheries
This component will greatly improve controls over environmentally unfriendly damaging activities
A number of new jobs should be created under this programme
Improvements in fish processing technology
Development of more efficient fish processing plant
This measure should reduce significantly the proportion of fish lost or degraded post harvest Improved fish processing technology will also reduce wood used from the forest as firewood for fish smoking
Potential displacement of vulnerable groups (women children and the elderly)who currently participate in fish drying curing using basic equipment
Construction of fish ponds
Expanding areas of dug-outs and other farm ponds
Small scale impacts on vegetation stream flow
Displacement of existing land users
Catalysing aquaculture development
Encouragement of larger fish farming enterprises Installation of fish cage aquaculture
Localised deterioration in water quality increased nutrients leading to eutrophication potential spread of fish parasites disease
Potential competition with free capture fisheries displacing vulnerable groups in existing fishing villages
62
85 PROPOSED MITIGATION MEASURES AND COST ESTIMATES Mitigation measures The potential environmental and social impacts to be addressed within the context of preparing this Environmental and Social Management Framework are generalized as shown in Table 82 below It is not possible at this time to prepare specific mitigation measures It is expected though that environmental and social assessment studies will be carried out within specific localities as and when required The framework for compensationresettlement (See Chapters 9 and 10) will then be applied incorporating (1) specific institutional arrangements (2) resettlementcompensation eligibility criteria (3) implementation procedures (4) financial responsibilities and (5) monitoring and evaluation plan Livelihood restoration measures Furthermore the livelihood restoration measures will consider issues such as
(1) income levels of affected persons
(2) other non-monetary sources of livelihood
(3) constraints and opportunities for income generation
(4) number of persons not able to revert to previous occupation and
(5) existing skills of affected persons
Table 82 Proposed mitigation measures for some potential impacts
Type of Impact Description of mitigation measures
1 Decommissioning of obsolete industrial vessels
a) A register will be prepared of all industrial vessels that are due to be decommissioned recording the owner and location of each vessel b) A system will be introduced for tracking progress on decommissioning including the means of disposal and measures taken to dispose of all potentially toxic or hazardous materials c) Persons who lose their job or livelihood as a result of a decision to decommission any particular vessel will be entitled to benefit from the skills training schemes enterprise allowances alternative livelihoods fund being developed
2 Plan for fishing capacity reduction
a) A full Social and Environmental Impact Assessment will be carried out on the Plan for fishing capacity reduction and appropriate measures for ameliorating and mitigating adverse effects on affected sectors of the community and PAPs will be incorporated in a revised edition of this Fisheries Environmental and Social Management Framework
63
3 Harbour development and landing site improvements
a) All harbour development proposals will be subject to Environmental and Social Impact Assessment (ESSA) in accordance with EPA Regulations b) Proposals for improvement of individual landing sites will be assessed in accordance with the checklist (832) and submitted to EPA for a ruling on the level of environmental assessment that is required which will depend on the nature of the intended works
4 Adaptation Strategies to climate change
a) An adaptation Strategy shall include proposals for mitigating any impacts on the environment or social welfare of local communities
b) Any strategy for responding to potential effects of climate change on the fisheries sector will be submitted to EPA for review to determine whether an SEA or EIA is required
5 Establishment of exclusion zones ndash oil production and marine protection areas
a) Proposals for restricting access of fishing vessels to oil production areas and marine production areas shall be subject to an Environmental and Social Assessment which shall be submitted for approval to EPA b) In the event that restrictions are likely to adversely affect fishersrsquo livelihoods the provisions set out in 7 below will apply
6 Development of Co-Management System
a) Development of co-management systems will require full cooperation and engagement of all stakeholders In the unlikely event that the provisions of any scheme are challenged by local communities there shall be a right of appeal to the Minister of Food and Agriculture and the Fisheries Commission acting jointly
7 Support for PAPs
Establishment of enterprise training programmes
a) Identification of vulnerable people including women children and the elderly and identification of the cause and impacts of their vulnerability shall be established through direct interviews and procedures to be developed as part of 6 above b) A high priority within the Fisheries and Aquaculture Sector Development Plansrsquo first five year programme will be the development of specific proposals for the establishment of skills training programmes and the establishment of enterprise allowances and an alternative livelihoods fund c) The measures outlined in 7b) above will be targeted specifically at PAPs and vulnerable sectors of the community
8 Developing Compliance Systems
a) All proposals for securing compliance with fisheries regulations shall be subject to review by a fisheries stakeholder committee to be established by the Fisheries Commission with the remit of ensuring that the measures themselves and penalties for failure to comply are commensurate with the ability of offenders to make restitution and do not unfairly penalize vulnerable sectors of the community
9 Improvements in fish processing technology
a) All plans and proposals for the introduction of new fish processing technology shall be published and shall include a statement on the likely impact of the project on existing processors within the local community
64
b) Any members of the public who consider they are unfairly disadvantaged by proposals for the introduction of new technology may apply to the local co-management committee to determine whether or not they fall within the category of PAP (see 6 and 7 above)
10 Construction of fish ponds Proposals for the construction of new fish ponds shall be assessed in accordance with the checklist (see section 832)
11 Catalysing aquaculture development
a) All proposals for aquaculture development shall be in accordance with the provisions laid down in Local Management Plans applying to specific TURFs
65
2
protection and mitigation is provided through implementation of an Environmental and Social Management Plan
Chapter 5 considers the four funding components under which the World Bank is proposing to support the Ghana Fisheries and Aquaculture Sector Development Plan These cover
1 Good governance and sustainable management of the fisheries 2 Reduction of illegal fishing 3 Increasing the contribution of the marine fish resources to the local economy and 4 Coordination Monitoring and Evaluation and Program Management The potential for investment to give rise to adverse effects on the environment andor social conditions is reviewed It is concluded that that there are unlikely to be any significant adverse environmental or social effects as a result of the planned investments The only possible exception relates to the effectiveness of measures that are put in place under Sub-Component 12 to support pilot stakeholder-based fishery initiatives The outcome of the overall program will depend heavily on the success of these pilots For this reason it is essential that planning of the pilot initiatives is linked closely with measures for supporting alternative livelihoods and strengthening processing and marketing initiatives under Sub-Components 13 and 14
Chapter 6 provides an analysis of the environmental and social issues raised by the wider fisheries and aquaculture programme and as such it constitutes the Environmental and Social Assessment (ESA) A matrix is used to identify potential interactions between elements of marine and inland fishery capture operations and the natural environment together with possible socio-economic effects A similar matrix is also used to examine the potential for aquaculture development The overall effects of the planned interventions are positive in terms of both environmental and socio-economic gains but there are potentially some adverse social and economic consequences for a limited number of individuals whose livelihoods will be affected by restrictions on access to fishing or from changes in economic conditions affecting the purchase processing and marketing of fish Mitigation measures are considered subsequently in Chapter 8
Chapter 7 briefly considers the possible consequences of taking no action to deal with the declining stocks and profitability of fishing (the do-nothing option A) This is a standard part of the methodology for conducting an Environmental and Social Assessment The conclusions are compared with the alternatives of taking limited action (a lsquoweakrsquo option B) or of implementing the full set of plans and proposals (the lsquooptimumrsquo option C) The comparison includes the conclusion that the fisheries industry is often studied and dealt with in isolation from other parts of the economy However in order for the planned reforms to have maximum beneficial impact a new approach is required to integrated coastal development in which a range of ministries and agencies should be involved
Chapter 8 sets out a draft Environmental and Social Management Framework (ESMF) This picks up areas of risk identified in the ESA Report and proposes remedial action The ESMF notes that the principal goals of government policy are to
bull Improve management of fisheries the conservation of aquatic resources and protection of the natural environment
bull Promote value addition in the fisheries sector and the improvement of livelihoods in fisheries communities
bull Encourage sustainable development of aquaculture
3
bull Improve the services provided to the fisheries sector by the Fisheries Commission and supporting institutions
The Draft ESMF sets out eight specific interlinked actions namely
1) Preparation of local management plans and close surveillance of all new fishing enterprises in deep waters
2) Preparation of environmental protection clauses to be included in all contracts and agreements for physical development work
3) Regular inspection by environmental protection officers of construction work at harbours and landing sites
4) Establishment of community management plans to provide support to those groups and individuals who are adversely affected by any of the measures listed above
5) Creation of community liaison groups to actively support community development alternative livelihoods and conversion to new areas of economic activity for those Fisher families or individual fishers who are adversely impacted
6) Introduction of skills training centres and business advice for small and medium enterprise development
7) Establishment of a coastal development approach drawing on the resources of the ministry of local government agriculture and tourism (others to be added) to coordinate integrated projects and initiatives for economic development linked with the existing coastal zone management plans
8) Creation of a liaison group between the government of Ghana and its international development partners to ensure that investment in the fisheries sector is targeted in the most effective way to deliver plan objectives and avoid duplication of effort
Chapter 9 provides a draft National Process Framework (NPF)) to implement the recommended process framework laid down by the West Africa Regional Fisheries Program (WARFP) which Ghana will become part of This framework explains how eligibility criteria will be employed to determine which settlements qualify as participating communities and what the responsibilities of these communities will be in terms of setting up Co-management Committees (CMCs) and selecting classes of Project Affected People (PAPs) who will be eligible for assistance under national guidelines to be prepared by the Fisheries Commission The ESMP also outlines proposals for income restoration measures in accordance with World Bank guidance as interpreted through the West Africa Regional Fisheries process framework that where open access to fishery resources is restricted for the common good any adversely affected individuals should not be penalized but should receive assistance to restore their livelihoods at least to the extent that they are impacted by the project activities and preferably to an improved state1
1 Extract from Executive Summary Process Framework West African Regionl Fisheries Program (P106063) Cape Verde Liberia Sierra Leone Senegal Commission sous Regionale des Peche Dakar Senegal
Measures are also outlined for conflicts or grievance resolution administrative and legal procedures and monitoring arrangements
ldquoSection V Livelihood Restoration Measures World Bank policy requires that livelihoods be restored at least to the extent that they are impacted directly by project activities and preferably inproved This policy prescription is based on the principle that people who give up most for the public good ndash the PAPs- should not be penalised and impoverished as a result of their loss for the greater good The aim thereopfre is to improve the public good (in this instance marine resources) while also ensuring that those who lose access to resources and income because of restrictions on marine resources are assisted effectively to restore that part of their income that is affected through alternative livelihood measuresrdquo
4
Chapter 10 looks in more detail at specific safeguards relating to possible involuntary relocation of people as a result of the long term fisheries programme It constitutes the Resettlement Policy Framework (RPF) which while not a formal legal requirement of the World Bankrsquos lending policy is nevertheless recommended as good practice
5
PART A ENVIRONMENTAL AND SOCIAL SAFEGUARDS ASSESSMENT
The Environmental and Social Safeguard Assessment comprises bull Three background chapters (1-3) bull Two chapters which deal with assessment of the potential effects of the World Bankrsquos financial
and technical support for the Ghana Fisheries Programme over the initial five years (Chapter 4) and the longer term effects of the overall Fisheries Programme which is expected to run for 10-15 years (Chapter 5)
bull Analysis of the consequences of taking no action (the do-nothing option) in Chapter 7 and bull A draft Environmental and Social Management Framework (Chapter 8)
7
CHAPTER 1 INTRODUCTION
11 INTRODUCTION The government of Ghana is embarking on a Fisheries and Aquaculture Sector Development Plan (FASDP) for restructuring its coastal and inland fisheries The aim is to reverse the current trend whereby fish stocks are increasingly diminishing and the current rate of fishing is unsustainable resulting in less productive fisheries increased costs with declining profitability and the risk of exacerbating nutritional deficiencies and poverty within fishing communities To date the government has enacted legislation (Fisheries Act 2002) prepared policies (2008 updated in 2010) and published regulations (August 2010) but the Ministry of Food and Agriculture and the Fisheries Commission lack the capacity and financial resources to implement all of these initiatives The World Bank is therefore considering a supporting programme of technical assistance and finance which will assist with governance reforms the introduction of licensing for all vessels a reduction in the size of the industrial and semi-industrial fishing fleets and the progressive transfer of fishing activity to the canoe sector International support for Ghanas fishing industry is being coordinated under the West Africa Regional Fisheries Programme (WARFP) This initiative began with four countries Cape Verde Liberia Sierra Leone and Senegal It is now being extended to the following countries Ghana Guinea Guinea Bissau and Gambia A process framework has been developed by the Commission sous Regionale des Peche (Based in Dakar Senegal) to assist member countries of WARFP to prepare their own national process frameworks together with accompanying environmental and social safeguards assessment an environmental management plan and resettlement policy This report has been designed to provide the outline structure and contents for these documents on behalf of the Government of Ghana Another important function of the report is to review the application of the World Banks own Environmental and Social Safeguard policy to the planned investment Both the governments development plan (FASDP) and preparation of the World Banks financial assistance package are at an early stage Consequently this report covers (and can only cover) the broad principles and sets out initial conclusions It will be necessary for further reviews to be undertaken when the Government of Ghanarsquos programme has been developed in more detail Objectives of the Environmental and Social Assessment (ESA) The overall aims of planned interventions in the fisheries industry of Ghana are to improve fish stocks and increase the sustainability of fishing activity which will have long-term environmental and social benefits for the country However the process of introducing change is likely to have some short-term adverse effects on individuals and particularly those who are vulnerable or disadvantaged within poorer fishing communities unless appropriate mitigation measures are taken The purpose of the environmental and social assessment set out in chapter 6 is to identify potential environmental and social impacts both individually and cumulatively and to assess their relative magnitude duration reversibility and importance Based on these findings the draft management framework (see chapter 8) sets out proposals for avoiding or mitigating unacceptable change The process of reforming the fisheries sector will take a number of years and the existing FASDP covers only the first five years With the exception of proposals to scale down the size of the industrial and semi-industrial fishing fleets it is unlikely that major changes will take effect in terms of fishing activity during this five-year period Consequently from the standpoint of the World Banks investment there are likely to be relatively few issues in terms of potential conflict with safeguarding policies Later
8
however significant change is within the fishing industry and particularly onshore processing and marketing of fish products An important element in this report has therefore been the need to define the point at which the banksrsquo responsibilities are seen to terminate and all liabilities are transferred to other supporting donors and the government of Ghana In the short term a reduction in the industrial fleet may lead to the loss of 1000 to 3000 jobs for crew members although in practice most of this work is only part time and many of the vessels that are due to be withdrawn are no longer seaworthy In the longer term it is intended to encourage more selective fishing by limiting open and unfettered access to fish stocks eliminating illegal and damaging processes including dynamiting uncontrolled light fishing and the use of small size monofilament nets and introducing seasonal restrictions to protect breeding cycles The intention is that these measures will be managed jointly by the government and communities through co-management systems At the same time major efforts will be made to reduce the level of post-harvest losses and to increase the value of fish products The expectation is that the number of industrial semi-industrial vessels and canoes will be stabilised at a fixed lower level within five years Once this point is reached and no further licences are granted individual licences will acquire higher values especially as fish stocks recover and the size and value of fish catches starts to increase Subsequently licenses are likely to be sold and traded as less efficient owners drop out of the market and sell on to stronger individuals and companies In terms of onshore activities fish landing processing and marketing will become more efficient and losses will be reduced through use of better smokers freezing and drying equipment Previous studies in West Africa and elsewhere (Bennett et al 2001) have shown that the transition away from open access to a more regulated system of access management can give rise to social risks Specifically older men are likely to be displaced when they are no longer fit enough to withstand the rigours of fishing while a rising number of young men may find it harder to enter a career in fishing Women who currently manage or assist with all areas of buying processing and marketing using traditional clay ovens may also experience competition as new companies and enterprises are established to take advantage of higher profitability in the fishing sector perhaps using better equipment newer technologies and different logistics arrangements or their own transportation Methodology This study has followed the methodology developed within the process framework for the West Africa regional fisheries programme (WARFP) Figure 1 sets out both sequence and timescale for the work
The range of jobs at risk is based on assumptions about the number of vessels and average crew size and cannot be determined with any degree of accuracy until the necessary surveys are undertaken
9
The report is based on three major areas of activity 1 documentary analysis and utilisation of the studies already carried out by the fisheries commission 2 meetings with institutional stakeholders principally affected by the project and 3 Consultations and visits to some of the key fishing villages and communities The planned presentation of findings to Stakeholders has been postponed at the Clientrsquos request due to other pressing commitments in the agriculture and fisheries sectors This presentation will however need to be subsequently undertaken by the Ministry and the Fisheries Commission
11
CHAPTER 2 PLAN AND PROGRAMME DESCRIPTION
INTRODUCTION This chapter is divided into two parts Part 1 sets out the progress which the government Ghana is making in giving effect to the legislation policy and regulations Part 2 describes the proposed programme of assistance being offered by the World Bank with the specific aims of strengthening governance and enforcement systems (Components 1 and 2) and in promoting value addition and reduction of post-harvest losses
PART 1- THE DRAFT FISHERIES AND AQUACULTURE SECTOR DEVELOPMENT PLAN (FASDP) This plan (FASDP) covers the period 2010-2015 It recognises the importance of Ghanarsquos fisheries which generate in the order of US$ 1 billion a year contribute 45 to GDP and indirectly support the livelihoods of 22 million people However through over-fishing and lack of investment in management and value addition the average income per canoe has dropped by up to 40 over the last ten years to the point where it costs as much to fish as the catch is worth By comparison well managed fisheries in other parts of the world are capable of generating economic returns of 30-60 on investment (equivalent to a potential income of US$ 300 million a year for Ghanarsquos fisheries) The Draft FASDP acknowledges that the fishing sector is expected to make a substantial contribution towards doubling the size of the Ghanaian economy by 2015 (GPRS II) as part of the Republic of Ghana Fisheries and Aquaculture Policy Seven targets are set in the draft FASDP 1 Maintaining capture fisheries production at current levels 2amp3 Increasing revenue and profitability in capture fisheries by at least US$ 50 million a year after
five years 4 Increasing aquaculture production to 35000 tonnes a year after five years 5 Retaining Ghana as a landing and processing hub for the West Africa tuna industry 6 Developing fisheries management to allow effective control of all commercial fishing effort in
Ghanaian waters and 7 Ensuring fisheries management costs are sustainable and that the fisheries sector overall make a
fiscal contribution to Government revenues There is an underlying presumption that the canoe sector will remain at the heart of Ghanarsquos fishing industry but the plan is not prescriptive and leaves open the ways of achieving the overall goals At the same time there is an underlying assumption that the long term sustainability of Ghanarsquos fisheries will depend upon discouraging further entry by new operators
PART 2 THE WORLD BANKrsquos CONTRIBUTION TO GHANA FISHERIESPLAN (FASDP)
The essential aim of the World Bankrsquos contribution to FASDP is to provide investment which will build the necessary policy and capacity for effective fisheries management designed to reduce fishing effort while maintaining approximately the same catch levels and to address the impacts of change for fishers
12
and the communities in which they live Based on the currently available draft Project Appraisal Document (PAD) each of the components is now described in turn Component 1 - Good governance and sustainable management of the fisheries This component on good governance comprises four subcomponents which are broken down in turn into a number of separate activities Sub-component 11 developing the capacity rules procedures and practices for good governance of the fisheries Activity 111 reviewing the Fisheries Act and developing regulations to support the Sector Policy and the Fisheries and Aquaculture Sector Development Plan Activity 112 Developing an operational policy to enable implementation of the aquaculture and fisheries sector development plan Activity 11 3 strengthening fisheries management systems and capability (fisheries management plan development aquaculture implementation technical support and training) Activity 114 strengthening fisheries Information Systems (catch recording and monitoring systems statistical analysis and training)
Sub-component 12 introducing fishing rights
Activity 121 developing pilot stakeholder-based fisheries management initiatives around defined fisheries units (ie local management initiatives tighter defining fisheries resources in up to 6 selected Fisher communities) Activity 122 introducing and administering a licensing regime
Subcomponent 13 Adjusting fishing effort and capacity to more sustainable levels marine resource conservation and supporting alternative livelihood opportunities when needed Activity 131 vessel decommissioning Activity 132 compensation packages for crew of decommissioned industrialsemi-industrial vessels Activity 133 alternative livelihood development to incentivise voluntary capacity reduction in the canoe sector Activity 134 marine resources management and conservation
Subcomponent 14 social marketing communication and transparency Activity 141 communications stakeholder consultations and awareness raising programmes to support fishery development Component 2 reduction of illegal fishing Under the West Africa regional fisheries programme subcomponent 21 allows for enabling environment for reduction of illegal fishing These provisions already exist within Ghana and this subcomponent is therefore omitted Subcomponent 22 monitoring control and surveillance (MCS) systems Activity 221 developing compliant systems and capability
13
Component 3 increasing the contribution of the marine fish resources to the local economies Subcomponent 31 product diversificationvalue chain development (freshfrozen producttrade facilitation) Activity 311 landing site development Activity 312 Port development Subcomponent 32 fish product trade infrastructure information and systems - regional minimum integrated trade expansion platform (MITEP) Activity 321 export certification centre development Activity 322 fish processing technology improvements Activity 323 national fisheries advisory group Subcomponent 33 marine and inland aquaculture development Activity 331 space developing aquaculture policy and legal framework Activity 332 improving genetic policy of tilapia fingerlings and breedstock Activity 333 catalysing aquaculture development Component 4 Coordination monitoring and evaluation and program management Subcomponent 41 national implementation subcomponent 42 regional coordination Each of the components sub-components and activities are described in more detail in Chapter 5 which assesses the nature of environmental and social safeguards issues in terms of the World Bankrsquos planned investment
15
CHAPTER 3 BASELINE CONDITIONS
INTRODUCTION This chapter discusses the existing fishery resources of Ghana and describes recent environmental and social trends It identifies some of the pressures that led to the reduction in value of fishing activity and indicates the threats that could be posed if no action is taken in accordance with the planned fisheries and aquaculture program to deal with them FISHERY RESOURCES The continental and coastal waters of Ghana are potentially very rich due to a combination of warm waters and nutrients carried in ocean currents which up-well seasonally on the continental shelf The tonnage of fish caught in marine waters peaked in the mid-1990s around 500000 tonnes and currently averages around 400000 t(See Figure 1) Figure 1 Wild Capture Production in Ghana 1950-2005
2
Table31 Top 10 Species Exported (by value)
1 Canned tuna ($72000000) 2 Fresh tuna ($7200000) 3 Tilapia (no figure available) 4 Miscellaneous dried fish ($1000000) 5 Salmonids frozen ($900000) 6 Marine fish frozen ($600000) 7 Cuttlefish and squid ($600000) 8 Shrimps and prawns ($90000) 9 Sardines ($80000) 10 Crustaceans frozen ($50000) Source FAO Fishstat
The principal catch from deep waters is tuna Industrial vessels registered in Ghana target these species in international waters but also illegally in coastal waters Herring sardine and anchovies are fished in coastal waters by semi-industrial vessels and canoes Table 31 shows the top 10 species of fish exported from Ghana in 2005 PROFILE OF THE FISHING INDUSTRY Fishing is of vital importance in Ghana not only in terms of its contribution to gross domestic product (45 per annum) but because fish provides 65 of the countrys protein In recent years (between 2003-2008) and more specifically in 2004 the countryrsquos annual fish requirement has been estimated to be 882000 tonnes of which the country produces just about half (Tetteh 2007) Of the total population of 22 million people it has been estimated that between 15 and 22 million people are employed or gain their livelihoods from fishing (8-10) Of these there are 210000 men who are directly employed as
2 This figure is the Fisheries Departmentrsquos estimate for 2008
16
fishers The total export of seafood was valued US$824 billion in 2005 Ghanas fishing industry can be divided into three sections marine capture inland capture and aquaculture It can be further analysed by scale of operations distinguishing between industrial semi-industrial and artisanal sectors Marine fisheries Industrial sector Commercial fishing for tuna began in 1962 In the early 1980s Ghana sought to develop an industrial fishing fleet and there are currently 90 industrial trawlers and other vessels which are located in Tema and Takoradi Sekondi The port of Tema was expanded from 1962 to create four main areas the Inner Harbour Outer Harbour Canoe Basin and Commercial Area In 1999 fish landing facilities were improved at the Albert Bosumtwi Sam Fishing Harbour built in Sekondi This harbour is equipped with a cold store an ice-making plant offices a berthing bay for inshore vessels a jetty for canoes and a net drying area Under Ghanaian law more than 50 of the ownership of industrial vessels must be registered with a Ghanaian company or individuals However in practice many vessels are owned by foreign nationals with token Ghanaian ownership Relatively few of these large vessels regularly put to sea and a number are in poor condition or obsolete Nevertheless the impact of trawling activities by Ghanaian registered and foreign owned vessels has been very considerable in coastal waters in recent years Fish landed from industrial vessels is usually transferred directly to Canning factories in Tema and Takoradi Ghana has the largest canning industry in West Africa In the region of 30000 tonnes of tuna are landed In addition to trawling some industrial vessels are engaged in shrimping the use of tuna lines and polls purse seining and demersal trawling Semi-industrial sector in addition to deep sea trawlers there are around 230 large semi-industrial ships propelled by inboard motors which are used for trawling in shallow waters during the off-season and purse seining during upwelling seasons There are currently reported to be 48 bottom trawlers 14 pair trawlers 2 shrimpers 33 pole and line vessels and 10 tuna purse seiners operating from 2 of the 7 landing sites Canoe sector Ghanas artisanal fishing sector is based on between 10000 and 12000 wooden canoes Fifty seven per cent of the fleet is powered by outboard motors supported by paddle and occasionally sail Each Canoe carries a crew of between three and 20 men depending on size and length There are over 334 landing sites along the 550 km coast of Ghana and the majority of fish caught by canoe (180000 tonnes) is returned to these sites accounting for 70 of Ghanarsquos fish production The principal landing sites are at Teshie Jamestown Chorkor Shama Axim Elmina Winneba Mumford Akplabonya Adina Atiteti Abutiakope and more Fishing is undertaken by men but the majority of canoes are owned by women who pre-finance fishing trips (purchasing gear and premixed fuel) and purchase the catch Women also predominate in processing and marketing fish and fish products Only about 20 of fish sold fresh a further 20 is salted and the majority (60) is smoked It is estimated that up to 30 of the catch is spoilt through lack of ice for storage or alternative processing facilities
17
Inland fisheries Water Resources Ghanarsquos inland fishery resources consist of a natural lake( Lake Bosomtwe) and nine major river basins which from east to west of the country are
bull the Volta bull Densu bull Ayensu bull Ochi bull Kakum bull Pra bull Ankobra and bull the Tano
The River Tano forms the border between Ghana and Cote drsquo Ivoire The largest of the rivers is the Volta which drains more than two-thirds of the country through several large tributaries in virtually all regions of the country The Volta river system also incorporates the Volta reservoir generally known as the Volta Lake which has a surface area of around 8400 km2 The Volta lake discharges through the Akosombo dam before flowing through a delta into the Atlantic Ocean The eight other river systems are relatively smaller simpler and open more directly into the Atlantic There are also several reservoirs created on the smaller river systems mainly for potable water production irrigation and flood control These reservoirs irrespective of their primary purposes enhance availability of more permanent aquatic habitable space for fish and therefore support some fisheries Finally with all the river systems opening into the Atlantic there are a series of lagoons and estuaries which act as interfaces between the rivers and the sea These water areas constitute another type of inland water resource for salt and brackish water fishes Inland Fish resources Within the inland water resources of Ghana there are over 150 fish species more than 90 of which are fished for food
In commenting on inland fisheries in Ghana it must be noted that virtually all available information on inland fisheries is obtained from the Volta Lake No national fish production records have been kept on the fisheries of the eight smaller river systems and the lagoons and estuaries Thus the usual statement that inland fish production constitutes about 20 of what the country produces should refer to fish production from the Volta Lake In practice the total inland fish contribution could more realistically be estimated at about 30-35 of national fish production This is a very considerable but understated contribution to national food security and nutrition
Fishing vessels The dominant fishing vessel on the Volta Lake is the canoe the majority of which are built from wooden planks On some other river systems while plank canoes predominate a small number are carved as dug-outs from single tree trunks There is some variety in sizes of the canoes depending on how many planks are used to build the boat and the size of tree trunk used in building a canoe The total number of canoes estimated on the Volta Lake during a survey in 2000 was 24035 On the tributary rivers of the Volta Lake and other river systems in the country the planked canoe is the main vessel used in fishing
18
Fishing gear There are about eleven main kinds of gear used for fishing on the Volta Lake They are Gill Nets Cast Nets Hook and Line Basket and wire mesh traps Winch net Beach seine Bamboo Nifa-nifa Wangara Spears and Atidzas On other rivers in the country Gill nets Cast nets Hook and Line and traps are the fishing gear used On both the lake and rivers the Gill net is the main gear
People Involved In the 2000 frame survey of the Volta Lake conducted by the Fisheries Directorate of Ghana the estimate of fishers on the Volta Lake was put at 71861 Fishers on the lake work in collaboration with a host of fishmongers or handlers who also function as wholesalers for individual fishing groups Assuming that the fisher population on the lake has increased by a modest 3 in the ten years from 1998 to 2010 a fisher population of about 93500 could be considered to be on the Volta Lake now If again it is estimated that number of fishers on rivers in the country were to be a tenth of those on the lake this would put the fisher population on inland waters (apart from the Volta Lake) at about 9350 fishers A very conservative estimate therefore puts the total number of individuals who are directly engaged in inland fishing at over 100000 This excludes all directly associated groups such as fish handlers processors and traders An estimate of secondary fisheries operators such as boat builders out-board motor operators and mechanics as well as bulk salt and fuel wood sellers and those engaged in buying selling and distributing fish would have to be considered in developing estimates for both direct and indirect employment in inland fisheries but the number can be assumed to lie between 125000 and 150000 people
Aquaculture Under Ghanarsquos legal framework aquaculture is defined as ldquoany activity designed to cultivate or farm fish and other aquatic living resourcesrdquo Currently only fin fishes are involved in aquaculture in Ghana
Current culture media and environment Currently fish culture takes place almost exclusively in fresh water in Ghana either in cages brush parks or dugouts Dug-outs are excavations made in floodplains in the savannah parts of the country were water scarcity has been a major hindrance to development in general and food security in particular Dug-outs get filled with flood waters and whatever the water carries during major wet periods of a year in the savannah areas Waters that fill Dug-outs invariably contain fish which are trapped in the Dug-out after the wet period These water bodies are managed until the end of the dry period and the fish are harvested before the next flood period Since the 1960rsquos various strategies to augment fish production from Dug-outs have been developed and tested These involve adding fingerlings of selected fish species to those which are lsquonaturally stockedrsquo in Dug-outs by floods Dug-outs are the major fish culture production approach in the savannah parts of the country which accounts for a little more than half the area of the country The Environment of fish culture Currently fish culture is taking place mainly in freshwater environments Brackish water fish culture and mari-culture activities which will bring lagoons estuaries and the sea into fish culture production have long term potential for development Fishes in culture Fishes being cultivated in Ghana In order of importance are Nile tilapia Oreochromis niloticus the African catfish Clarias gariepinus species of the catfish Heterobranchus and the Bony tongue Heterotis niloticus Scale of Culture Based on level of production fish culture operations can be categorized as follows
bull Large scale commercial where an enterprise produces up to 10000 tonnes per year
19
bull Medium scale commercial where a single enterprise produces between 50 and 500 tonnes bull Small scale commercial where an enterprise produces between one and 20 tonnes and bull Very small scale commercial with productions below 20 tonnes
Fish culture production Cultured fish contribution to national production was officially stated as 9000 tonnes for the year 2009 However informed opinion amongst fish farmers indicates that a figure of between 16000 and 20000 tonnes in 2010 would be closer to reality This statement is based on the facts that most producersrsquo published figures are underestimates several small to medium scale producers are not recorded in official lists and the recording of newly established fish farms has lagged actual establishment especially since 2009 Although cultured production up till 2009 may not have been significant considering a shortfall of about 460000 mt (as recorded in 2004) between captured fish production and national demand this reflected the fact that there were only two large scale commercial producers in the country each of which had had less than ten years of operation Anticipated growth in fish culture production within the next five years is expected to be dramatic as some of the critical challenges of the industry are resolved
CHALLENGES AND PROSPECTS Marine Fisheries The fishing sector is vital for food security and job creation to help alleviate rural poverty in Ghana However the levels of fisheries harvests are generally considered to be close to or to have exceeded the maximum sustained yield Future sustainability in the industry will depend upon the restriction of open access to fisheries and the introduction of management systems which allow fish stocks to recover and the establishment of consistent yields in both marine and inland waters Inland Fisheries Environmental conditions on the Volta Lake constitute the major environmental and social challenges for fisheries its sustainability and profitability In terms of future prospects success will depend heavily on implementation of the lsquoGhana Fisheries and Aquaculture Sector Development Planrsquo and the capacity of the system in Ghana to enforce the Fisheries Regulations passed by parliament in August 2010 Aspects of the Development plan that offers great prospects for the lakes fisheries include the provisions for eventually licensing boats (although the scale of this task should not be underestimated) and measures to involve communities in management of fisheries resources of the Lake
Aquaculture The main challenges facing aquaculture development in Ghana relate to bull The high cost of fish feed (significantly due to its importation from other countries) bull None availability of commercial fish hatcheries as enterprises bull Lack of a nation-wide distribution network for fish seed and cultured fish producers Most
sources of fingerlings are concentrated in one part of the country and since farms all over Ghana obtain their fingerlings individually transportation costs add significantly to overall production costs
bull Now emerging certification and monitoring to check the health and safety of aquaculture processes and products
bull The absence of adequate regulations regarding establishment of an aquaculture enterprise until August 2010 (In the absence of regulations only the large and medium scale commercial farms worked towards conforming to international performance Standards and operational regulations for certification of farms and their products still remain in a draft state)
bull Low national support for research to support expansion and systematic development of aquaculture
20
The prospects for development of aquaculture as an industry in Ghana are good since a number of practical policy and legal frameworks have been put in place to resolve the basic challenges to the industry listed above These include
bull Construction of the first local fish feed plant by an international fish feed company with the expectation of having initial products on the Ghanaian market during 2011
bull A lsquoLarge scale commercial fish farmrsquo with great capacity for fingerling production is shifting emphasis to fish seed production And several localized fish seed producers are expanding operations
bull Distribution strategies by cultured fish producers have started to emerge on a limited scale and are expected to evolve with increasing production as existing commercial farms expand and new ones join in
Now that regulations regarding establishment of aquaculture enterprises have been gazetted there is likely to be a positive response amongst fish farmers of all size categories New operational standards are being prepared which will introduce minimum standards for local certification This should set the stage for preparation of fish culture products and the broadening of choice for consumers while also qualifying Ghanaian producers to enter external markets
ENVIRONMENTAL CONDITIONS The coastal and marine environment a critical zone of influence for this study comprises a 550 km coastline a coastal belt ranging from 1 to 20 km in width and coastal waters extending to 200 nautical mile limit which was established in 1977(under the territorial waters and continental shelf act 1973 as amended by the territorial waters and continental shelf amendment decree 1977) The Coastal Belt The coastal belt accounts for only 65 of the land mass of Ghana but it is one of the most densely settled areas accounting for 25 of the population and80 of the industrial establishments in Ghana Historically the coastal zone was cultivated for coconut (copra) but this industry is in decline Vegetables and other agricultural produce are grown on better soils but the principal economic activities are fishing transportation salt production and sand and stone winning Tourism also offers great potential There is considerable expectation that the discovery of offshore oil and gas deposits will bring new wealth to parts of the coastal corridor However present plans to transfer crude products to tankers at sea and then export them directly will limit industrial activity to a support role A high percentage of industrial and municipal wastes is dumped at landfill sites within the coastal zone which creates pollution risks The coastal belt is generally a low-lying area less than 200 m above sea level Vegetation types reflect the rainfall gradient and consist of coastal shrub and Savannah to Winneba southern marginal forest to the east of Sekondi dry semi-deciduous and moist semi-deciduous forest to the east of Cape Three Points estuary and wet evergreen forest in the extreme south Soils are variable within this area ranging from fertile pockets river valleys to Sandy poorer quality soils close to the sea The Coast The coast line divides into three sections (Ly 1980)
bull West of Cape Three Points this area has a wide and flat beaches backed by coastal lagoons and
21
wave heights are generally low bull Between Cape three points and Tema the coast consists of a series of rock headlands enclosing
shallow bays together with sandbars or spits enclosing coastal lagoons The surf zone is a medium to high energy environment with wave heights often exceeding 1 m South-westerly prevailing winds give rise to longshore drift in an easterly direction
bull Between Tema and Aflao most of the shore is sandy although there are rocky outlets The coastal zone is important internationally in providing feeding roosting and nesting sites for thousands of migratory birds Environmental degradation is significant in Ghana and is recognized in the countryrsquos environmental action plan It contributes to rising poverty levels coupled with poor human health and inadequately planned urbanization which fuel a vicious cycle inhibiting human development The core issues include
bull Domestic sanitation bull Increased urbanization without appropriate infrastructure bull Wetlands and mangrove degradation bull Coastal erosion and bull General biodiversity loss
Briefly each of the above could directly or indirectly adversely influence fisheries and aquaculture separately or together For example in a recently completed study of water quality scenarios of the Volta Lake in relation to fish production as a component of a comprehensive study (The Challenge Program Project of Water amp Food) it was concluded among others that poor sanitation in highly populated fisheries communities adversely influenced water quality to the detriment of fish life and thus fish production With reference to aquaculture the same unsanitary conditions in highly populated shore communities adversely influenced water quality especially in terms of oxygen depletion when lake waters extend to the shore in high water periods This is a situation which has caused fish kills in cages because caged fish cannot escape lsquopollutedrsquo waters Degradation of wetlands and mangroves leads directly to a reduction in their capacities as spawning and nursery zones for both marine and inland water fishes which reduce fish production in both environments The situation outlined above is often contributed to by anthropogenic and industrial pollution due to urbanization without appropriate infrastructure Another issue linking human activity to a deteriorating environment is demonstrated by the encroachment of aquatic weeds on inland waters such as the Volta Lake Weed growth is accelerated by farming reservoir catchments which increases nutrient levels and the building of dams which reduce or cut off intrusion of sea water into rivers Currently as climatic change observable impacts such as floods seem to escape predictions The project could possibly contribute to mitigating against direct and indirect effects of climate change on fishing and aquaculture through investment into climate change orientation and education of fishers and fish farmers to mainly influence reasonable precautions they take Marine waters The continental shelf is relatively narrow projecting out to 25-35 km except in the area of Cape Coast to Salt Pond where it extends to almost 80 kms Sandy and rocky substrates which previously supported coral and seaweeds have been severely affected by former trawling activity which indiscriminately
22
dredges material from the seabed Coastal waters are enriched by freshwater discharges from the relatively small number of rivers and by two seasonal up-wellings which occur between late June and early October (the main upwelling) and January and March (the minor upwelling) The origin and driving mechanisms of these up-wellings are not fully understood and both their location and strength varies from year to year
Lake Volta and other inland water
Major environmental issues on the Volta Lake which might also be considered as challenges to sustainable fisheries on the major inland fisheries resource can be summarised as follows
bull The Volta Lake is known to be low in nutrients It therefore has low standing crops of phytoplankton and zoo plankton to support high fish production
bull The northern segment of the lake together with tributary rivers constitute the spawning and feeding grounds for majority of fish species in the lake during the wet season however these segments are intensely fished during the same period
bull The Volta Lake is divided into eight unequal strata with different distribution of boats per Km2 At the last estimation of carrying capacity in 2000 stratum V and II had the highest (527) and lowest(157) number of boatsKm2 respectively
bull The rate of siltation in the lake is considered to be increasing due to erosion associated with high rates of deforestation
bull A major challenge exists in getting fishers fishing communities and fishing entrepreneurs to understand and comply with fishing regulations aimed at conserving fish and fisheries resources
bull There is a lack of resources studies and research to support fisheries management of the Lake
bull High illiteracy exists amongst lake shore communities
bull Open access to the fish resources of the Lake has been in operation since its formation
bull Declining fish yields are occurring in the lake (468 Kgha in 1976 to 320 Kgha in 2003-MOFA) brought about by the constraints listed above
bull The commonly assumed estimate of potential fish production from the lake of around 75500 mtyr) is considered to be a serious underestimate since Stratum VII alone was estimated to produce 33800mtyr in 1996
bull The policy environment for aquaculture is currently strongly supportive of the industry and related enterprises
bull There is good quality and more than sufficient water to allow some kind of aquaculture to be developed in every region of the country with the Volta lake (about 8400 Km2) as the single most important water unit for fish culture Currently it appears that the free access to the fish resources of the lake has to some extent been applied to establishment of small scale caged fish culture enterprises a situation constituting environmental risk to investments of large scale commercial fish culture establishments in the lake
bull The Volta Lake is low in nutrients (Obeng 1964) resulting in a situation where higher fish yields could be sustained if greater quantities of fish feed were available
23
bull In Ghana the Nile tilapia O niloticus occurred naturally only in the Volta system Due to positive culture characteristics of the fish it has been moved into virtually all other river basins in the country The situation provides opportunities for hybridization of the Nile tilapia with other tilapia species native to the river basin into which the Nile tilapia has been moved
25
CHAPTER 4 POLICY AND LEGAL FRAMEWORK FOR ENVIRONMENTAL AND SOCIAL ISSUES
41 INTRODUCTION
Development and implementation of the Ghana Fisheries and Aquaculture Sector Development Plan and the World Bankrsquos supporting program need to be developed with full regard to existing international conventions national legislation policies and regulations This chapter highlights the main legislative and policy considerations for the protection of the environment natural resources fisheries and social and economic development It begins with reference to the World Bankrsquos safeguard framework and those of other donors This is followed by a section on the governance framework in Ghana
42 WORLD BANK AND OTHER DONORSrsquo SAFEGUARDS POLICIES
The World Bankrsquos safeguard policies exist to ensure that all projects which it finances are developed and implemented on environmentally and socially sound principles A range of different policies exist and these have been carefully considered to ensure that the Ghana Fisheries and Aquaculture Development Sector Development Plan complies with these safeguards All policies have been screened and those that have no bearing on the fisheries programme have been excluded from Table 41 below Table 41 lists policies which could have some applicability to the FASDP even if this interaction might be very slight It is important to stress that the comments in the third column of Table 41 relate to the entirety of the Fisheries and Aquaculture Sector Development Plan whose effects will continue to be experienced long after the World Bankrsquos financial support has been expended Most of the activities in the FASDP will have no effect in relation to safeguard objectives and where there are implications these are likely to occur at precise locations (for example at fish landing sites) rather than throughout the industry Where potential interactions have been noted the necessary mitigating measures are incorporated in the Draft Process Framework
Table 41 World Bank Safeguard Policies in Context
Safeguard Policy
Safeguard Policy Objective Brief Description and relevance to FASDP
OP 401 Environmental Assessment
This policy aims to ensure that Bank-financed projects are environmentally sound and sustainable and that the decision-making process is improved through appropriate analysis of actions and mitigation of their likely environmental impacts This policy is triggered if a project is likely to carry potentially adverse environmental risks and impacts on its area of influence OP 401 covers impacts on the natural environment (air water and land)
The majority of actions planned under FASDP will be beneficial to the marine environment and to inland waters However new construction activities could have impacts and depending on the project and the nature of impacts a range of instruments can be used to ameliorate and mitigate adverse effects while enhancing beneficial effects These include EIA environmental audit risk assessment and environmental management plans (EMP) The need for EIA and EMP is considered in this report
26
OP 404 Natural Habitats
This policy recognizes that conservation of natural habitats is essential to safeguard their unique biodiversity and to maintain environmental services and goods for human society and for long-term sustainable development The Bank therefore supports the protection management and restoration of natural habitats in its project financing as well as policy dialogue and economic and sectoral work Natural habitats comprise many types of terrestrial freshwater coastal and marine ecosystems They include areas lightly modified by human activities but retaining their ecological functions and most native species
This policy is triggered by any project (including any sub-project under a sector investment or financial intermediary) with the potential to cause significant conversion (loss) or degradation of natural habitats whether directly (through construction) or indirectly (through human activities induced by the project) This policy is applicable to the Ghana Fisheries Programme because the project focuses on the integrated management of natural habitats However by screening all proposals under the ESMF any sub-projects that might impact these habitats will not be funded
OP 409 Pest Management
The objective of this project is to (i) promote the use of biological or environmental control and reduce reliance on synthetic chemical pesticides and (ii) strengthen the capacity of the countryrsquos regulatory framework and institutions to promote and support safe effective and environmentally sound pest management
The policy is triggered if (i) procurement of pesticides or pesticide application equipment is envisaged either directly through the project or indirectly through on-lending co-financing or government counterpart funding (ii) the project supports an activity requiring the use of pesticides that may have negative effects on the environment The only instance in which this policy might be triggered by the Ghana Fisheries Programme is if aquatic herbicides or antibiotics were to be used in connection with aquaculture This is most unlikely but can be monitored through the implementation programme
OP 411 Physical Cultural Resources
The policy objective is to assist countries in avoiding or mitigating adverse impacts of development projects on physical cultural resources For the purposes of this policy ldquophysical cultural resourcesrdquo are defined as movable or immovable objects sites structures groups of structures natural features and landscapes that have
Under the Ghana Fisheries Programme construction and rehabilitation activities that could have negative impacts on cultural property will be avoided In the case of discovery of remains national procedures will be applied
27
archaeological paleontological historical architectural religious aesthetic or other cultural significance
OP 412 Involuntary Resettlement
The objective of this policy is to (i) avoid or minimize involuntary resettlement where feasible while exploring all viable alternative project designs (ii) to assist displaced persons in raising their former living standards income-earning capacity and production levels or at least in restoring them (iii) encourage community participation in planning and implementing resettlement and (iv) provide assistance to affected people regardless of the legality of land tenure
The policy covers not only physical relocation but any loss of land or other assets resulting in (i) relocation or loss of shelter (ii) loss of assets or access to assets (iii) loss of income sources or means of livelihood whether or not the affected people must move to another location The activities of the Ghana Fisheries Programme are likely to result in loss of assets or access to assets and loss of income sources or means of livelihood for some groups and individuals The potential for such losses will be carefully scrutinised and compensated for through the National Process Framework and Resettlement Policy Framework described in this report and appropriate procedures will be followed where necessary
Other donors and aid agencies including International and National NGOs play an active role within the fisheries sector in Ghana and their safeguards standards will be observed through operation of the Environmental and Social Safeguards Management Plan
28
43 THE GOVERNANCE FRAMEWORK IN GHANA
The Ministry of Food and Agriculture (MOFA) Preparation of Fisheries laws and policies fall under the responsibilities of the Minister of Food and Agriculture who in turn delegates functions including implementation to a semi-autonomous body the Fisheries Commission
The Fisheries Commission (FC) was established under the Fisheries Commission Act (625 2002) It oversees management regulation and utilisation of the fisheries resources of Ghana drawing on powers set out in the Fisheries Law (PNDC 256 1991) Fisheries Act 625 provided for the establishment of a more robust Fisheries Commission (FC) which is an amalgamation of the erstwhile FC and Department of Fisheries
Ten individuals constitute the Board which is led by a chairman (appointed by the President of Ghana in consultation with the Council of State) supported by three members drawn from the ministries of transport defence and environment There are three representatives from the following parastatal organizations - the Ghana Marine Fishing Officers Association Water Research Institute and Ghana Irrigation Development Authority- and two representatives (one from the artisanal and one from the industrial sections )of the National Fisheries Association of Ghana Finally the tenth member is a person with requisite knowledge of the fishing industry or natural resources renewal management
The day to day work of the Fisheries Commission is undertaken by the Department of Fisheries (DOF) which serves as the implementation secretariat of the Fisheries Commission as stipulated by the Fisheries Act 625 of 2002 Specific tasks that are undertaken by the Department of Fisheries include
bull preparing fishery resource management plans bull developing regulations for the fishing industry bull organizing monitoring surveillance and enforcement for the national fishery resources and
ensuring compliance with national fisheries law and institutionalizing co-management concepts
The MCS Division of the DoF (established under the Fisheries Sub sector Capacity Building project) works in conjunction with the Ghana Navy and undertakes sea patrols to exclude industrial fishing vessels from the 30-metre depth IEZ reserved for artisanal fisheries The MCS also conducts inspection of industrial vessels at the fishing ports of Tema and Takoradi for
bull valid fishing licences bull legality of fishing gear bull skipperrsquos certificate bull log book and crew composition
The MCS undertakes similar functions for inland fisheries on Lake Volta
The Ministry of Local Government and Rural Development (MLGRD) is responsible for managing fishers fish processors and fishery resources at district and sub-district levels which it undertakes through the District Assemblies In 2002 the District Assemblies in collaboration with DoF were mandated to facilitate fishery resource management by
bull helping to form and sustain Community Based Fisheries Management Committees (CBFMCs) bull cooperating with the DoF MCS units bull providing legal and financial support to the CBFMCs and bull approving levies proposed by the CBFMCs
29
Community-Based Fisheries Management Committees are charged with the responsibility of enforcing national fisheries laws at community level as well as initiating and enforcing their own by-laws
44 THE LEGAL FRAMEWORK
441 International Conventions
Ghana has ratified a number of international conventions and treaties which have an important bearing on the state of its marine and inland waters and the condition of the fisheries These are listed in Box 1 below
Box 1 International Conventions treaties and agreements to which Ghana is a signatory 1 International Convention for the Prevention of Pollution of the sea by Oil 21 October 1962 2 Convention on the Africa Migratory Locust 25 May 1962 3 Treaty Banning Nuclear Weapon Tests in the Atmosphere in Outer Space and Under Water 5th August 1963 4 International Convention for the Conservation of Atlantic Tunas 4 May 1966 5 Africa Convention on the Conservation of Nature and Natural Resources 15 September 1968 6 International Convention on Civil Liability for Oil Pollution Damage 29 November 1969 7 International Convention Relating to Intervention on the High Seas in Cases of Oil Pollution Causalities 8 Convention on Wetlands of International Importance Especially as Waterfowl Habitats 2 February 1971 9 Treaty and Prohibition of the Emplacement of Nuclear Weapons of Mass Destruction on the Seabed and the Ocean Floor and in the Subsoil Thereof 11 January 1971 10 International Convention on the Establishment of an International Fund for Compensation of Oil Pollution Damage 18th December 1971 11 Convention Concerning the Protection of World Cultural and Natural Heritage 16 November 1972 12 Convention on International Trade on Endangered Species of Wild Fauna and For a 3 March 1973 13 Convention on the Military or Any other Hostile Use of the Environmental Modification Techniques 10 December 1976 14 Convention on the Conservation of Migratory Species of Wild Animals 23 June 1979 15 Convention for the Cooperation in the Protection and Development of the Marine and Coastal Environment of the West and Central African Region1981(Abidjan Convention) 16 United Nation Convention on the Law of the Sea 10 December 1982 17 Montreal Protocol on Substances that Deplete the Ozone Layer 24 July 1989 18 Convention to Combat Drought and Desertification 19 Framework Convention on Climate Change June 1992 20 Convention on Biological Diversity1992 442 Environmental-Related Conventions Environmentally related conventions ratified by Ghana include
bull International Convention for the Prevention of Pollution of the sea by Oil 21 October 1962
bull Convention on the Africa Migratory Locust 25 May 1962 Treaty Banning Nuclear Weapon Tests in the Atmosphere in Outer Space and Under Water 5th August 1963
bull International Convention for the Conservation of Atlantic Tunas 4 May 1966 bull Africa Convention on the Conservation of Nature and Natural Resources 15 September 1968 bull 992256International Convention on Civil Liability for Oil Pollution Damage 29 November
1969 bull International Convention Relating to Intervention on the High Seas in Cases of Oil
30
Pollution Causalities bull Convention on Wetlands of International Importance Especially as Waterfowl Habitats
2 February 1971 bull Treaty and Prohibition of the Emplacement of Nuclear Weapons of Mass Destruction
on the Seabed and the Ocean Floor and in the Subsoil Thereof 11 January 1971 bull International Convention on the Establishment of an International Fund for
Compensation of Oil Pollution Damage 18th December 1971 bull Convention Concerning the Protection of World Cultural and Natural Heritage 16
November 1972 bull Convention on International Trade on Endangered Species of Wild Fauna and For a 3
March 1973 bull Convention on the Military or Any other Hostile Use of the Environmental
Modification Techniques 10 December 1976 bull Convention on the Conservation of Migratory Species of Wild Animals 23 June 1979 bull Convention for the Cooperation in the Protection and Development of the Marine and
Coastal Environment of the West and Central African Region1981(Abidjan Convention)
bull United Nation Convention on the Law of the Sea 10 December 1982 bull Montreal Protocol on Substances that Deplete the Ozone Layer 24 July 1989 bull Convention to Combat Drought and Desertification bull Framework Convention on Climate Change June 1992 bull Convention on Biological Diversity1992
443 National Legislation
The principal national legislation that affects fisheries in Ghana is listed below
1 Fisheries Regulation 1984 LI 1294 2 Fisheries (Amendment) Regulation 1977 3 Maritime Zones (Delimitation) Law 1986 4 PNDC Law 256 of 1991 5 Fisheries Commission Act of 1993 and 6 Fisheries Act 625 of 2002 7 Fisheries Regulations passed in 2010 LI 1968
Other laws that have relevance to the fisheries sector include
1 Wild Animals Preservation Act 1961 (Act 43) 2 Volta River Development Act 1961 (Act 46) 3 Ghana Water and Sewerage Corporation Act 1965 (Act 310) 4 Oil in Navigable Waters Act 1964 (Act 235) 5 Irrigation Development Authority Decree 1977 (SMCD 85) 6 Minerals and Mining Law 1986 (PNDCL 153) 7 Environmental Protection Agency Act 1994 (Act 490) 8 Ghana Highway Authority Act 1997 (Act 540) 9 Timber Resources Management Act 1998 (Act 547) and 10 Minerals and Mining Act 2006 (Act 703
31
434 Policies A number of Environmental related Policies exist in Ghana however there is no specific policy on the coastal zone These include
bull The National Environment Policy bull National Wetlands Policy bull Agricultural Policy bull Tourism Development Policy bull Land Management Policy bull National Health Policy bull Energy Policy bull Minerals Policy bull Wildlife Conservation Policy
The main thrust and orientation of national policies on the protection management and development of the marine and coastal environment focuses on the following three major areas
bull Integrated coastal zone management and sustainable development bull Marine environmental protection both from land-based activities and from sea-based
activities and bull Sustainable use and conservation of marine living resources (both of the high seas and
under national jurisdiction) Specific plans have been developed to ensure the realization of prudent management of the marine and coastal environment These include
bull Coastal Zone Management Indicative Plan 1990 bull National Environmental Action Plan 1994 bull Draft Integrated Coastal Zone Plan 1998 bull Coastal Zone Profile of Ghana 1998 bull National Oil Spill Contingency Plan with specific reference to the marine environment
2002 bull Environmental sensitivity map of the coastal areas of Ghana 1999 and 2004
Despite the existence of these plans active integration and coordination has been lacking in practice at local level 434 Regulations Though several legislations exist on coastal protection and sustainable development there is no omnibus legislation on the environment Legislation relating to the area include the following
bull Beaches Obstruction Ordinance 1897 (Cap 240) bull The Mineral and Mining Law 1986 (PNDC 153) bull Rivers Ordinance 1903 (Cap 226) bull Land Planning and Soil Conservation Ordinance No 32 of 1953 as Amended by the bull Land Planning and Soil Conservation (Amendment) Act 1957 (No 35 of 1957) bull Maritime Zones (Delimitation) Law 1986 (PNDCL 159) urban planning and
32
bull development bull Town and Country Planning Ordinance (Cap 84) bull Wild Animals Preservation Act Act 235 1964 bull The Towns Ordinance (Cap 86) bull National Building Regulations 1996 (LI 1630) bull Volta River Development Act 1961 bull Fisheries Act 2002 Act 625 bull Fisheries Law 1991 (PNDC 256) bull Fisheries (Amended) Regulations 1977 and 1984
The sustainable use and conservation of marine resources is encouraged through legislation regulations education and awareness creation programmes as well as the enforcement of existing regulations and legislation The legal framework for coastal zones issues and management in the country are contained in the following documents
bull The 1992 constitution bull EPA Act 1994 (Act 490) bull Environmental Assessment Regulations 1999 (LI 1652) bull Local Government Act 1993 (Act 462) bull Environmental Standards and Guidelines bull
In addition there are other specific legal frameworks which include a) The legal framework for Ecosystem Protection which are
bull Wild Animals Preservation Act 1961 (Act 43) bull Wildlife Conservation Regulations 1971 (LI685) bull Wild Reserves Regulations 1971 (LI 740) bull The Wetland Management (Ramsar sites) Regulation 1999 bull Oil in Navigable Waters Act 1964 (Act 235)
b) The legal framework for Fisheries Resources which are bull Fisheries Law 1971 (PNDCL 256) bull Fisheries Act 2000
c) The legal framework for Oil and Gas Industry bull Petroleum (Exploration and production) Law 1984 (PNDCL 84) bull Mineral (Offshore) Regulations 1963 (LI 257) bull Mineral (Oil and Gas) Regulations 1963 (LI 256) bull Oil and Mining Regulations 1957 (LI 221)
d) The legal framework for Tourism Promotion (including coastal tourism) bull Ghana investment Promotion Centre Act 1994 (Act 478) bull Companies Code 1963 (Act 179) bull Free Zone Act 1995 (Act 504) bull Ghana Tourism Board bull Ghana Commission on Culture
44 ACTIVITIES RELATING TO FISHERIES INTERESTS
33
Over the years several activities have been undertaken which are of relevance to protection of the marine environment and fisheries These include
bull Ghana Environmental Resource Management Project in Coastal Wetlands Management Component
bull Gulf of Guinea Large Marine Ecosystem Project bull Fisheries Sub-sector Capacity Building Project bull Establishment of a Protected Wetland Ecosystem on the coast bull Development and Implementation of Oil Spill Contingency Plan bull Monitoring of fish stock levels and associated oceanographic parameters bull Institution of a programme of Monitoring Compliance and Surveillance of the marine
environment bull Development of industrial pollution standards bull Development of University course on Coastal Zone Management bull Increased public education on sound coastal and marine environmental practices
45 RELEVANT INSTITUTIONS With regards to protection management and development of the marine and coastal environment a number of ministries and agencies have been identified as potential stakeholders Those shown with an asterisk are likely to have a particularly active role
bull Ministry of Environment and Science bull The Environmental Protection Agency bull Ministry of Tourism bull Ministry of Local Government and Rural Development bull Ministry of Ports bull District Assemblies bull Ghana Ports and Harbours Authority bull Hydrological Services Department bull Ministry of Food and Agriculture bull Ghana Tourist Board bull Ghana Investment Promotion Centre bull Fisheries Commission Ministry of trade Industries and PSI bull Ministry of Lands and Natural Resources Forestry and Mines bull Ministry of Energy bull Ministry of Health bull Ministry of Education Youth and Sports bull Ministry of Defence bull Ghana Navy bull Ministry of Works and Housing bull Ministry of Women and Childrenrsquos Affairs bull Ministry of Roads and Transport bull National Development Planning Commission bull Council for Scientific and Industrial Research bull Universities and Research Institutions bull Ghana Meteorological Agency bull Town and Country Planning Department bull Water Resources Commission
34
bull Ghana National Petroleum Corporation bull Volta River Authority bull Geological Survey Department bull Forestry Commission (Forestry and Wildlife Division) bull Traditional Rulers and their analogous ministry and laws
Non-Governmental Organisations including Resource Development amp Environmental Oriented Development Organisation
bull Friends of the Earth bull Green Earth bull Wildlife Society bull Recerca e Cooperazione bull Centre for African Wetlands bull And many others
46 PARTNERSHIPS Few formal partnerships exist However support for coastal conservation activities has been received from the private sector as well as from Government Regional and sub-regional collaboration efforts occur at various levels although the level of practical intervention is sometimes limited The science and technology unit of ECOWAS is engaged on issues relating to the management of the Gulf of Guinea In addition a bilateral arrangement exists between Ghana and Cote drsquoIvoire for the management of and datasharing on Sardinella stocks which migrate between the two countries The NEPAD framework among the coastal states of Africa is also developing an interest in marine and coastal management 461 Technical and financial support Ghana receives technical support in the form of training research and project implementation from national bilateral and multi-lateral sources Financing of activities in the sector is primarily supported from the national budget However donor support from both bilateral and multilateral sources has also been obtained for specific programmes such as the World Bank sponsored Fisheries Sub-sector Capacity Building Project UNOPS sponsored Environmental Sensitivity Map for Coastal Areas The Ghana Coastal Wetland Project of the World Bank UNEPrsquos WACAF Programmes and The Darwin Marine Biodiversity of West Africa Project by DFID implemented by the University of Ghana 47 ACTIVITIES Activities undertaken in the country with importance to the marine and coastal area are outlined in the following sections 471 Environment-related activities
bull Ecological Baseline studies of Korle Lagoon (1990-2000) This was carried out to satisfy EIA requirement and as a result pollution status of the lagoon was established
bull Lower Volta Mangrove Project (1996-1998) The objective is to ensure sustainable management of mangrove stands and as such baseline information was documented
bull Save the Seashore Birds Project (1985-1995) This was to protect the seashore birds and as a result conservation awareness of seashore birds was achieved
bull Ghana coastal wetlands management project (1996-1999) In this management of the five coastal wetlands designated as Ramsar Site was put in place
bull Darwin Marine Biodiversity of West Africa Project It is a training project in marine biodiversity assessment
35
472 Social-related activities bull A considerable amount of attention is currently being given to the potential impact of oil-related
development in coastal regions following the publication of Environmental and Social Impact Assessments and Management Plans relating to the Jubilee Oil Field discoveries
473 Coastal area management bull Climate and vulnerability and adaptation assessment on water resources agriculture and the
coastal zone Projects (1997-1999) The projects assessed the vulnerability of the coastal zone to climate change
bull Coastal area management plan for Princess Town (1998-2000) which aimed at providing a plan for the management of Princess Town
bull Keta Sea Defence Project Work (2000-2004) The project aimed at protecting the Keta and its environs from the episodes of erosion faced in the area and also to ensure improvement in environmental and socio-economic conditions at Keta and its immediate surroundings
474 Regional Programmes bull Gulf of Guinea Large Marine Ecosystems Project (1996-1999) The project developed an
effective approach to prevent and control pollution in the Gulf of Guinea and conserve its biodiversity As a result regional institutional capacities were strengthened and also a coastal zone management profile and plans produced
bull UNEP WACAF Projects 1 amp 2 This aims at institutionalising and coordination of national contingency plans monitoring of pollution in the marine environment and control of coastal erosion
475 Other major programmes Other recent programmes and activities in the marine and coastal environments have included
bull Ghana Environmental Resources Management Project in Coastal Wetlands bull Fisheries sub-sector Capacity Building Project bull Establishment of a Protected Wetland Ecosystem on the coast bull Development and Implementation of Oil Spill Contingency Plan bull
48 ONGOING PROJECTS Ghana is currently implementing several projects in the marine and coastal area Some of these projects are linked to developmental projects for which impact assessments are required under the Environmental Assessment Regulations of 1999 Some of the projects are large scale in nature with extensive baseline and monitoring studies like the Keta Sea Defence Project and the West Africa Gas Pipeline project Others are projects being implemented under the auspices of the United Nations agencies and non-governmental organisations include
bull Combating Living Resource Depletion and Coastal Area Degradation in the Guinea Current LME through Ecosystem-based Regional Actions
bull Amansuri Conservation and Integrated Development Project (ACID) bull Danida Water and Sanitation Sector Programme II Support to Integrated Water Resources
Management (IWRM) Component (2004-2008)The Densu Basin aspect of the IWRM component
bull Reduction of Environmental Impact from coastal tourism
bull Bui Hydro Power Project
bull Sea Defence Project at Atorkor
bull Sea Defence Projects in selected towns in the Western Region of Ghana
36
49 CONCLUDING REMARKS
This chapter has highlighted the wide range of conventions laws policies regulations and activities affecting the inland and coastal regions and inland freshwater and marine environment of Ghana It will be important to keep all of these processes and procedures under review as the Fisheries and Aquaculture Sector Development Plan is taken forward to the implementation stage
The main responsibility for ensuring delivery of the Fisheries and Aquaculture Sector Development Programme will rest with the Fisheries Department of the Ministry of Food and Agriculture and the Fisheries Commission supported by the MCS Division and Ghana Navy However a key part of the programme is the development of local co-management arrangements and the Ministry of Local Government and Rural Development and individual District Assemblies will play a key role in helping to form and sustain Community Based Fisheries Management Committees
Over time a significant number of fishermen and individual fish processors are likely to leave the sector as harvesting landing and processing of the catch becomes more efficient Management of these changes especially where disadvantaged and vulnerable sections of the community are affected will need substantial support and investment and a high degree of coordination amongst government ministries and agencies NGOs and international partners to ensure that development assistance is effectively targeted
37
CHAPTER 5 WORLD BANK SAFEGUARD ISSUES
51 INTRODUCTION
The World Bankrsquos proposed funding support to the Government of Ghana covers an initial five yearsrsquo period which could potentially be extended at a later date As the Government of the Republic of Ghana notes in the draft FASDP ldquoimproving the management of the countryrsquos fisheries and ensuring that the impacts on individuals and communities are properly addressed will take 20 or more years to effectrdquo It has therefore been judged important in this report to distinguish between changes that might occur as a direct result of the World Bankrsquos financial assistance thereby triggering the Bankrsquos environmental and social safeguards and changes that could result from longer term adjustments to fisheries and other sectors of Ghanarsquos economy as a result of wider influences by Government other donors and world-wide factors (for example international progress in world trade agreements)
The aim in this chapter is to identify changes which are likely to fall within the purview of the World Banks reputational risks and responsibilities under the first five years of the Fisheries and Aquaculture Sector Development Plan (FASDP) It should be clearly understood that the views expressed are those of the consultancy team and it will be for the World Bankrsquos internal advisors to decide what formal recommendations are made to the World Bank Board
Trends that may emerge in later stages of the implementation of FASDP ndash subsequent to the initial five year period - are discussed in chapter 6
52 THE CURRENT SITUATION
The general status of Ghanarsquos fisheries has been described in Chapters 3 while the legal and policy context has been set out in Chapter 4 The World Bankrsquos investment is being planned specifically to support government policy with the aim of providing a more efficient and better regulated fisheries sector Currently open access is leading to progressive deterioration in fish stocks and lower economic returns Based on many international examples of successful intervention the current proposals (see Chapter 2) are to provide support to introduce formal licensing of all vessels and proper monitoring and control over the seasonal timing and location of fishing activity use of gear and approved nets and self regulation through co-management structures under which the Government and fishing communities will work together to achieve recovery of fish stocks higher income levels for fishers and better returns on catches by reducing post harvest losses and improving processing and marketing operations
53 ANTICIPATED OUTCOMES
It is expected that the proposed reforms and changes will eventually lead to significant improvement in the marine environment restoration of fisheries and enhanced incomes In this respect the provision of grants and loans from the World Bank will bring about major benefits to the economy livelihoods and the environment in the longer term The question that has to be addressed however is - are there likely to be any short term adverse environmental or social consequences from the Bankrsquos own investment strategy Answers are considered in relation to each of the planned components sub-components and activities which are summarised in Table 51 A colour coding and numbering system has been adopted to distinguish those activities that are seen as particularly relevant from the standpoint of the environmental and social assessment Elements highlighted in green are those likely to have positive and beneficial effects on the environment and social conditions those highlighted in orange red have potentially negative or adverse consequences if not handled properly
38
Component 1 Good Governance and Sustainable Management of the Fisheries
Sub-Component 11 seeks to develop the capacity rules procedures and practices that will lead to better governance As such these procedural interventions will have no direct effect on the environment or social conditions of fishing communities However it will be important to ensure that the drafting agencies (government departments and consultants) give due attention to environmental and social objectives during this phase of work Three specific areas are highlighted including undertaking a socio-economic impact assessment with mitigation measures as part of the plan for fishing capacity reduction reviewing the economic and social implications of subsidies and fish import tariffs in the fisheries sector and developing the policy for the development and operation of community-based management networks built around defined fisheries management units
In developing regulations and guidelines it will be important to consider how less able individuals and vulnerable sectors are going to adapt to new systems For example the new regulations on licensing canoes including completion of registration forms the display of registration numbers on vessels and demonstration of basic competence in health and safety standards may prove taxing demands for owners and crew lacking any formal education Similarly legal instruments that are used to remove fuel subsidies or other benefits will need to be carefully explained A socio-economic impact assessment is proposed in the draft PAD to be accompanied by appropriate mitigation measures This assessment should consider amongst other things
bull whether support should be offered and if so under what conditions to any company community or individual who fails to secure a license for a particular class of vessel
bull how the transfer or sale of licenses will be regulated in the wider public interest to ensure transparent processes and avoid the creation of monopolistic and oligopolistic elites
bull who wins and who loses from any planned changes to subsidies and fish import tariff adjustments
bull how the performance of community-based management networks will be judged bull what action will be taken to mitigate the loss of any traditional fishing grounds that become the
subject of marine protected area development or are subject to exclusion zones to protect oil drilling and production platforms
Sub-Component 12 introduces the concept of fishing rights This is to be initiated through a series of four pilot stakeholder-based fishery initiatives and the rolling out of licensing procedures Discussions with stakeholders have made it very clear that the credibility of the entire fisheries policy and programme could be challenged if these pilots do not show positive and constructive ways of moving forward with fisheries reform There is a great deal of distrust for new procedures amongst the fishing communities based on the knowledge that many previous initiatives have failed It is therefore essential that the pilots are led by a strong implementation team are adequately financed and include a credible transparent and inclusive process for debate discussion and consultation Co-operation from the selected communities will be more likely to be achieved if they can see early results in terms of income generating activities
Sub-Component 13 is targeted at adjusting fishing effort and capacity to more sustainable levels and supporting alternative livelihood opportunities These activities are critical in giving effect to the policy decisions that have already been taken to reduce the size of the industrial and semi-industrial fishing fleet and to strengthen the role of the canoe sector Specific measures are proposed for compensating crew members who lose their jobs and for providing training to young men who are willing to transfer
39
out of the fishing sector The scale of this task should not be under-estimated however since there are currently few alternative employment opportunities in the coastal belt for manual workers with low education and skill levels which typify the status of many young fishermen The concept of creating some additional employment with conservation of the coastal littoral and marine ecosystems is strongly supported since this can be linked with development of tourism
Sub-Component 14 is another element that is strongly focused on delivering improved livelihoods with its emphasis on social marketing communication and transparency The focus on stakeholder participation is particularly welcome and should lead to positive response providing it is backed with direct financial support to participating communities
Component 2 - Reduction of Illegal Fishing
There is no Sub-Component 21 within the Ghana Fisheries Programme
Sub-Component 22 aims to develop monitoring control and surveillance (MCS) systems These measures are largely procedural and apart from the relatively small team that will be recruited to operationalise the systems it will have minimal effects on either the environment or social conditions One element that is highlighted in Table 51 relates to provision of facilities and training for participatory coastal surveillance of small-scale fisheries This should have direct and strongly positive benefits for participants and the communities who are enrolled in the training programmes
Component 3 increasing the contribution of the marine fish resources to the local economies
Sub-Component 31 will support the development of basic infrastructure at nine marine fish landing sites and two inland sites The scale of physical construction will be restricted to repair and minor extension of roads and jetties wharves and construction of net mending screens and storage sheds These activities are unlikely to have any significant adverse environmental impacts and should lead to positive social effects
Sub-Component 32 will underpin efforts to improve fish product trade infrastructure information and systems Introduction of new technology for smoking and curing fish and the extension of existing ice preparation plants will start to have positive beneficial effects within the selected communities
Sub-Component 33 provides a modest level of support to marine and inland aquaculture development Aquaculture development should include finalization establishment and enforcement of current draft operational standards to cater for environmental friendliness of fish culture industry for its own survival The main focus will be on developing policy and legal frameworks together with support for stock improvement These measures will have some impact on affected communities in the short term but are clearly aimed at longer term benefits
40
Component 4 Coordination Monitoring and Evaluation and Program Management
Sub-Components 41 and 42 are directed specifically at strengthening the capacity of the Governmentrsquos institutions for national implementation and regional co-ordination As such they will have no direct environmental or social impacts
54 SUMMARY AND CONCLUSIONS
This review of potential environmental and social safeguard issues under the World Bankrsquos targeted programme concludes that there are unlikely to be any significant adverse environmental or social effects as a result of the planned investments
The only possible exception relates to the effectiveness of measures that are put in place under Sub-Component 12 to support pilot stakeholder-based fishery initiatives It is of paramount importance that these pilots are successful and win the confidence of all participants since failure to achieve positive results could set back the entire fisheries programme For this reason it is essential that planning of the pilot initiatives is linked closely with measures for supporting alternative livelihoods and strengthening processing and marketing initiatives under Sub-Components 13 and 14
A number of the planned interventions may have longer term consequences as policies regulations and bye-laws are put into effect but these will be addressed in subsequent work by the Government of Ghana (see Chapter 6)
Table 51 Elements of the World Bank Programme and assessment of potential environmental and social risks
Description of Component Sub-Component and Activities
Measure of Likely Effects
Large (3)
Moderate (2)
Small (1)
None
Beneficial
3
2
1
Adverse
3
2
1
Component 1 Good Governance amp Sustainable Management of the Fisheries
Sub-Component 11 Developing the Capacity Rules Procedures amp Practices for Good Governance of the Fisheries
Reviewing developing programmes and projects designed to support the Fisheries and Aquaculture Development Sector Plan (FASDEP)
Developing an operational policy to enable implementation of the Aquaculture and Fisheries
Plan for fishing capacity reduction (including socio-economic impact assessment and mitigation) 3 2
Commercial vessel and fishing activity licensing plan including allocation criteria rules for transfer of licenses
41
Sector Development Plan and timetable and schedule of license fees
Compliance strategy and plan
Regulations for the management of fisheries including the identification and specification of fisheries management units (ie stocks species areas)
Recommendations for environmental and social safeguards arising from the review of the economic and social implications of subsidies and fish import tariffs in the fisheries sector
3
Policy for the development and operation of community-based management networks built around defined fisheries management units
3
Policy on adaptation strategies for climate change and marine protected area development
2 2
Review of the Ghana Tuna Industry to identify policy or infrastructure needs that threaten Ghanarsquos hub status
Strengthening capture fisheries management systems and capability
Development of fisheries and aquaculture management systems and processes and training
Strengthening fisheries information systems
Installation and operation of fisheries lsquodashboardrsquo database and information collection
Sub-Component 12 Introducing Fishing Rights ($15 M GEF)
Developing 4 pilot Stakeholder-Based Fisheries Management initiatives around defined fisheries units (ie local management initiatives tied to defined fisheries resources including demand-side governance initiatives)
3 2
Introducing and administering a licensing regime (registry establishment training stakeholder education) 2 2
Sub-Component 13 Adjusting Fishing Effort and Capacity to more Sustainable Levels and Supporting Alternative Livelihood Opportunities where Needed
Vessel decommissioning Decommissioning of 60 to 80 industrial trawlers in an environmentally friendly manner
2
Developing alternative livelihoods for crew of decommissioned industrialsemi-industrial
Skills training and small business development training and support for young (18-30 yrs) industrialsemi-industrial crew members willing to transition out of the sector
3
42
vessels
Alternative livelihood development to incentivize voluntary capacity reduction in canoe sector
Alternative livelihoods fund and CDD support to targeted fishing communities
3 2
Marine Resource Conservation
Would include confirming conservation priorities and management regimes and possible provision of support for alternative livelihood options (funded under 133) associated with conservation of coastal littoral and marine ecosystems as well as de facto protected areas associated with the development of oil and gas extraction
3
Sub-Component 14 Social Marketing Communication and Transparency)
Communications stakeholder consultations and awareness raising programs to support fisheries development
3
Component 2 Reduction of Illegal Fishing
Sub-Component 21 does not apply to Ghana
Sub-Component 22 Monitoring Control and Surveillance (MCS) Systems
Developing compliance systems and capability
Development of judicial and policy capacity (training)
Compliance risk assessmentstrategy systems and process development
Enforcement Unit establishment (dedicated facility)
Coastal surveillance stations 2
Facilities and training for participatory coastal surveillance of small-scale fisheries
3
Training for surveillance officers
Operation of aerial and water patrols (vessel leases aerial patrols operational costs patrol vehicles)
Observer program
Compliance education (stakeholder training signage) 1
Upgrademaintenance of the Vessel Monitoring System (VMS)
43
Component 3 Increasing the Contribution of the Marine Fish Resources to the Local Economies
Sub-Component 31 Fish Landing Site Clusters
Product diversificationvalue chain development
9 marine landing sites (basic infrastructure) at Axim Dixcove Fete Jamestown Moree Mumford Senya-Beraku Teshi and Winneba
3 1
2 inland fish landing sites (improved access and berthing infrastructure) at Abotoase and Dzemeni
3 1
2 ports developed (technical studies for 1 new port at Axim and additional berthing space in existing port of Elmina)
3 2
Sub-Component 32 Fish Product Trade Infrastructure Information and Systems
Export certification center development
Fish processing technology improvements 1 1
Technical assistance training and goods to support the National Fisheries Advisory Group
Sub-Component 33 Marine and Inland Aquaculture Development
Developing aquaculture policy and legal framework
Improving genetic quality of Tilapia fingerlings and breedstock
Catalyzing aquaculture development 2
Component 4 Coordination Monitoring and Evaluation and Program Management
Sub-Component 41 National Implementation
Technical assistance for Secretariat to the Fisheries Commission to implement the Project
Sub-Component 42 Regional Coordination
Technical assistance for Regional Coordination Unit at the CSRP support to Fisheries Information Systems (lsquoDashboardrsquo)
45
CHAPTER 6 ENVIRONMENTAL AND SOCIAL ASSESSMENT OF DRAFT FISHERIES AND AQUACULTURE SECTOR DEVELOPMENT PLAN (FASDP)
61 INTRODUCTION
This chapter examines environmental and social issues which need to be considered as part of the overall structural and economic adjustments in Ghanarsquos fisheries sector in the longer term (ie 1-15 years) The assessment deliberately focuses on the longer term because it will take a number of years before current plans start to have their full effect However the same temporal considerations apply to measures that are designed to avoid or mitigate potentially harmful effects so it will be important to start planning remedial actions as part of the joint Government of Ghana and World Bank fisheries programme
611 Key sectors and activities The fishing industry is divided first into marine capture and inland capture fisheries and then aquaculture For each of these three sectors activities are then broken down as follows Marine Capture Fisheries CATEGORY ACTIVITY Stock Management Research Surveillance reef building Harvesting Vessels Gear Skills capacity Marketing Sellers Buyers Processing Fresh fish Sun dried Smoking Freezing Consumers By market sector Support Sectors Boat Canoe Building fuel supply net making kiln construction
refrigeration transport cold store management Legal Enforcement Financing Investment in all elements Infrastructure Harbour wharf processing plant construction
Inland Capture Fisheries CATEGORY ACTIVITY Stock Management Research Surveillance Harvesting Vessels Gear Skills capacity Marketing Sellers Buyers Processing Fresh fish Sun dried Smoking Freezing Support Sectors Boat Canoe Building fuel supply net making kiln construction
refrigeration transport cold store management Legal Enforcement Financing Investment in all elements Infrastructure Harbour wharf processing plant construction
46
Aquaculture and Mariculture CATEGORY ACTIVITY Stock Management Research Surveillance Rearing Roe fingerling production cage -pond rearing Harvesting Vessels Gear Skills capacity Marketing Sellers Buyers Processing Fresh fish Sun dried Smoking Freezing Support Sectors Boat Canoe Building fuel supply cage construction kiln construction
refrigeration transport cold store management Legal Enforcement Financing Investment in all elements Infrastructure Harbour wharf processing plant construction
612 Evaluation Criteria The environmental and social assessment has been undertaken using a matrix (See Annex 114) which analyses the key sectors and activities of the fishing industry and the changes that are envisaged against a set of evaluation criteria Evaluation Criteria are broken down into environmental and social issues distinguishing between beneficial and adverse effects Table 61 below shows the relationship between the groups of criteria Table 61 List of Evaluation Criteria
Environment Social
Positive Adverse Positive Adverse
bull Sea bed rejuvenated
bull Fish stocks recovered
bull Biodiversity enhanced
bull Sea bed degraded
bull Fish stocks reduced
bull Biodiversity reduced
bull Increased harvest (catch volume)
bull Increased catch value
bull Reduced costs of inputs
bull Increased profit
bull Enhanced livelihoods
bull Increased job opportunities
bull Increased local economic multiplier
bull Reduced harvest (catch volume)
bull Reduced catch value
bull Increased costs of inputs
bull Reduced profit
bull Reduced livelihoods
bull Reduced job opportunities
bull Reduced local economic multiplier
The assessment process has involved systematically considering each sectoractivity against the evaluation criteria and recording either positive or negative results by drawing on the judgement of the consultancy specialists The findings are discussed in the paragraphs that follow and are reflected in Table 81 forming part of the Draft Environmental and Social Management Plan
62 DETAILED ASSESSMENT OF THE MARINE AND AQUACULTURE SECTORS
47
TunaIndustrial fleet streamlined and catch per vessel improved At present industrial trawlers have to travel increasing distances to fishing grounds and while the level of catch is remaining broadly static costs are increasing against available economic returns A major shortcoming is lack of investment in re-equipping the aging fishing fleet Many of the 90 vessels that make up this sector are increasingly unseaworthy and need to be replaced with modern trawlers and gear The plan is to buy out owners of substandard vessels by offering compensation at market value based on a full commercial survey Vessels remaining in the fleet will be required to meet exacting standards By reducing the number of old and inefficient boats this will allow each of the remaining vessels to catch a higher proportion of fish The aim is to ensure that Ghana is equipped with the latest vessels and technology in order to preserve the countryrsquos position as the hub of the West African tuna fishing and processing industry (see also the section on canneries below) The effect of these measures on the environment will remain broadly neutral since the same number of fish will be caught Providing other policies and increased surveillance are successful in preventing trawling in inland waters the smaller fleet will have to fish in deep oceanic waters This could potentially transfer some environmental effects on fish populations to other parts of the migratory cycle However this would become part of the international effort through fishing quotas to regulate overall catches Reduction in the size of the industrial fleet will mean that fewer men are needed to crew and service the vessels However in practice many men who work in this sector have only part time work and since a significant percentage of boats no longer put to sea the number of crewmen who will be displaced could be in the range of 1000-30003
It will be important to set up support services for those losing their jobs including retraining and welfare assistance where necessary
Decommissioning will necessitate the sale of seaworthy vessels and their removal from Ghanaian waters Other boats will need to be broken up and scrapped This process requires heavy duty specialized equipment and can release significant quantities of waste oil other toxic chemicals including refrigerants and asbestos used in pipe and engine room cladding Measures will need to be taken to ensure that proper environmental and health safety precautions are taken that decommissioning takes place in properly equipped boatyards and that all waste products are disposed of without environmental risk Cannery sector optimized The Fisheries and Aquaculture Sector Development Plan seeks to maintain the port of Tema as the centre of the Tuna canning industry in Ghana At present a proportion of Ghanarsquos tuna catch is diverted to neighbouring countries due to constraints on processing capacity These limitations include poor port infrastructure ageing equipment and delays in handling catch for some operators due to preferential treatment of vessels that are part-owned by the existing canneries Options for improvement include encouraging upgrading of the capacity of one or more existing canneries or promoting more competition in the processing sector and improving the infrastructure Providing modern building designs and construction techniques are employed and a full environmental assessment is undertaken in accordance with Ghanarsquos EIA regulations there should be no significant environmental or social risks associated with these development possibilities The potential economic benefit resulting from encouraging investment in this sector is very high
Industrial fishing excluded from inshore waters A major longer-term intention under the new fisheries plan (FASDP) is to ensure that existing regulations that restrict industrial and semi-industrial vessels from trawling in inshore waters are properly enforced This requires provision of surveillance
3 Based on an average crew of 20
48
equipment fast patrol vessels capacity building and training and increased staffing within Government agencies together with a full programme of awareness raising training and financial support to local bodies providing self-governance under new co-management services Restriction of industrial trawling in coastal waters will greatly ease pressures on fish stocks and reduce environmental damage to the sea bed In time this should lead to healthier fish population with more fish to be caught by the canoe industry as a result However the task of policing and enforcing regulations will not be easy and will take a number of years to bring into full effect Reduction in fishing activity by inshore trawlers will displace a number of crew members and have a short-term impact on dependent families until these individuals are either absorbed into the canoe fleet or find alternative employment There will therefore be a need to assist genuinely deserving cases where crew members (and their families dependents) need to transfer to other sectors of the economy These measures will only be required in the short term since the anticipated improvement in fish stocks will lead to improved economic performance in the canoe sector within which the bulk of employment exists
Expansion of deep water fisheries The fisheries plan notes that there may be a potential for exploitation or increased exploitation of some deep sea fish resources However the status and population dynamics of some affected species is not well known so any such activities should be scientifically monitored through research and enforced by MCS
Tema Secondi Port infrastructure improvements (equipmentbuildings) Under present conditions the transfer of fish from commercial and industrial vessels to canneries is often delayed by the time taken to offload crates and manouvre within the port area where there are conflicting activities There are also difficulties that arise when vessels owned by the canneries are given priority for landing leaving other boats waiting for many hours which can result in quality deterioration At this stage no details are available about the precise improvements that could be introduced and this will need to be investigated as the fisheries plan is advanced Any environmental effects from infrastructure improvements would be contained within the existing port areas and should be largely positive in reducing fuel (energy) costs and increasing overall efficiency It will however be important to carry out an environmental review of specific development proposals at the design stage especially if these involve plans for any dredging or for altering facilities for discharging waste and disposing of bilge water Both of these activities can have damaging effects on the sea bed (The first through dispersal of silt and sediment and the second through release of potential contaminants) Socio-economic effects from the infrastructure improvements should also be beneficial by removing delays increasing efficiency and reducing waste However there could be some slight reduction in manpower requirements leading to the need for skills retraining Regulating the catch (eg Fishing for selected species reducing juvenile catch to improve value of catch in inshore waters) The fundamental aim of the fisheries plan is to reduce the harmful effects on fish stocks and low economic returns from fish catches by phasing out open access for all and introducing regulation of fishing activity This is to be achieved through close cooperation between the Fisheries Commission Monitoring and Surveillance Unit as well as marine fisheries management division and individual fishing communities working together under a co-management framework The practical details will need to be worked out through each individual co-management group and initially the World Bank is offering to assist in the establishment of four pilots These bodies will test exactly what is required to increase fishersrsquo awareness to build capacity in self regulation and agree on appropriate measures
49
From discussion with stakeholders it is clear that while the broad principles are accepted the majority of the fishing community simply do not believe that the new regulations will be enforced because they have witnessed the failure of so many previous efforts to introduce firm management A major issue for the planned programme is therefore how to change this critical mindset without which very little progress is likely to be made in practice It will be necessary to demonstrate through the pilots that by regulating fishing activity direct benefits will accrue to those participating fishing communities Unfortunately efforts to eliminate harmful practices are unlikely to result in an immediate gain in fish stocks Instead catches are likely to fall in the short term It will therefore be essential to introduce other forms of incentive to cushion short term losses Such measures might include the purchase of new nets and gear for sale at subsidized price to local cooperatives the introduction of cash incentives for canoes demonstrating best practice in the use of gear and nets preservation of the catch using ice and landing and marketing fish of the required size and quality As restriction of open access starts to take effect there should be positive environmental gains in terms of improving fish stocks and less damage of the sea bed On the other hand both fishers and fish processors will feel the adverse temporary effect of reduced catches These social and local economic impacts will need to be monitored closely and assistance provided to help foster alternative livelihoods Cephalopus (Octopus) harvesting encouraged in inshore waters Although most fish species are currently exploited to unacceptably high levels within coastal waters there is a specific opportunity to increase the number of octopus caught by pot fishing This fishery could be developed by both the semi-industrial and canoe sectors Taking octopus in pots would have no adverse physical impacts on the sea bed and could allow very slight expansion in fish species that are preyed on by octopus At the same time it is important to note that there is only limited information on species composition and functioning of selected marine habitats including those of the octopus and more research should be undertaken on this and other species that could be selected for expanded fishing activity There would be clear socio-economic benefits arising from the creation of this new fishery Focusing fish landing at specific landing sites (to improve opportunities for subsequent marketing processing) Plans are already being developed for the enhancement of landing and processing facilities at a number of existing locations along the coast These locations include the construction of harbours at Jamestown and Elmina and development of landing sites at Teshie Ada Axim Dixcove Winneba Mumford SenyaBeraku Gomoa Fetteh Moree Keta Dzemeni and Tapa Abotoase Two sets of issues need to be considered in relation to these improvements all of which affect existing fish landing and processing sites The first is the nature of the physical works and infrastructure and it s potential effect on the marine and terrestrial environment The second is the socio-economic impact Both Elmina and Jamestown are long established fishing ports where the catch is landed either directly onto the beach or shallow wharves It is understood that the primary aim of the improvements will be to increase the area of permanent wharves to make it easier for fish to be offloaded to reduce the time taken in transferring stock to processing plants and to introduce modern technology In the case of other smaller landing sites the scale of improvements will be quite modest involving improvement to existing short stretches of access road the erection of stores for nets and other gear and provision of covered areas to provide shade for net-mending With all proposals for physical infrastructure development there will be a need to consider possible
50
environmental implications Due to the existing nature of these sites there are no major industrial or other commercial processes in the vicinity which could give rise to cumulative impacts including contamination of fish products The scale of plant needed for ice-making and storage and commercial smokeries is commensurate with the artisanal nature of the fishing activity itself and would not give rise to any significant environmental effects on air or water quality Harbour works could potentially involve some small scale dredging (for example the removal of accumulated silt) Where dredging is required it will be important to identify disposal areas (either at sea or on land) where silt can be deposited without damage to sensitive habitats In terms of economic and social impacts it is not clear at this stage who are likely to be the major investors from the private sector although it may be assumed that existing operators who have access to finance will be the main beneficiaries Over time as landing marketing and processing become more efficient it is possible that individuals in the traditional fish smoking sector will lose a significant proportion of their trade as the product switches to fresh or frozen fish sales for transfer to the major urban markets and the beach price for fish rises The draft Ghana fisheries and aquaculture sector development Plan notes in annex 2 that proposed facilities associated with the ports and landing sites may not have support from fish mammies or at least formidable commercial advocates able to resist any opposition from that quarter Inspection of major fish landing areas like Elmina and Sekondi indicates that the existing social and commercial structure of support activities to fish harvesting is very complex and involves almost every member of the community including children and the elderly Such activities include net mending boatbuilding metalworking (for cooking pots stoves and grills supplies (ropes weights tar paint wood) fuel supplies ice crates transport etc Leaders of the fishing community confirmed that in principle the improvements of facilities is welcomed provided that safeguards are in place for those who may lose part or all of their current trading activity through rationalisation Stabilise fleet capacity at a sustainable level Fishery experts consider that there would be significant benefits in reducing the number of canoes from the present 10000-12000 to around 8000-9000 which correlates with the number operating in the mid 1990rsquos when catches were at optimum levels At the same time the Fisheries and Aquaculture Plan stresses that the canoe sector will remain at the heart of the Ghana fishing industry and this has strong political enforcement Consequently there is unlikely to be any enforced reduction in the number of canoes holding licenses and owners of all existing canoes will be able to register their vessels The ability of canoe owners to pay annual licence fees should rise as the overall measures to increase efficiency and improve catches take effect However many people anticipate that over time as the annual cost of holding licenses rises less efficient fishers will sell their licenses (and hence their rights to fish) There may therefore be a de facto reduction in the size of the canoe fleet Even if numbers do not decrease the fleet could be stabilized at its present size by taking a decision not to grant new licences The draft plan discusses the fact that under existing law (section 53) there is a requirement for licenses to be issued on demand (presumably to ensure that Ghanaians are not barred from subsistence fishing) It is argued in the plan that this is a misconception since canoe fishing is largely a commercial activity and it is concluded that lsquoit is therefore essential that the number of canoe licenses can be controlled in future and the legal basis for these controls must be reviewed as a matter of priorityrsquo Decisions of this nature will require the full support of local co-management groups if they are to be effective but committees could easily come under pressure to make exceptions as the coastal population continues to rise and families without alternative livelihoods start lobbying for assistance
51
Accusations of preferential treatment of certain individuals by committees (or committee officials) - possibly linked with suggestions of bribery and corruption -could cause a lot of social tension and start to undermine community trust in the need to work together to improve fisheries management It is therefore most important that the detailed proposals for co-management address this risk and include proposals for mitigating individual hardship of the less advantaged ndash for example by offering voluntary retirement with some form of incentive Influencing marketing to maximise value and reduce post harvest losses (marketing cooperatives strong market structures etc) FAO has estimated that physical post harvest losses in Ghana amount to between 3 and 17 of smoked fish production and 16-20 of gillnet landings The plan notes that introduction of lsquonew generationrsquo small scale fish smokers should be introduced to replace the traditional Chorkor model This would improve fish product quality by eliminating charring of fish over open flames and also protecting operatorsrsquo eyes from the damaging effect of smoke and particles The other major improvement in post harvest value and profits would arise from greater use of ice throughout the supply chain Developing Aquaculture A distinction needs to be made between aquaculture development in ponds and dugouts which are self-contained and fish rearing in cages within open water In the case of farm ponds the commercial rearing of fish is little different to other forms of intensive livestock rearing Providing there is no direct connection to rivers and streams there is little likelihood of interaction between farmed and wild stocks which could spread fish infections and parasites In the case of fish farms in open water (rivers and lakes) there are well known risks of the spread of disease which can arise if overstocking occurs Intensive feeding of large numbers of fish in a confined area can lead to significant deterioration in water quality through the build up of nutrients from wood and waste It is also possible for antibiotics and growth hormones to be dispersed beyond the area of farm cages Genetic modification of farmed fish can also affect the local fish population through escapes All of these issues are capable of being managed and mitigated through good initial planning and design and subsequent maintenance and supervision It will therefore be necessary to develop additional regulations and guidelines specifically for the aquaculture sector 63 SUMMARY OF ENVIRONMENTAL RISKS AND OPPORTUNITIES Review of the full range of governance and development activities suggests that there are no high levels of risk to the marine or littoral environment Successful implementation of the Policy and plan should in fact result in very significant environmental gains Over a timespan of 5-20 years five activities in particular should result in significant improvements in the condition of the sea bed in coastal waters (to a depth of 30 metres) reestablishment of benthic flora and niche habitats increased fish stock and enriched biodiversity These interlinked activities are bull The exclusion of industrial vessels and trawling within coastal waters bull Regulation of fish catches through zonation seasonal control of fishing and standards for vessels
gear bull Stabilisation of the fishing fleet within sustainable harvesting yields bull The adoption of management plans formulated and agreed with full cooperation of local
communities bull The introduction of fishing rights through co-management agreements and bull Well planned consultation and information dissemination throughout the fisheries sector
52
Three components of the development plan have been identified where minor to moderate risk to the physical and biological environment could arise if proper design and implementation standards are not adhered to These relate to bull A potential risk of over-exploitation of new catch species in deep water off the continental shelf if
such development is not accompanied by through research to establish the sustainable yield of target species
bull Strictly localized effects on the physical environment from construction of landing wharves or jetties and other harbour facilities and
bull Infrastructure development at the existing ports of Tema and Takoradi All of these risks are capable of being fully managed by improved governance in the fishing sector and EIA procedures that are well-established in Ghana 64 SUMMARY OF SOCIO-ECONOMIC RISKS AND OPPORTUNITIES Implementation of the Plan Project will bring about substantial change in the fisheries sector and over time increased revenue reduction of post[harvest losses and added value to fish products will bring major economic returns At the same time there will be some individuals who do not participate in direct gains and whose livelihoods could be adversely affected if appropriate safeguarding measures are not put in place The level and extent of these socio-economic risks will be determined by 1 the level of commitment that is entered into by Government and its development partners to
deliver incentives to vulnerable and disadvantaged groups and 2 the speed with which the sector is transformed Rapid change could cause significant
displacement of less-efficient operators especially within the semi-industrial and canoe sector which would have serious ramifications for dependent communities However these effects can be marginalized if the development programme is carefully phased to ensure that alternative livelihood and employment incentives are available
The main risks to local livelihoods relate to the potential for bull loss of employment for crews of unseaworthy obsolete vessels ( from all sectors including
industrial semi-industrial and canoes) that are withdrawn from the fishing fleet because they no longer comply with license regulations
bull the inability of vulnerable and disadvantaged groups including artisanal fishers vendors and individual fish processors in small fishing villages to adjust to new market conditions at selected landing sites
53
CHAPTER 7 ASSESSMENT OF POLICY OPTIONS
71 INTRODUCTION
In order to place the significance of the environmental and social safeguards assessment in context this chapter examines the possible consequences of different policy responses to the existing challenges that face the fisheries sector in Ghana These different policy responses range from a continuation of the status ndashquo effectively a ldquodo-nothingrdquo option (A) to full-scale commitment by all stakeholders to achieving a sustainable fisheries future the ldquoOptimum Solutionrdquo option (C) Various less sustainable outcomes lie in between these two ends of a continuum of policy choices and these are represented by the ldquoWeak Solutionrdquo option (B) 72 OPTION A ndash DO NOTHING Background research and discussion with stakeholders indicates that practical capacity to deliver on clearly stated national goals for sustainable fisheries livelihoods and the reduction of poverty is weak This situation exists despite the fact that Ghana has a strong legal framework for management of its fisheries including the Law Policies and Regulations There is inertia and strong resistance on the part of the majority of players to accept that it is largely their own actions which are responsible for present conditions This in turn leads to the attitude that it is only the lsquoGovernmentrsquo that must act by providing increased subsidies and cushioning the industry against further deterioration in catches Unfortunately there is overwhelming evidence from around the world that where fish stocks are exploited beyond their natural capacity to regenerate this can lead to sudden and near-total collapse Ghana has historically been one of the strongest fisheries in West Africa but the signs are ominous that current levels of exploitation are leading to progressive decreases in annual catches for most species in both marine and inland waters As fishing effort intensifies with an increasing number of all types of vessel using illegal methods and inappropriate gear the distinction between the traditional lsquopeak season and lean season (linked to migration patterns breeding cycles and upwelling) is becoming blurred This is clearly illustrated by a statement from one of Elminarsquos fish mammies ldquowe use to smoke the herring in the peak but now the fishers bring them all the yearrdquo Use of monofilament nets light dynamite and chemicals to obtain fish in the lean season is aggravating a situation where too many boats are chasing too few fish Many fishers blame the reduction of catch on global warming for increasing water temperature the emergent oil and gas industry for restricting access to traditional fishing grounds and industry and urban development for increasing pollution leading to deterioration in water quality Each of these assertions warrants careful consideration but the industry is generally in denial when it comes to the primary fact ndash too many fish including juveniles are caught to allow regeneration of the stock In addition weak governance and lack of resources to ensure implementation of policy result in a situation where the law can be ignored with impunity If collective failure to recognize the seriousness of the current position and lack of commitment to taking hard decisions continues the omens for the future are not good Within a period of 10-15 years fish catches could fall by 50 or more from their present level Impacts on each species would vary and catches of some fish with regional or global migration patterns could remain viable (although this depends on the international conservation effort) On the other hand stocks of fish that provide the mainstay of local food resources herring and sardine could be decimated
54
Complete collapse of all fish species is unlikely but it is possible to envisage a situation where catches might fall below 300000 tonnes a year by 2025 (a reduction of more than 25 from present levels) The most serious consequences would be felt as a result of the social and local economic impact on fishing communities Perhaps 30000 men representing the crews of 3000 canoes and semi industrial boats and 15000 women engaged in marketing and processing would lose their present livelihoods Population migration away from the coast could follow and severe social pressures and local economic hardship This is clearly a ldquoworst caserdquo scenario and if conditions were to worsen gradually it might be possible to intervene but the fact has to be accepted that fish stocks are dynamic and subject to rapid decline (as in the case of the North Sea Herring and Atlantic Cod) 73 OPTION B THE lsquoWEAKrsquo SOLUTION The bleak future painted in Option A is unlikely to arise if the present policy and draft fisheries development plan is followed since these are specifically directed to addressing the major challenges However realization of the aims is dependent upon delivery across a wide range of initiatives by multiple stakeholders The following paragraphs illustrate some of the ways in which delivery of policy objectives might be thwarted These may be summarized as
bull Commitment to good governance and institutional reform bull Political resolve to implement unpopular measures bull Availability of adequate technical and financial resources bull Inertia to necessary changes in fishing practice
Good Governance and Institutional Reform Fundamental reforms are required to fully equip the national fisheries management effort at government level This includes introduction of change management clarification of responsibilities for senior staff rationalization of financial management systems provision of equipment expansion of staff numbers additional training and capacity building As an illustration of the extent of the effort required reference can be made to just one topic area the issue of monitoring control and surveillance At present the Fisheries Commissionrsquos MCS Unit has only 10 employees to oversee implementation of the fisheries regulations throughout Ghana This number will be increased as other institutions are engaged in joint monitoring initiatives but it is obvious that staff numbers and capacity will need to be expanded if regulations on fishing activities are to be affected Enforcement is only one part of the equation however Much greater emphasis will need to be placed on voluntary controls and self-policing at community level through Co-management schemes
Failure to press ahead with governance and institutional reform could delay the process of introducing and registering licenses which represents a crucial first step in moving from open access to managed access in the fisheries sector Given the urgency for action the five years allowed in the current plan for completing the registration process seems very generous Political resolve to implement unpopular measures Stakeholder meetings have confirmed the significance of party political influence as a constraint on achieving progress in the reform of the fisheries sector The offer of incentives like subsidies or the promise of new facilities and equipment are regularly employed by individual politicians to garner votes whether or not these form part of party manifestos Examples have been quoted to the consultants where enabling regulations that might restrict fishing access and prove unpopular amongst the fishing community are quietly ignored and officers may be discouraged from pursuing breaches of the law where the offender has political influence These issues arise with governments of all political
55
persuasions and can apply at all levels from District Assemblies through to regional and national committees
A serious issue with fisheries sector reform is that once actions have been taken to conserve fish stocks it may be years before the full benefits are felt and the results are evident in terms of increased catches This makes it harder for governments to institute unpopular reforms ndash even though these are in the best interests of the nation fishing communities and individuals Fishermen and their families are used to seeing an instant lsquosame day returnrsquo on their catch and are less willing or able than stakeholders in other economic sectors to wait for gradual improvements There is an urgent need to establish cross-party support for the fisheries sector in Ghana and to seek agreements between the main political parties to support established policy and regulations where these are in the interests of delivering sustainable fish stocks Availability of Technical and Financial Resources The process of moving from complete open access to restricted use rights for both marine and inland capture fisheries will take many years to complete Progress will be heavily influenced by the level of political will availability of technical assistance and financial support Existing subsidies (pre-mix fuel and import tariffs) are seen as a deterrent to the encouragement of more efficient business practices However in order to reduce dependencies on these forms of government aid there is also a need to underwrite new forms of economic enterprise by giving help to start-up businesses developing training centres and promoting alternative livelihoods for those individuals who are either displaced or voluntarily give up work in the fisheries sector Inertia to Change Traditional fishing practices are quite literally a way of life for many Ghanaians and have been handed down from generation to generation These traditions are closely interlinked with cultural practices and power and influence resides in specific families with hereditary authority In order to change attitudes and gain acceptance of new approaches to fishing there is a need for a major awareness building and communications strategy targeting in particular the traditional leaders of the fishing industry Without such a plan it will be difficult to break down the internal resistance and inertia towards change The constraints that have been outlined above in relation to the lsquoweakrsquo option are very real and in combination they present a serious barrier to progress It will require real political commitment on the part of Government and strong financial support from international partners to break down these barriers 74 OPTION C THE lsquoOPTIMUMrsquo SOLUTION
The new Draft Fisheries and Aquaculture Plan together with the Act and Policies provide a solid foundation for revitalising the fisheries sector in Ghana However for the reasons discussed in relation to options A and B above there are a number of impediments that need to be overcome In addition to the measures in Option B an ldquoOptimumrdquo solution would also include
A coherent mix of Incentives (carrots) and Regulation (sticks) A top priority in developing existing strategies and plans will be to ensure that measures are in place to offer encouragement and practical assistance to fishers to convert to more sustainable practices while at the same time introducing effective enforcement There are some real challenges with both of these goals
56
New forms of incentive need to be developed to convince boat owners and their crews that it is worth their while to drop illegal methods (dynamiting use of monofilament nets etc) and to reduce the level of fishing effort (through close seasons introduction of restricted zones etc) Without these incentives it is highly unlikely that there will be significant take-up of the fisheries stock management and conservation message Special attention needs to be given to the role of chief fishermen and local community councils in developing effective local policing since it is impractical to rely on a national MCS team to regulate canoe activity in either the marine or inland capture fisheries The national MCS team will have its own responsibilities for policing local and international waters in relation to industrial and semi-industrial sized vessels Integrated Coastal Development The long term success of the fisheries strategy depends upon reducing fishing effort to a level at which catches become both sustainable and profitable for those who remain in the business This in turn requires that those displaced from the industry are able to find gainful employment and livelihoods in other sectors of the economy The fisheries industry is often seen as a separate economic sector which attracts its own funding and support but in order for the necessary reforms to take place these attitudes will need to change A new approach is required to lsquointegrated coastal developmentrsquo following the lessons from integrated rural development Many fishing inland and marine fishing communities are almost wholly dependent on fishing with less than 10 of the local economy being devoted to other industries Reform of the fishing sector therefore requires that as much ndash if not more ndash effort is devoted by government and its international partners to building up complementary economic activities in construction transportation manufacturing food processing environmental conservation and tourism There is a need to explore new state industry partnerships to establish appropriate economic development agencies and to coordinate activities between relevant state institutions ministries and departments under the current decentralisation initiatives with district assemblies taking a prominent role If initiatives of this sort are taken forward it will make the task much easier in persuading conservatively ndashminded fishing communities that they need to simultaneously develop their own entrepreneurial flair and impose their own discipline
57
Chapter 8 DRAFT ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK (ESMF) 81 INTRODUCTION Previous chapters of this report have described the principal environmental and social impacts that are likely to arise from reform in the fisheries sector This chapter sets out the Framework (ESMF) for an Environmental and Social Management Plan (ESMP)The first step has been to outline specific objectives to be achieved through implementation of the ESMF These objectives relate specifically to the issues described in earlier chapters Subsequent sections of the chapter detail the measures which are required to respond to specific areas of environmental and social impact through mitigation and amelioration works They also describe the types and level of environmental monitoring required together with the institutional aspects which need to be improved in order to support the fisheries sector 82 STRATEGY AND OBJECTIVES The basic aim of the environmental and social management plan is to set out guidelines for participatory programs under which members of local fishing communities and civil society in general can become involved in the design and implementation of local fishery co-management maintaining sustainable local livelihoods and achieving local monitoring of fishery efforts The basic principle for future fisheries management is that both marine and inland waters will be demarcated as territories for use rights to fisheries (TURFs) The principal goal of government policy in the fisheries sector is to ensure that the fisheries industry plays an increasingly important role in supporting the growth of the economy as outlined in the Ghana poverty reduction strategy (GPRS II) and the Republic of Ghana fisheries and aquaculture policy This goal will be supported by implementation of the fisheries and aquaculture sector development plan over the next five years In this timescale the aim will be to bull improve management of fisheries the conservation of aquatic resources and protection of the
natural environment bull promote value addition in the fisheries sector and the improvement of livelihoods in fisheries
communities bull encourage sustainable development of aquaculture bull improve the services provided to the fisheries sector by the fisheries commission and supporting
institutions The overall consequences of this strategy and the investments that are being made by the government and its aid partners will be stabilisation of fish stocks and sustainable catch levels a strengthening of the national economy and creation of a more robust fisheries industry with consequent benefits for fishing communities Impact assessment confirms that the result will be significant benefits for the marine environment and local economy However depending on the rate of transition from an open access to a fully regulated market a number of adverse effects could arise unless appropriate mitigation measures are put in place Specific issues which require attention in this plan are listed below bull potential risks of environmental degradation through development of new fishing targets in
deep water
58
bull localised environmental impacts at construction sites bull loss of resources for individual operators due to restricted or controlled access to fishing
grounds bull displacement of labour from crews of vessels that are withdrawn from the industrial and semi-
industrial fleet bull Decommissioning of obsolete industrial vessels may not necessarily lead to recovery of fish
stocks Catch Per Unit Effort (CPUE) may increase This could lead to loss of livelihoods to crew members and the owners of the decommissioned vessels it could increase catch for the few vessels remaining in the system
bull increase production costs due to idling time in closed seasons for fishing bull exclusion of some groups and individuals seeking entrance to the industry following completion
of licensing bull concentration of processing and marketing at selected landing sites leaving Fish Mammies and
their dependents in other smaller fishing communities at an economic disadvantage bull displacement of traditional canoe building and other ancillary support industries by more
efficient and modern methods of construction and the inability of some workers in these trades to train and re-skill in the use of modern materials
bull lack of employment opportunities in alternative sectors The ESMF will set out specific actions to address these concerns through a coordinated set of interlinked proposals as follows 1) Preparation of local management plans and close surveillance of all new fishing enterprises in
deep waters
2) Preparation of environmental protection clauses to be included in all contracts and agreements for physical development work
3) Regular inspection by environmental protection officers of construction work at harbours and landing sites
4) Establishment of community management plans to provide support to those groups and individuals who are adversely affected by any of the measures listed above
5) Creation of community liaison groups to actively support community development alternative livelihoods and conversion to new areas of economic activity for those Fisher families or individual fishers who are adversely impacted
6) Introduction of skills training centres and business advice for small and medium enterprise development
7) Establishment of a coastal development agency drawing on the resources of the ministry of local government agriculture and tourism (others to be added) to coordinate integrated projects and initiatives for economic development linked with the existing coastal zone management plans
8) Creation of a liaison group between the government of Ghana and its international development partners to ensure that investment in the fisheries sector is targeted in the most effective way to deliver plan objectives and avoid duplication of effort
59
83 COMPONENTS OF THE ESMF The following paragraphs provide a summary of the draft ESMF 831 Local Management Plans these plans will be prepared for discrete zones of influence around specified fishing settlements Each plan will contain the same standard list of relevant activities that are to be monitored 832 Environmental Protection In relation to construction activity a checklist will be prepared identifying precisely what level of environmental scrutiny is required for specific types of development This checklist will be prepared by the Fisheries Commission with the support and advice of the Environmental Protection Agency 833 Small-Scale Project Development and Livelihood Restoration a list of potential micro-projects will be prepared by the Fisheries Commission which are regarded as suitable for support funding Demand for these micro-projects will be determined at the local level (ie in villages and fishing communities) Applications for funding of micro-projects will be submitted to the community liaison group for vetting and recommendation based on pre-established eligibility criteria Recommended projects will be referred for formal approval at national level (or through the Coastal Development Agency) 84 POTENTIAL PROJECT IMPACTS ON ASSETS AND LIVELIHOODS The project will have some adverse impacts on assets and livelihoods Therefore provisions will be made under the ESMF to minimize all such impacts including those of socio- economic significance and on any environmentally sensitive sites Provisions are also made in the RPF to accommodate all potential situations including cases that may entail actual displacement and livelihood restoration assistance in accordance with the Governmentrsquos policy and World Bank Policy on Involuntary Resettlement OP412 (see Chapters 9 and 10) The potential social and environmental impacts associated with the project (see Chapters 5 and 6) are summarised in Table 81 and the approach to related mitigation measures is defined in section 85 and Table 82 below
Table 81 Potential Environmental impacts and Social issues
Type of Activity Description Environmental Significance
Social Significance
Decommissioning of obsolete industrial vessels
Scrapping of vessels may release toxic waste (contaminated oils asbestos pipe wrapping and insulation etc)
Contamination of landfill dumps
Related health hazards
Laying off of work force Recovery of fish stocks in areas currently over-fished by trawling
Decommissioning of excessovercapacity would result in loss of livelihoods for crew members
60
Plan for fishing capacity reduction
introduction of licensing system for canoes and enforcement of licensing system for semi industrial vessels
Reduced catch from the decline in the use of prohibited fishing methods (activities) as stipulated in the Fisheries Regulation 2010 (LI1968) eg use of light dynamite etc
Reduction in fishing capacity should lead to significant recovery of fish stocks with long term benefits for all
Short term reduction in fishing effort and increased regulation may prejudice vulnerable sectors (illiterate elderly fishers) Capping on new entrants may remove the safety net opportunity offered by fisheries to would-be fishers who may be without alternative livelihoods
Harbour development and landing site improvements
Construction of access road improvements Erection of fish processing and ice making plant The Project could give rise to a small level of physical displacement for some sectors of individual communities
Removal of shelters homes Displacement of boat repair and trading sites for local community
Possible non-voluntary resettlement including vulnerable groups (women children and the elderly)
Adaptation Strategies to climate change
Introduction over time of regulations relating to fishing activity in rivers lakes estuaries lagoons and lsquoareas of upwelling affected by climate change
Measures to combat tackle rising temperature and other climate induced changes should ameliorate environmental impacts
Both beneficial and adverse effects may result from changes in climate (eg faster growth rates from higher water temperature spread of invasive species)
Establishment of exclusion zones ndash oil production and marine protection areas
Restrictions on fishing in oil production areas and marine protection areas
Positive ndash recovery of fish stocks but also potential risks of pollution from oil leaks and human waste
Temporary loss of livelihood for those fishers displaced from lsquotraditionalrsquo fishing grounds
Development of Co-Management System
Creation of 4 pilot Stakeholder ndashbased Fisheries Management Initiatives
Demonstration of practical benefits for the marine environment resulting from elimination of damaging practices
Greater social cohesion and sense of purpose established
61
Type of Activity Description Environmental Significance
Social Significance
Support for PAPs Establishment of enterprise training programmes
Development of criteria for defining Project Affected Persons (PAP) Development of skills training schemes enterprise allowances alternative livelihoods fund
Major benefits for PAPs ndash but scope for misinterpretation mismanagement of programme at local level Jobs created under social significance should be familiar to the fishers ie things they will be willing to do
Developing Compliance Systems
Establishment of enforcement unit and development of facilities and training for participatory coastal surveillance of small-scale fisheries
This component will greatly improve controls over environmentally unfriendly damaging activities
A number of new jobs should be created under this programme
Improvements in fish processing technology
Development of more efficient fish processing plant
This measure should reduce significantly the proportion of fish lost or degraded post harvest Improved fish processing technology will also reduce wood used from the forest as firewood for fish smoking
Potential displacement of vulnerable groups (women children and the elderly)who currently participate in fish drying curing using basic equipment
Construction of fish ponds
Expanding areas of dug-outs and other farm ponds
Small scale impacts on vegetation stream flow
Displacement of existing land users
Catalysing aquaculture development
Encouragement of larger fish farming enterprises Installation of fish cage aquaculture
Localised deterioration in water quality increased nutrients leading to eutrophication potential spread of fish parasites disease
Potential competition with free capture fisheries displacing vulnerable groups in existing fishing villages
62
85 PROPOSED MITIGATION MEASURES AND COST ESTIMATES Mitigation measures The potential environmental and social impacts to be addressed within the context of preparing this Environmental and Social Management Framework are generalized as shown in Table 82 below It is not possible at this time to prepare specific mitigation measures It is expected though that environmental and social assessment studies will be carried out within specific localities as and when required The framework for compensationresettlement (See Chapters 9 and 10) will then be applied incorporating (1) specific institutional arrangements (2) resettlementcompensation eligibility criteria (3) implementation procedures (4) financial responsibilities and (5) monitoring and evaluation plan Livelihood restoration measures Furthermore the livelihood restoration measures will consider issues such as
(1) income levels of affected persons
(2) other non-monetary sources of livelihood
(3) constraints and opportunities for income generation
(4) number of persons not able to revert to previous occupation and
(5) existing skills of affected persons
Table 82 Proposed mitigation measures for some potential impacts
Type of Impact Description of mitigation measures
1 Decommissioning of obsolete industrial vessels
a) A register will be prepared of all industrial vessels that are due to be decommissioned recording the owner and location of each vessel b) A system will be introduced for tracking progress on decommissioning including the means of disposal and measures taken to dispose of all potentially toxic or hazardous materials c) Persons who lose their job or livelihood as a result of a decision to decommission any particular vessel will be entitled to benefit from the skills training schemes enterprise allowances alternative livelihoods fund being developed
2 Plan for fishing capacity reduction
a) A full Social and Environmental Impact Assessment will be carried out on the Plan for fishing capacity reduction and appropriate measures for ameliorating and mitigating adverse effects on affected sectors of the community and PAPs will be incorporated in a revised edition of this Fisheries Environmental and Social Management Framework
63
3 Harbour development and landing site improvements
a) All harbour development proposals will be subject to Environmental and Social Impact Assessment (ESSA) in accordance with EPA Regulations b) Proposals for improvement of individual landing sites will be assessed in accordance with the checklist (832) and submitted to EPA for a ruling on the level of environmental assessment that is required which will depend on the nature of the intended works
4 Adaptation Strategies to climate change
a) An adaptation Strategy shall include proposals for mitigating any impacts on the environment or social welfare of local communities
b) Any strategy for responding to potential effects of climate change on the fisheries sector will be submitted to EPA for review to determine whether an SEA or EIA is required
5 Establishment of exclusion zones ndash oil production and marine protection areas
a) Proposals for restricting access of fishing vessels to oil production areas and marine production areas shall be subject to an Environmental and Social Assessment which shall be submitted for approval to EPA b) In the event that restrictions are likely to adversely affect fishersrsquo livelihoods the provisions set out in 7 below will apply
6 Development of Co-Management System
a) Development of co-management systems will require full cooperation and engagement of all stakeholders In the unlikely event that the provisions of any scheme are challenged by local communities there shall be a right of appeal to the Minister of Food and Agriculture and the Fisheries Commission acting jointly
7 Support for PAPs
Establishment of enterprise training programmes
a) Identification of vulnerable people including women children and the elderly and identification of the cause and impacts of their vulnerability shall be established through direct interviews and procedures to be developed as part of 6 above b) A high priority within the Fisheries and Aquaculture Sector Development Plansrsquo first five year programme will be the development of specific proposals for the establishment of skills training programmes and the establishment of enterprise allowances and an alternative livelihoods fund c) The measures outlined in 7b) above will be targeted specifically at PAPs and vulnerable sectors of the community
8 Developing Compliance Systems
a) All proposals for securing compliance with fisheries regulations shall be subject to review by a fisheries stakeholder committee to be established by the Fisheries Commission with the remit of ensuring that the measures themselves and penalties for failure to comply are commensurate with the ability of offenders to make restitution and do not unfairly penalize vulnerable sectors of the community
9 Improvements in fish processing technology
a) All plans and proposals for the introduction of new fish processing technology shall be published and shall include a statement on the likely impact of the project on existing processors within the local community
64
b) Any members of the public who consider they are unfairly disadvantaged by proposals for the introduction of new technology may apply to the local co-management committee to determine whether or not they fall within the category of PAP (see 6 and 7 above)
10 Construction of fish ponds Proposals for the construction of new fish ponds shall be assessed in accordance with the checklist (see section 832)
11 Catalysing aquaculture development
a) All proposals for aquaculture development shall be in accordance with the provisions laid down in Local Management Plans applying to specific TURFs
65
3
bull Improve the services provided to the fisheries sector by the Fisheries Commission and supporting institutions
The Draft ESMF sets out eight specific interlinked actions namely
1) Preparation of local management plans and close surveillance of all new fishing enterprises in deep waters
2) Preparation of environmental protection clauses to be included in all contracts and agreements for physical development work
3) Regular inspection by environmental protection officers of construction work at harbours and landing sites
4) Establishment of community management plans to provide support to those groups and individuals who are adversely affected by any of the measures listed above
5) Creation of community liaison groups to actively support community development alternative livelihoods and conversion to new areas of economic activity for those Fisher families or individual fishers who are adversely impacted
6) Introduction of skills training centres and business advice for small and medium enterprise development
7) Establishment of a coastal development approach drawing on the resources of the ministry of local government agriculture and tourism (others to be added) to coordinate integrated projects and initiatives for economic development linked with the existing coastal zone management plans
8) Creation of a liaison group between the government of Ghana and its international development partners to ensure that investment in the fisheries sector is targeted in the most effective way to deliver plan objectives and avoid duplication of effort
Chapter 9 provides a draft National Process Framework (NPF)) to implement the recommended process framework laid down by the West Africa Regional Fisheries Program (WARFP) which Ghana will become part of This framework explains how eligibility criteria will be employed to determine which settlements qualify as participating communities and what the responsibilities of these communities will be in terms of setting up Co-management Committees (CMCs) and selecting classes of Project Affected People (PAPs) who will be eligible for assistance under national guidelines to be prepared by the Fisheries Commission The ESMP also outlines proposals for income restoration measures in accordance with World Bank guidance as interpreted through the West Africa Regional Fisheries process framework that where open access to fishery resources is restricted for the common good any adversely affected individuals should not be penalized but should receive assistance to restore their livelihoods at least to the extent that they are impacted by the project activities and preferably to an improved state1
1 Extract from Executive Summary Process Framework West African Regionl Fisheries Program (P106063) Cape Verde Liberia Sierra Leone Senegal Commission sous Regionale des Peche Dakar Senegal
Measures are also outlined for conflicts or grievance resolution administrative and legal procedures and monitoring arrangements
ldquoSection V Livelihood Restoration Measures World Bank policy requires that livelihoods be restored at least to the extent that they are impacted directly by project activities and preferably inproved This policy prescription is based on the principle that people who give up most for the public good ndash the PAPs- should not be penalised and impoverished as a result of their loss for the greater good The aim thereopfre is to improve the public good (in this instance marine resources) while also ensuring that those who lose access to resources and income because of restrictions on marine resources are assisted effectively to restore that part of their income that is affected through alternative livelihood measuresrdquo
4
Chapter 10 looks in more detail at specific safeguards relating to possible involuntary relocation of people as a result of the long term fisheries programme It constitutes the Resettlement Policy Framework (RPF) which while not a formal legal requirement of the World Bankrsquos lending policy is nevertheless recommended as good practice
5
PART A ENVIRONMENTAL AND SOCIAL SAFEGUARDS ASSESSMENT
The Environmental and Social Safeguard Assessment comprises bull Three background chapters (1-3) bull Two chapters which deal with assessment of the potential effects of the World Bankrsquos financial
and technical support for the Ghana Fisheries Programme over the initial five years (Chapter 4) and the longer term effects of the overall Fisheries Programme which is expected to run for 10-15 years (Chapter 5)
bull Analysis of the consequences of taking no action (the do-nothing option) in Chapter 7 and bull A draft Environmental and Social Management Framework (Chapter 8)
7
CHAPTER 1 INTRODUCTION
11 INTRODUCTION The government of Ghana is embarking on a Fisheries and Aquaculture Sector Development Plan (FASDP) for restructuring its coastal and inland fisheries The aim is to reverse the current trend whereby fish stocks are increasingly diminishing and the current rate of fishing is unsustainable resulting in less productive fisheries increased costs with declining profitability and the risk of exacerbating nutritional deficiencies and poverty within fishing communities To date the government has enacted legislation (Fisheries Act 2002) prepared policies (2008 updated in 2010) and published regulations (August 2010) but the Ministry of Food and Agriculture and the Fisheries Commission lack the capacity and financial resources to implement all of these initiatives The World Bank is therefore considering a supporting programme of technical assistance and finance which will assist with governance reforms the introduction of licensing for all vessels a reduction in the size of the industrial and semi-industrial fishing fleets and the progressive transfer of fishing activity to the canoe sector International support for Ghanas fishing industry is being coordinated under the West Africa Regional Fisheries Programme (WARFP) This initiative began with four countries Cape Verde Liberia Sierra Leone and Senegal It is now being extended to the following countries Ghana Guinea Guinea Bissau and Gambia A process framework has been developed by the Commission sous Regionale des Peche (Based in Dakar Senegal) to assist member countries of WARFP to prepare their own national process frameworks together with accompanying environmental and social safeguards assessment an environmental management plan and resettlement policy This report has been designed to provide the outline structure and contents for these documents on behalf of the Government of Ghana Another important function of the report is to review the application of the World Banks own Environmental and Social Safeguard policy to the planned investment Both the governments development plan (FASDP) and preparation of the World Banks financial assistance package are at an early stage Consequently this report covers (and can only cover) the broad principles and sets out initial conclusions It will be necessary for further reviews to be undertaken when the Government of Ghanarsquos programme has been developed in more detail Objectives of the Environmental and Social Assessment (ESA) The overall aims of planned interventions in the fisheries industry of Ghana are to improve fish stocks and increase the sustainability of fishing activity which will have long-term environmental and social benefits for the country However the process of introducing change is likely to have some short-term adverse effects on individuals and particularly those who are vulnerable or disadvantaged within poorer fishing communities unless appropriate mitigation measures are taken The purpose of the environmental and social assessment set out in chapter 6 is to identify potential environmental and social impacts both individually and cumulatively and to assess their relative magnitude duration reversibility and importance Based on these findings the draft management framework (see chapter 8) sets out proposals for avoiding or mitigating unacceptable change The process of reforming the fisheries sector will take a number of years and the existing FASDP covers only the first five years With the exception of proposals to scale down the size of the industrial and semi-industrial fishing fleets it is unlikely that major changes will take effect in terms of fishing activity during this five-year period Consequently from the standpoint of the World Banks investment there are likely to be relatively few issues in terms of potential conflict with safeguarding policies Later
8
however significant change is within the fishing industry and particularly onshore processing and marketing of fish products An important element in this report has therefore been the need to define the point at which the banksrsquo responsibilities are seen to terminate and all liabilities are transferred to other supporting donors and the government of Ghana In the short term a reduction in the industrial fleet may lead to the loss of 1000 to 3000 jobs for crew members although in practice most of this work is only part time and many of the vessels that are due to be withdrawn are no longer seaworthy In the longer term it is intended to encourage more selective fishing by limiting open and unfettered access to fish stocks eliminating illegal and damaging processes including dynamiting uncontrolled light fishing and the use of small size monofilament nets and introducing seasonal restrictions to protect breeding cycles The intention is that these measures will be managed jointly by the government and communities through co-management systems At the same time major efforts will be made to reduce the level of post-harvest losses and to increase the value of fish products The expectation is that the number of industrial semi-industrial vessels and canoes will be stabilised at a fixed lower level within five years Once this point is reached and no further licences are granted individual licences will acquire higher values especially as fish stocks recover and the size and value of fish catches starts to increase Subsequently licenses are likely to be sold and traded as less efficient owners drop out of the market and sell on to stronger individuals and companies In terms of onshore activities fish landing processing and marketing will become more efficient and losses will be reduced through use of better smokers freezing and drying equipment Previous studies in West Africa and elsewhere (Bennett et al 2001) have shown that the transition away from open access to a more regulated system of access management can give rise to social risks Specifically older men are likely to be displaced when they are no longer fit enough to withstand the rigours of fishing while a rising number of young men may find it harder to enter a career in fishing Women who currently manage or assist with all areas of buying processing and marketing using traditional clay ovens may also experience competition as new companies and enterprises are established to take advantage of higher profitability in the fishing sector perhaps using better equipment newer technologies and different logistics arrangements or their own transportation Methodology This study has followed the methodology developed within the process framework for the West Africa regional fisheries programme (WARFP) Figure 1 sets out both sequence and timescale for the work
The range of jobs at risk is based on assumptions about the number of vessels and average crew size and cannot be determined with any degree of accuracy until the necessary surveys are undertaken
9
The report is based on three major areas of activity 1 documentary analysis and utilisation of the studies already carried out by the fisheries commission 2 meetings with institutional stakeholders principally affected by the project and 3 Consultations and visits to some of the key fishing villages and communities The planned presentation of findings to Stakeholders has been postponed at the Clientrsquos request due to other pressing commitments in the agriculture and fisheries sectors This presentation will however need to be subsequently undertaken by the Ministry and the Fisheries Commission
11
CHAPTER 2 PLAN AND PROGRAMME DESCRIPTION
INTRODUCTION This chapter is divided into two parts Part 1 sets out the progress which the government Ghana is making in giving effect to the legislation policy and regulations Part 2 describes the proposed programme of assistance being offered by the World Bank with the specific aims of strengthening governance and enforcement systems (Components 1 and 2) and in promoting value addition and reduction of post-harvest losses
PART 1- THE DRAFT FISHERIES AND AQUACULTURE SECTOR DEVELOPMENT PLAN (FASDP) This plan (FASDP) covers the period 2010-2015 It recognises the importance of Ghanarsquos fisheries which generate in the order of US$ 1 billion a year contribute 45 to GDP and indirectly support the livelihoods of 22 million people However through over-fishing and lack of investment in management and value addition the average income per canoe has dropped by up to 40 over the last ten years to the point where it costs as much to fish as the catch is worth By comparison well managed fisheries in other parts of the world are capable of generating economic returns of 30-60 on investment (equivalent to a potential income of US$ 300 million a year for Ghanarsquos fisheries) The Draft FASDP acknowledges that the fishing sector is expected to make a substantial contribution towards doubling the size of the Ghanaian economy by 2015 (GPRS II) as part of the Republic of Ghana Fisheries and Aquaculture Policy Seven targets are set in the draft FASDP 1 Maintaining capture fisheries production at current levels 2amp3 Increasing revenue and profitability in capture fisheries by at least US$ 50 million a year after
five years 4 Increasing aquaculture production to 35000 tonnes a year after five years 5 Retaining Ghana as a landing and processing hub for the West Africa tuna industry 6 Developing fisheries management to allow effective control of all commercial fishing effort in
Ghanaian waters and 7 Ensuring fisheries management costs are sustainable and that the fisheries sector overall make a
fiscal contribution to Government revenues There is an underlying presumption that the canoe sector will remain at the heart of Ghanarsquos fishing industry but the plan is not prescriptive and leaves open the ways of achieving the overall goals At the same time there is an underlying assumption that the long term sustainability of Ghanarsquos fisheries will depend upon discouraging further entry by new operators
PART 2 THE WORLD BANKrsquos CONTRIBUTION TO GHANA FISHERIESPLAN (FASDP)
The essential aim of the World Bankrsquos contribution to FASDP is to provide investment which will build the necessary policy and capacity for effective fisheries management designed to reduce fishing effort while maintaining approximately the same catch levels and to address the impacts of change for fishers
12
and the communities in which they live Based on the currently available draft Project Appraisal Document (PAD) each of the components is now described in turn Component 1 - Good governance and sustainable management of the fisheries This component on good governance comprises four subcomponents which are broken down in turn into a number of separate activities Sub-component 11 developing the capacity rules procedures and practices for good governance of the fisheries Activity 111 reviewing the Fisheries Act and developing regulations to support the Sector Policy and the Fisheries and Aquaculture Sector Development Plan Activity 112 Developing an operational policy to enable implementation of the aquaculture and fisheries sector development plan Activity 11 3 strengthening fisheries management systems and capability (fisheries management plan development aquaculture implementation technical support and training) Activity 114 strengthening fisheries Information Systems (catch recording and monitoring systems statistical analysis and training)
Sub-component 12 introducing fishing rights
Activity 121 developing pilot stakeholder-based fisheries management initiatives around defined fisheries units (ie local management initiatives tighter defining fisheries resources in up to 6 selected Fisher communities) Activity 122 introducing and administering a licensing regime
Subcomponent 13 Adjusting fishing effort and capacity to more sustainable levels marine resource conservation and supporting alternative livelihood opportunities when needed Activity 131 vessel decommissioning Activity 132 compensation packages for crew of decommissioned industrialsemi-industrial vessels Activity 133 alternative livelihood development to incentivise voluntary capacity reduction in the canoe sector Activity 134 marine resources management and conservation
Subcomponent 14 social marketing communication and transparency Activity 141 communications stakeholder consultations and awareness raising programmes to support fishery development Component 2 reduction of illegal fishing Under the West Africa regional fisheries programme subcomponent 21 allows for enabling environment for reduction of illegal fishing These provisions already exist within Ghana and this subcomponent is therefore omitted Subcomponent 22 monitoring control and surveillance (MCS) systems Activity 221 developing compliant systems and capability
13
Component 3 increasing the contribution of the marine fish resources to the local economies Subcomponent 31 product diversificationvalue chain development (freshfrozen producttrade facilitation) Activity 311 landing site development Activity 312 Port development Subcomponent 32 fish product trade infrastructure information and systems - regional minimum integrated trade expansion platform (MITEP) Activity 321 export certification centre development Activity 322 fish processing technology improvements Activity 323 national fisheries advisory group Subcomponent 33 marine and inland aquaculture development Activity 331 space developing aquaculture policy and legal framework Activity 332 improving genetic policy of tilapia fingerlings and breedstock Activity 333 catalysing aquaculture development Component 4 Coordination monitoring and evaluation and program management Subcomponent 41 national implementation subcomponent 42 regional coordination Each of the components sub-components and activities are described in more detail in Chapter 5 which assesses the nature of environmental and social safeguards issues in terms of the World Bankrsquos planned investment
15
CHAPTER 3 BASELINE CONDITIONS
INTRODUCTION This chapter discusses the existing fishery resources of Ghana and describes recent environmental and social trends It identifies some of the pressures that led to the reduction in value of fishing activity and indicates the threats that could be posed if no action is taken in accordance with the planned fisheries and aquaculture program to deal with them FISHERY RESOURCES The continental and coastal waters of Ghana are potentially very rich due to a combination of warm waters and nutrients carried in ocean currents which up-well seasonally on the continental shelf The tonnage of fish caught in marine waters peaked in the mid-1990s around 500000 tonnes and currently averages around 400000 t(See Figure 1) Figure 1 Wild Capture Production in Ghana 1950-2005
2
Table31 Top 10 Species Exported (by value)
1 Canned tuna ($72000000) 2 Fresh tuna ($7200000) 3 Tilapia (no figure available) 4 Miscellaneous dried fish ($1000000) 5 Salmonids frozen ($900000) 6 Marine fish frozen ($600000) 7 Cuttlefish and squid ($600000) 8 Shrimps and prawns ($90000) 9 Sardines ($80000) 10 Crustaceans frozen ($50000) Source FAO Fishstat
The principal catch from deep waters is tuna Industrial vessels registered in Ghana target these species in international waters but also illegally in coastal waters Herring sardine and anchovies are fished in coastal waters by semi-industrial vessels and canoes Table 31 shows the top 10 species of fish exported from Ghana in 2005 PROFILE OF THE FISHING INDUSTRY Fishing is of vital importance in Ghana not only in terms of its contribution to gross domestic product (45 per annum) but because fish provides 65 of the countrys protein In recent years (between 2003-2008) and more specifically in 2004 the countryrsquos annual fish requirement has been estimated to be 882000 tonnes of which the country produces just about half (Tetteh 2007) Of the total population of 22 million people it has been estimated that between 15 and 22 million people are employed or gain their livelihoods from fishing (8-10) Of these there are 210000 men who are directly employed as
2 This figure is the Fisheries Departmentrsquos estimate for 2008
16
fishers The total export of seafood was valued US$824 billion in 2005 Ghanas fishing industry can be divided into three sections marine capture inland capture and aquaculture It can be further analysed by scale of operations distinguishing between industrial semi-industrial and artisanal sectors Marine fisheries Industrial sector Commercial fishing for tuna began in 1962 In the early 1980s Ghana sought to develop an industrial fishing fleet and there are currently 90 industrial trawlers and other vessels which are located in Tema and Takoradi Sekondi The port of Tema was expanded from 1962 to create four main areas the Inner Harbour Outer Harbour Canoe Basin and Commercial Area In 1999 fish landing facilities were improved at the Albert Bosumtwi Sam Fishing Harbour built in Sekondi This harbour is equipped with a cold store an ice-making plant offices a berthing bay for inshore vessels a jetty for canoes and a net drying area Under Ghanaian law more than 50 of the ownership of industrial vessels must be registered with a Ghanaian company or individuals However in practice many vessels are owned by foreign nationals with token Ghanaian ownership Relatively few of these large vessels regularly put to sea and a number are in poor condition or obsolete Nevertheless the impact of trawling activities by Ghanaian registered and foreign owned vessels has been very considerable in coastal waters in recent years Fish landed from industrial vessels is usually transferred directly to Canning factories in Tema and Takoradi Ghana has the largest canning industry in West Africa In the region of 30000 tonnes of tuna are landed In addition to trawling some industrial vessels are engaged in shrimping the use of tuna lines and polls purse seining and demersal trawling Semi-industrial sector in addition to deep sea trawlers there are around 230 large semi-industrial ships propelled by inboard motors which are used for trawling in shallow waters during the off-season and purse seining during upwelling seasons There are currently reported to be 48 bottom trawlers 14 pair trawlers 2 shrimpers 33 pole and line vessels and 10 tuna purse seiners operating from 2 of the 7 landing sites Canoe sector Ghanas artisanal fishing sector is based on between 10000 and 12000 wooden canoes Fifty seven per cent of the fleet is powered by outboard motors supported by paddle and occasionally sail Each Canoe carries a crew of between three and 20 men depending on size and length There are over 334 landing sites along the 550 km coast of Ghana and the majority of fish caught by canoe (180000 tonnes) is returned to these sites accounting for 70 of Ghanarsquos fish production The principal landing sites are at Teshie Jamestown Chorkor Shama Axim Elmina Winneba Mumford Akplabonya Adina Atiteti Abutiakope and more Fishing is undertaken by men but the majority of canoes are owned by women who pre-finance fishing trips (purchasing gear and premixed fuel) and purchase the catch Women also predominate in processing and marketing fish and fish products Only about 20 of fish sold fresh a further 20 is salted and the majority (60) is smoked It is estimated that up to 30 of the catch is spoilt through lack of ice for storage or alternative processing facilities
17
Inland fisheries Water Resources Ghanarsquos inland fishery resources consist of a natural lake( Lake Bosomtwe) and nine major river basins which from east to west of the country are
bull the Volta bull Densu bull Ayensu bull Ochi bull Kakum bull Pra bull Ankobra and bull the Tano
The River Tano forms the border between Ghana and Cote drsquo Ivoire The largest of the rivers is the Volta which drains more than two-thirds of the country through several large tributaries in virtually all regions of the country The Volta river system also incorporates the Volta reservoir generally known as the Volta Lake which has a surface area of around 8400 km2 The Volta lake discharges through the Akosombo dam before flowing through a delta into the Atlantic Ocean The eight other river systems are relatively smaller simpler and open more directly into the Atlantic There are also several reservoirs created on the smaller river systems mainly for potable water production irrigation and flood control These reservoirs irrespective of their primary purposes enhance availability of more permanent aquatic habitable space for fish and therefore support some fisheries Finally with all the river systems opening into the Atlantic there are a series of lagoons and estuaries which act as interfaces between the rivers and the sea These water areas constitute another type of inland water resource for salt and brackish water fishes Inland Fish resources Within the inland water resources of Ghana there are over 150 fish species more than 90 of which are fished for food
In commenting on inland fisheries in Ghana it must be noted that virtually all available information on inland fisheries is obtained from the Volta Lake No national fish production records have been kept on the fisheries of the eight smaller river systems and the lagoons and estuaries Thus the usual statement that inland fish production constitutes about 20 of what the country produces should refer to fish production from the Volta Lake In practice the total inland fish contribution could more realistically be estimated at about 30-35 of national fish production This is a very considerable but understated contribution to national food security and nutrition
Fishing vessels The dominant fishing vessel on the Volta Lake is the canoe the majority of which are built from wooden planks On some other river systems while plank canoes predominate a small number are carved as dug-outs from single tree trunks There is some variety in sizes of the canoes depending on how many planks are used to build the boat and the size of tree trunk used in building a canoe The total number of canoes estimated on the Volta Lake during a survey in 2000 was 24035 On the tributary rivers of the Volta Lake and other river systems in the country the planked canoe is the main vessel used in fishing
18
Fishing gear There are about eleven main kinds of gear used for fishing on the Volta Lake They are Gill Nets Cast Nets Hook and Line Basket and wire mesh traps Winch net Beach seine Bamboo Nifa-nifa Wangara Spears and Atidzas On other rivers in the country Gill nets Cast nets Hook and Line and traps are the fishing gear used On both the lake and rivers the Gill net is the main gear
People Involved In the 2000 frame survey of the Volta Lake conducted by the Fisheries Directorate of Ghana the estimate of fishers on the Volta Lake was put at 71861 Fishers on the lake work in collaboration with a host of fishmongers or handlers who also function as wholesalers for individual fishing groups Assuming that the fisher population on the lake has increased by a modest 3 in the ten years from 1998 to 2010 a fisher population of about 93500 could be considered to be on the Volta Lake now If again it is estimated that number of fishers on rivers in the country were to be a tenth of those on the lake this would put the fisher population on inland waters (apart from the Volta Lake) at about 9350 fishers A very conservative estimate therefore puts the total number of individuals who are directly engaged in inland fishing at over 100000 This excludes all directly associated groups such as fish handlers processors and traders An estimate of secondary fisheries operators such as boat builders out-board motor operators and mechanics as well as bulk salt and fuel wood sellers and those engaged in buying selling and distributing fish would have to be considered in developing estimates for both direct and indirect employment in inland fisheries but the number can be assumed to lie between 125000 and 150000 people
Aquaculture Under Ghanarsquos legal framework aquaculture is defined as ldquoany activity designed to cultivate or farm fish and other aquatic living resourcesrdquo Currently only fin fishes are involved in aquaculture in Ghana
Current culture media and environment Currently fish culture takes place almost exclusively in fresh water in Ghana either in cages brush parks or dugouts Dug-outs are excavations made in floodplains in the savannah parts of the country were water scarcity has been a major hindrance to development in general and food security in particular Dug-outs get filled with flood waters and whatever the water carries during major wet periods of a year in the savannah areas Waters that fill Dug-outs invariably contain fish which are trapped in the Dug-out after the wet period These water bodies are managed until the end of the dry period and the fish are harvested before the next flood period Since the 1960rsquos various strategies to augment fish production from Dug-outs have been developed and tested These involve adding fingerlings of selected fish species to those which are lsquonaturally stockedrsquo in Dug-outs by floods Dug-outs are the major fish culture production approach in the savannah parts of the country which accounts for a little more than half the area of the country The Environment of fish culture Currently fish culture is taking place mainly in freshwater environments Brackish water fish culture and mari-culture activities which will bring lagoons estuaries and the sea into fish culture production have long term potential for development Fishes in culture Fishes being cultivated in Ghana In order of importance are Nile tilapia Oreochromis niloticus the African catfish Clarias gariepinus species of the catfish Heterobranchus and the Bony tongue Heterotis niloticus Scale of Culture Based on level of production fish culture operations can be categorized as follows
bull Large scale commercial where an enterprise produces up to 10000 tonnes per year
19
bull Medium scale commercial where a single enterprise produces between 50 and 500 tonnes bull Small scale commercial where an enterprise produces between one and 20 tonnes and bull Very small scale commercial with productions below 20 tonnes
Fish culture production Cultured fish contribution to national production was officially stated as 9000 tonnes for the year 2009 However informed opinion amongst fish farmers indicates that a figure of between 16000 and 20000 tonnes in 2010 would be closer to reality This statement is based on the facts that most producersrsquo published figures are underestimates several small to medium scale producers are not recorded in official lists and the recording of newly established fish farms has lagged actual establishment especially since 2009 Although cultured production up till 2009 may not have been significant considering a shortfall of about 460000 mt (as recorded in 2004) between captured fish production and national demand this reflected the fact that there were only two large scale commercial producers in the country each of which had had less than ten years of operation Anticipated growth in fish culture production within the next five years is expected to be dramatic as some of the critical challenges of the industry are resolved
CHALLENGES AND PROSPECTS Marine Fisheries The fishing sector is vital for food security and job creation to help alleviate rural poverty in Ghana However the levels of fisheries harvests are generally considered to be close to or to have exceeded the maximum sustained yield Future sustainability in the industry will depend upon the restriction of open access to fisheries and the introduction of management systems which allow fish stocks to recover and the establishment of consistent yields in both marine and inland waters Inland Fisheries Environmental conditions on the Volta Lake constitute the major environmental and social challenges for fisheries its sustainability and profitability In terms of future prospects success will depend heavily on implementation of the lsquoGhana Fisheries and Aquaculture Sector Development Planrsquo and the capacity of the system in Ghana to enforce the Fisheries Regulations passed by parliament in August 2010 Aspects of the Development plan that offers great prospects for the lakes fisheries include the provisions for eventually licensing boats (although the scale of this task should not be underestimated) and measures to involve communities in management of fisheries resources of the Lake
Aquaculture The main challenges facing aquaculture development in Ghana relate to bull The high cost of fish feed (significantly due to its importation from other countries) bull None availability of commercial fish hatcheries as enterprises bull Lack of a nation-wide distribution network for fish seed and cultured fish producers Most
sources of fingerlings are concentrated in one part of the country and since farms all over Ghana obtain their fingerlings individually transportation costs add significantly to overall production costs
bull Now emerging certification and monitoring to check the health and safety of aquaculture processes and products
bull The absence of adequate regulations regarding establishment of an aquaculture enterprise until August 2010 (In the absence of regulations only the large and medium scale commercial farms worked towards conforming to international performance Standards and operational regulations for certification of farms and their products still remain in a draft state)
bull Low national support for research to support expansion and systematic development of aquaculture
20
The prospects for development of aquaculture as an industry in Ghana are good since a number of practical policy and legal frameworks have been put in place to resolve the basic challenges to the industry listed above These include
bull Construction of the first local fish feed plant by an international fish feed company with the expectation of having initial products on the Ghanaian market during 2011
bull A lsquoLarge scale commercial fish farmrsquo with great capacity for fingerling production is shifting emphasis to fish seed production And several localized fish seed producers are expanding operations
bull Distribution strategies by cultured fish producers have started to emerge on a limited scale and are expected to evolve with increasing production as existing commercial farms expand and new ones join in
Now that regulations regarding establishment of aquaculture enterprises have been gazetted there is likely to be a positive response amongst fish farmers of all size categories New operational standards are being prepared which will introduce minimum standards for local certification This should set the stage for preparation of fish culture products and the broadening of choice for consumers while also qualifying Ghanaian producers to enter external markets
ENVIRONMENTAL CONDITIONS The coastal and marine environment a critical zone of influence for this study comprises a 550 km coastline a coastal belt ranging from 1 to 20 km in width and coastal waters extending to 200 nautical mile limit which was established in 1977(under the territorial waters and continental shelf act 1973 as amended by the territorial waters and continental shelf amendment decree 1977) The Coastal Belt The coastal belt accounts for only 65 of the land mass of Ghana but it is one of the most densely settled areas accounting for 25 of the population and80 of the industrial establishments in Ghana Historically the coastal zone was cultivated for coconut (copra) but this industry is in decline Vegetables and other agricultural produce are grown on better soils but the principal economic activities are fishing transportation salt production and sand and stone winning Tourism also offers great potential There is considerable expectation that the discovery of offshore oil and gas deposits will bring new wealth to parts of the coastal corridor However present plans to transfer crude products to tankers at sea and then export them directly will limit industrial activity to a support role A high percentage of industrial and municipal wastes is dumped at landfill sites within the coastal zone which creates pollution risks The coastal belt is generally a low-lying area less than 200 m above sea level Vegetation types reflect the rainfall gradient and consist of coastal shrub and Savannah to Winneba southern marginal forest to the east of Sekondi dry semi-deciduous and moist semi-deciduous forest to the east of Cape Three Points estuary and wet evergreen forest in the extreme south Soils are variable within this area ranging from fertile pockets river valleys to Sandy poorer quality soils close to the sea The Coast The coast line divides into three sections (Ly 1980)
bull West of Cape Three Points this area has a wide and flat beaches backed by coastal lagoons and
21
wave heights are generally low bull Between Cape three points and Tema the coast consists of a series of rock headlands enclosing
shallow bays together with sandbars or spits enclosing coastal lagoons The surf zone is a medium to high energy environment with wave heights often exceeding 1 m South-westerly prevailing winds give rise to longshore drift in an easterly direction
bull Between Tema and Aflao most of the shore is sandy although there are rocky outlets The coastal zone is important internationally in providing feeding roosting and nesting sites for thousands of migratory birds Environmental degradation is significant in Ghana and is recognized in the countryrsquos environmental action plan It contributes to rising poverty levels coupled with poor human health and inadequately planned urbanization which fuel a vicious cycle inhibiting human development The core issues include
bull Domestic sanitation bull Increased urbanization without appropriate infrastructure bull Wetlands and mangrove degradation bull Coastal erosion and bull General biodiversity loss
Briefly each of the above could directly or indirectly adversely influence fisheries and aquaculture separately or together For example in a recently completed study of water quality scenarios of the Volta Lake in relation to fish production as a component of a comprehensive study (The Challenge Program Project of Water amp Food) it was concluded among others that poor sanitation in highly populated fisheries communities adversely influenced water quality to the detriment of fish life and thus fish production With reference to aquaculture the same unsanitary conditions in highly populated shore communities adversely influenced water quality especially in terms of oxygen depletion when lake waters extend to the shore in high water periods This is a situation which has caused fish kills in cages because caged fish cannot escape lsquopollutedrsquo waters Degradation of wetlands and mangroves leads directly to a reduction in their capacities as spawning and nursery zones for both marine and inland water fishes which reduce fish production in both environments The situation outlined above is often contributed to by anthropogenic and industrial pollution due to urbanization without appropriate infrastructure Another issue linking human activity to a deteriorating environment is demonstrated by the encroachment of aquatic weeds on inland waters such as the Volta Lake Weed growth is accelerated by farming reservoir catchments which increases nutrient levels and the building of dams which reduce or cut off intrusion of sea water into rivers Currently as climatic change observable impacts such as floods seem to escape predictions The project could possibly contribute to mitigating against direct and indirect effects of climate change on fishing and aquaculture through investment into climate change orientation and education of fishers and fish farmers to mainly influence reasonable precautions they take Marine waters The continental shelf is relatively narrow projecting out to 25-35 km except in the area of Cape Coast to Salt Pond where it extends to almost 80 kms Sandy and rocky substrates which previously supported coral and seaweeds have been severely affected by former trawling activity which indiscriminately
22
dredges material from the seabed Coastal waters are enriched by freshwater discharges from the relatively small number of rivers and by two seasonal up-wellings which occur between late June and early October (the main upwelling) and January and March (the minor upwelling) The origin and driving mechanisms of these up-wellings are not fully understood and both their location and strength varies from year to year
Lake Volta and other inland water
Major environmental issues on the Volta Lake which might also be considered as challenges to sustainable fisheries on the major inland fisheries resource can be summarised as follows
bull The Volta Lake is known to be low in nutrients It therefore has low standing crops of phytoplankton and zoo plankton to support high fish production
bull The northern segment of the lake together with tributary rivers constitute the spawning and feeding grounds for majority of fish species in the lake during the wet season however these segments are intensely fished during the same period
bull The Volta Lake is divided into eight unequal strata with different distribution of boats per Km2 At the last estimation of carrying capacity in 2000 stratum V and II had the highest (527) and lowest(157) number of boatsKm2 respectively
bull The rate of siltation in the lake is considered to be increasing due to erosion associated with high rates of deforestation
bull A major challenge exists in getting fishers fishing communities and fishing entrepreneurs to understand and comply with fishing regulations aimed at conserving fish and fisheries resources
bull There is a lack of resources studies and research to support fisheries management of the Lake
bull High illiteracy exists amongst lake shore communities
bull Open access to the fish resources of the Lake has been in operation since its formation
bull Declining fish yields are occurring in the lake (468 Kgha in 1976 to 320 Kgha in 2003-MOFA) brought about by the constraints listed above
bull The commonly assumed estimate of potential fish production from the lake of around 75500 mtyr) is considered to be a serious underestimate since Stratum VII alone was estimated to produce 33800mtyr in 1996
bull The policy environment for aquaculture is currently strongly supportive of the industry and related enterprises
bull There is good quality and more than sufficient water to allow some kind of aquaculture to be developed in every region of the country with the Volta lake (about 8400 Km2) as the single most important water unit for fish culture Currently it appears that the free access to the fish resources of the lake has to some extent been applied to establishment of small scale caged fish culture enterprises a situation constituting environmental risk to investments of large scale commercial fish culture establishments in the lake
bull The Volta Lake is low in nutrients (Obeng 1964) resulting in a situation where higher fish yields could be sustained if greater quantities of fish feed were available
23
bull In Ghana the Nile tilapia O niloticus occurred naturally only in the Volta system Due to positive culture characteristics of the fish it has been moved into virtually all other river basins in the country The situation provides opportunities for hybridization of the Nile tilapia with other tilapia species native to the river basin into which the Nile tilapia has been moved
25
CHAPTER 4 POLICY AND LEGAL FRAMEWORK FOR ENVIRONMENTAL AND SOCIAL ISSUES
41 INTRODUCTION
Development and implementation of the Ghana Fisheries and Aquaculture Sector Development Plan and the World Bankrsquos supporting program need to be developed with full regard to existing international conventions national legislation policies and regulations This chapter highlights the main legislative and policy considerations for the protection of the environment natural resources fisheries and social and economic development It begins with reference to the World Bankrsquos safeguard framework and those of other donors This is followed by a section on the governance framework in Ghana
42 WORLD BANK AND OTHER DONORSrsquo SAFEGUARDS POLICIES
The World Bankrsquos safeguard policies exist to ensure that all projects which it finances are developed and implemented on environmentally and socially sound principles A range of different policies exist and these have been carefully considered to ensure that the Ghana Fisheries and Aquaculture Development Sector Development Plan complies with these safeguards All policies have been screened and those that have no bearing on the fisheries programme have been excluded from Table 41 below Table 41 lists policies which could have some applicability to the FASDP even if this interaction might be very slight It is important to stress that the comments in the third column of Table 41 relate to the entirety of the Fisheries and Aquaculture Sector Development Plan whose effects will continue to be experienced long after the World Bankrsquos financial support has been expended Most of the activities in the FASDP will have no effect in relation to safeguard objectives and where there are implications these are likely to occur at precise locations (for example at fish landing sites) rather than throughout the industry Where potential interactions have been noted the necessary mitigating measures are incorporated in the Draft Process Framework
Table 41 World Bank Safeguard Policies in Context
Safeguard Policy
Safeguard Policy Objective Brief Description and relevance to FASDP
OP 401 Environmental Assessment
This policy aims to ensure that Bank-financed projects are environmentally sound and sustainable and that the decision-making process is improved through appropriate analysis of actions and mitigation of their likely environmental impacts This policy is triggered if a project is likely to carry potentially adverse environmental risks and impacts on its area of influence OP 401 covers impacts on the natural environment (air water and land)
The majority of actions planned under FASDP will be beneficial to the marine environment and to inland waters However new construction activities could have impacts and depending on the project and the nature of impacts a range of instruments can be used to ameliorate and mitigate adverse effects while enhancing beneficial effects These include EIA environmental audit risk assessment and environmental management plans (EMP) The need for EIA and EMP is considered in this report
26
OP 404 Natural Habitats
This policy recognizes that conservation of natural habitats is essential to safeguard their unique biodiversity and to maintain environmental services and goods for human society and for long-term sustainable development The Bank therefore supports the protection management and restoration of natural habitats in its project financing as well as policy dialogue and economic and sectoral work Natural habitats comprise many types of terrestrial freshwater coastal and marine ecosystems They include areas lightly modified by human activities but retaining their ecological functions and most native species
This policy is triggered by any project (including any sub-project under a sector investment or financial intermediary) with the potential to cause significant conversion (loss) or degradation of natural habitats whether directly (through construction) or indirectly (through human activities induced by the project) This policy is applicable to the Ghana Fisheries Programme because the project focuses on the integrated management of natural habitats However by screening all proposals under the ESMF any sub-projects that might impact these habitats will not be funded
OP 409 Pest Management
The objective of this project is to (i) promote the use of biological or environmental control and reduce reliance on synthetic chemical pesticides and (ii) strengthen the capacity of the countryrsquos regulatory framework and institutions to promote and support safe effective and environmentally sound pest management
The policy is triggered if (i) procurement of pesticides or pesticide application equipment is envisaged either directly through the project or indirectly through on-lending co-financing or government counterpart funding (ii) the project supports an activity requiring the use of pesticides that may have negative effects on the environment The only instance in which this policy might be triggered by the Ghana Fisheries Programme is if aquatic herbicides or antibiotics were to be used in connection with aquaculture This is most unlikely but can be monitored through the implementation programme
OP 411 Physical Cultural Resources
The policy objective is to assist countries in avoiding or mitigating adverse impacts of development projects on physical cultural resources For the purposes of this policy ldquophysical cultural resourcesrdquo are defined as movable or immovable objects sites structures groups of structures natural features and landscapes that have
Under the Ghana Fisheries Programme construction and rehabilitation activities that could have negative impacts on cultural property will be avoided In the case of discovery of remains national procedures will be applied
27
archaeological paleontological historical architectural religious aesthetic or other cultural significance
OP 412 Involuntary Resettlement
The objective of this policy is to (i) avoid or minimize involuntary resettlement where feasible while exploring all viable alternative project designs (ii) to assist displaced persons in raising their former living standards income-earning capacity and production levels or at least in restoring them (iii) encourage community participation in planning and implementing resettlement and (iv) provide assistance to affected people regardless of the legality of land tenure
The policy covers not only physical relocation but any loss of land or other assets resulting in (i) relocation or loss of shelter (ii) loss of assets or access to assets (iii) loss of income sources or means of livelihood whether or not the affected people must move to another location The activities of the Ghana Fisheries Programme are likely to result in loss of assets or access to assets and loss of income sources or means of livelihood for some groups and individuals The potential for such losses will be carefully scrutinised and compensated for through the National Process Framework and Resettlement Policy Framework described in this report and appropriate procedures will be followed where necessary
Other donors and aid agencies including International and National NGOs play an active role within the fisheries sector in Ghana and their safeguards standards will be observed through operation of the Environmental and Social Safeguards Management Plan
28
43 THE GOVERNANCE FRAMEWORK IN GHANA
The Ministry of Food and Agriculture (MOFA) Preparation of Fisheries laws and policies fall under the responsibilities of the Minister of Food and Agriculture who in turn delegates functions including implementation to a semi-autonomous body the Fisheries Commission
The Fisheries Commission (FC) was established under the Fisheries Commission Act (625 2002) It oversees management regulation and utilisation of the fisheries resources of Ghana drawing on powers set out in the Fisheries Law (PNDC 256 1991) Fisheries Act 625 provided for the establishment of a more robust Fisheries Commission (FC) which is an amalgamation of the erstwhile FC and Department of Fisheries
Ten individuals constitute the Board which is led by a chairman (appointed by the President of Ghana in consultation with the Council of State) supported by three members drawn from the ministries of transport defence and environment There are three representatives from the following parastatal organizations - the Ghana Marine Fishing Officers Association Water Research Institute and Ghana Irrigation Development Authority- and two representatives (one from the artisanal and one from the industrial sections )of the National Fisheries Association of Ghana Finally the tenth member is a person with requisite knowledge of the fishing industry or natural resources renewal management
The day to day work of the Fisheries Commission is undertaken by the Department of Fisheries (DOF) which serves as the implementation secretariat of the Fisheries Commission as stipulated by the Fisheries Act 625 of 2002 Specific tasks that are undertaken by the Department of Fisheries include
bull preparing fishery resource management plans bull developing regulations for the fishing industry bull organizing monitoring surveillance and enforcement for the national fishery resources and
ensuring compliance with national fisheries law and institutionalizing co-management concepts
The MCS Division of the DoF (established under the Fisheries Sub sector Capacity Building project) works in conjunction with the Ghana Navy and undertakes sea patrols to exclude industrial fishing vessels from the 30-metre depth IEZ reserved for artisanal fisheries The MCS also conducts inspection of industrial vessels at the fishing ports of Tema and Takoradi for
bull valid fishing licences bull legality of fishing gear bull skipperrsquos certificate bull log book and crew composition
The MCS undertakes similar functions for inland fisheries on Lake Volta
The Ministry of Local Government and Rural Development (MLGRD) is responsible for managing fishers fish processors and fishery resources at district and sub-district levels which it undertakes through the District Assemblies In 2002 the District Assemblies in collaboration with DoF were mandated to facilitate fishery resource management by
bull helping to form and sustain Community Based Fisheries Management Committees (CBFMCs) bull cooperating with the DoF MCS units bull providing legal and financial support to the CBFMCs and bull approving levies proposed by the CBFMCs
29
Community-Based Fisheries Management Committees are charged with the responsibility of enforcing national fisheries laws at community level as well as initiating and enforcing their own by-laws
44 THE LEGAL FRAMEWORK
441 International Conventions
Ghana has ratified a number of international conventions and treaties which have an important bearing on the state of its marine and inland waters and the condition of the fisheries These are listed in Box 1 below
Box 1 International Conventions treaties and agreements to which Ghana is a signatory 1 International Convention for the Prevention of Pollution of the sea by Oil 21 October 1962 2 Convention on the Africa Migratory Locust 25 May 1962 3 Treaty Banning Nuclear Weapon Tests in the Atmosphere in Outer Space and Under Water 5th August 1963 4 International Convention for the Conservation of Atlantic Tunas 4 May 1966 5 Africa Convention on the Conservation of Nature and Natural Resources 15 September 1968 6 International Convention on Civil Liability for Oil Pollution Damage 29 November 1969 7 International Convention Relating to Intervention on the High Seas in Cases of Oil Pollution Causalities 8 Convention on Wetlands of International Importance Especially as Waterfowl Habitats 2 February 1971 9 Treaty and Prohibition of the Emplacement of Nuclear Weapons of Mass Destruction on the Seabed and the Ocean Floor and in the Subsoil Thereof 11 January 1971 10 International Convention on the Establishment of an International Fund for Compensation of Oil Pollution Damage 18th December 1971 11 Convention Concerning the Protection of World Cultural and Natural Heritage 16 November 1972 12 Convention on International Trade on Endangered Species of Wild Fauna and For a 3 March 1973 13 Convention on the Military or Any other Hostile Use of the Environmental Modification Techniques 10 December 1976 14 Convention on the Conservation of Migratory Species of Wild Animals 23 June 1979 15 Convention for the Cooperation in the Protection and Development of the Marine and Coastal Environment of the West and Central African Region1981(Abidjan Convention) 16 United Nation Convention on the Law of the Sea 10 December 1982 17 Montreal Protocol on Substances that Deplete the Ozone Layer 24 July 1989 18 Convention to Combat Drought and Desertification 19 Framework Convention on Climate Change June 1992 20 Convention on Biological Diversity1992 442 Environmental-Related Conventions Environmentally related conventions ratified by Ghana include
bull International Convention for the Prevention of Pollution of the sea by Oil 21 October 1962
bull Convention on the Africa Migratory Locust 25 May 1962 Treaty Banning Nuclear Weapon Tests in the Atmosphere in Outer Space and Under Water 5th August 1963
bull International Convention for the Conservation of Atlantic Tunas 4 May 1966 bull Africa Convention on the Conservation of Nature and Natural Resources 15 September 1968 bull 992256International Convention on Civil Liability for Oil Pollution Damage 29 November
1969 bull International Convention Relating to Intervention on the High Seas in Cases of Oil
30
Pollution Causalities bull Convention on Wetlands of International Importance Especially as Waterfowl Habitats
2 February 1971 bull Treaty and Prohibition of the Emplacement of Nuclear Weapons of Mass Destruction
on the Seabed and the Ocean Floor and in the Subsoil Thereof 11 January 1971 bull International Convention on the Establishment of an International Fund for
Compensation of Oil Pollution Damage 18th December 1971 bull Convention Concerning the Protection of World Cultural and Natural Heritage 16
November 1972 bull Convention on International Trade on Endangered Species of Wild Fauna and For a 3
March 1973 bull Convention on the Military or Any other Hostile Use of the Environmental
Modification Techniques 10 December 1976 bull Convention on the Conservation of Migratory Species of Wild Animals 23 June 1979 bull Convention for the Cooperation in the Protection and Development of the Marine and
Coastal Environment of the West and Central African Region1981(Abidjan Convention)
bull United Nation Convention on the Law of the Sea 10 December 1982 bull Montreal Protocol on Substances that Deplete the Ozone Layer 24 July 1989 bull Convention to Combat Drought and Desertification bull Framework Convention on Climate Change June 1992 bull Convention on Biological Diversity1992
443 National Legislation
The principal national legislation that affects fisheries in Ghana is listed below
1 Fisheries Regulation 1984 LI 1294 2 Fisheries (Amendment) Regulation 1977 3 Maritime Zones (Delimitation) Law 1986 4 PNDC Law 256 of 1991 5 Fisheries Commission Act of 1993 and 6 Fisheries Act 625 of 2002 7 Fisheries Regulations passed in 2010 LI 1968
Other laws that have relevance to the fisheries sector include
1 Wild Animals Preservation Act 1961 (Act 43) 2 Volta River Development Act 1961 (Act 46) 3 Ghana Water and Sewerage Corporation Act 1965 (Act 310) 4 Oil in Navigable Waters Act 1964 (Act 235) 5 Irrigation Development Authority Decree 1977 (SMCD 85) 6 Minerals and Mining Law 1986 (PNDCL 153) 7 Environmental Protection Agency Act 1994 (Act 490) 8 Ghana Highway Authority Act 1997 (Act 540) 9 Timber Resources Management Act 1998 (Act 547) and 10 Minerals and Mining Act 2006 (Act 703
31
434 Policies A number of Environmental related Policies exist in Ghana however there is no specific policy on the coastal zone These include
bull The National Environment Policy bull National Wetlands Policy bull Agricultural Policy bull Tourism Development Policy bull Land Management Policy bull National Health Policy bull Energy Policy bull Minerals Policy bull Wildlife Conservation Policy
The main thrust and orientation of national policies on the protection management and development of the marine and coastal environment focuses on the following three major areas
bull Integrated coastal zone management and sustainable development bull Marine environmental protection both from land-based activities and from sea-based
activities and bull Sustainable use and conservation of marine living resources (both of the high seas and
under national jurisdiction) Specific plans have been developed to ensure the realization of prudent management of the marine and coastal environment These include
bull Coastal Zone Management Indicative Plan 1990 bull National Environmental Action Plan 1994 bull Draft Integrated Coastal Zone Plan 1998 bull Coastal Zone Profile of Ghana 1998 bull National Oil Spill Contingency Plan with specific reference to the marine environment
2002 bull Environmental sensitivity map of the coastal areas of Ghana 1999 and 2004
Despite the existence of these plans active integration and coordination has been lacking in practice at local level 434 Regulations Though several legislations exist on coastal protection and sustainable development there is no omnibus legislation on the environment Legislation relating to the area include the following
bull Beaches Obstruction Ordinance 1897 (Cap 240) bull The Mineral and Mining Law 1986 (PNDC 153) bull Rivers Ordinance 1903 (Cap 226) bull Land Planning and Soil Conservation Ordinance No 32 of 1953 as Amended by the bull Land Planning and Soil Conservation (Amendment) Act 1957 (No 35 of 1957) bull Maritime Zones (Delimitation) Law 1986 (PNDCL 159) urban planning and
32
bull development bull Town and Country Planning Ordinance (Cap 84) bull Wild Animals Preservation Act Act 235 1964 bull The Towns Ordinance (Cap 86) bull National Building Regulations 1996 (LI 1630) bull Volta River Development Act 1961 bull Fisheries Act 2002 Act 625 bull Fisheries Law 1991 (PNDC 256) bull Fisheries (Amended) Regulations 1977 and 1984
The sustainable use and conservation of marine resources is encouraged through legislation regulations education and awareness creation programmes as well as the enforcement of existing regulations and legislation The legal framework for coastal zones issues and management in the country are contained in the following documents
bull The 1992 constitution bull EPA Act 1994 (Act 490) bull Environmental Assessment Regulations 1999 (LI 1652) bull Local Government Act 1993 (Act 462) bull Environmental Standards and Guidelines bull
In addition there are other specific legal frameworks which include a) The legal framework for Ecosystem Protection which are
bull Wild Animals Preservation Act 1961 (Act 43) bull Wildlife Conservation Regulations 1971 (LI685) bull Wild Reserves Regulations 1971 (LI 740) bull The Wetland Management (Ramsar sites) Regulation 1999 bull Oil in Navigable Waters Act 1964 (Act 235)
b) The legal framework for Fisheries Resources which are bull Fisheries Law 1971 (PNDCL 256) bull Fisheries Act 2000
c) The legal framework for Oil and Gas Industry bull Petroleum (Exploration and production) Law 1984 (PNDCL 84) bull Mineral (Offshore) Regulations 1963 (LI 257) bull Mineral (Oil and Gas) Regulations 1963 (LI 256) bull Oil and Mining Regulations 1957 (LI 221)
d) The legal framework for Tourism Promotion (including coastal tourism) bull Ghana investment Promotion Centre Act 1994 (Act 478) bull Companies Code 1963 (Act 179) bull Free Zone Act 1995 (Act 504) bull Ghana Tourism Board bull Ghana Commission on Culture
44 ACTIVITIES RELATING TO FISHERIES INTERESTS
33
Over the years several activities have been undertaken which are of relevance to protection of the marine environment and fisheries These include
bull Ghana Environmental Resource Management Project in Coastal Wetlands Management Component
bull Gulf of Guinea Large Marine Ecosystem Project bull Fisheries Sub-sector Capacity Building Project bull Establishment of a Protected Wetland Ecosystem on the coast bull Development and Implementation of Oil Spill Contingency Plan bull Monitoring of fish stock levels and associated oceanographic parameters bull Institution of a programme of Monitoring Compliance and Surveillance of the marine
environment bull Development of industrial pollution standards bull Development of University course on Coastal Zone Management bull Increased public education on sound coastal and marine environmental practices
45 RELEVANT INSTITUTIONS With regards to protection management and development of the marine and coastal environment a number of ministries and agencies have been identified as potential stakeholders Those shown with an asterisk are likely to have a particularly active role
bull Ministry of Environment and Science bull The Environmental Protection Agency bull Ministry of Tourism bull Ministry of Local Government and Rural Development bull Ministry of Ports bull District Assemblies bull Ghana Ports and Harbours Authority bull Hydrological Services Department bull Ministry of Food and Agriculture bull Ghana Tourist Board bull Ghana Investment Promotion Centre bull Fisheries Commission Ministry of trade Industries and PSI bull Ministry of Lands and Natural Resources Forestry and Mines bull Ministry of Energy bull Ministry of Health bull Ministry of Education Youth and Sports bull Ministry of Defence bull Ghana Navy bull Ministry of Works and Housing bull Ministry of Women and Childrenrsquos Affairs bull Ministry of Roads and Transport bull National Development Planning Commission bull Council for Scientific and Industrial Research bull Universities and Research Institutions bull Ghana Meteorological Agency bull Town and Country Planning Department bull Water Resources Commission
34
bull Ghana National Petroleum Corporation bull Volta River Authority bull Geological Survey Department bull Forestry Commission (Forestry and Wildlife Division) bull Traditional Rulers and their analogous ministry and laws
Non-Governmental Organisations including Resource Development amp Environmental Oriented Development Organisation
bull Friends of the Earth bull Green Earth bull Wildlife Society bull Recerca e Cooperazione bull Centre for African Wetlands bull And many others
46 PARTNERSHIPS Few formal partnerships exist However support for coastal conservation activities has been received from the private sector as well as from Government Regional and sub-regional collaboration efforts occur at various levels although the level of practical intervention is sometimes limited The science and technology unit of ECOWAS is engaged on issues relating to the management of the Gulf of Guinea In addition a bilateral arrangement exists between Ghana and Cote drsquoIvoire for the management of and datasharing on Sardinella stocks which migrate between the two countries The NEPAD framework among the coastal states of Africa is also developing an interest in marine and coastal management 461 Technical and financial support Ghana receives technical support in the form of training research and project implementation from national bilateral and multi-lateral sources Financing of activities in the sector is primarily supported from the national budget However donor support from both bilateral and multilateral sources has also been obtained for specific programmes such as the World Bank sponsored Fisheries Sub-sector Capacity Building Project UNOPS sponsored Environmental Sensitivity Map for Coastal Areas The Ghana Coastal Wetland Project of the World Bank UNEPrsquos WACAF Programmes and The Darwin Marine Biodiversity of West Africa Project by DFID implemented by the University of Ghana 47 ACTIVITIES Activities undertaken in the country with importance to the marine and coastal area are outlined in the following sections 471 Environment-related activities
bull Ecological Baseline studies of Korle Lagoon (1990-2000) This was carried out to satisfy EIA requirement and as a result pollution status of the lagoon was established
bull Lower Volta Mangrove Project (1996-1998) The objective is to ensure sustainable management of mangrove stands and as such baseline information was documented
bull Save the Seashore Birds Project (1985-1995) This was to protect the seashore birds and as a result conservation awareness of seashore birds was achieved
bull Ghana coastal wetlands management project (1996-1999) In this management of the five coastal wetlands designated as Ramsar Site was put in place
bull Darwin Marine Biodiversity of West Africa Project It is a training project in marine biodiversity assessment
35
472 Social-related activities bull A considerable amount of attention is currently being given to the potential impact of oil-related
development in coastal regions following the publication of Environmental and Social Impact Assessments and Management Plans relating to the Jubilee Oil Field discoveries
473 Coastal area management bull Climate and vulnerability and adaptation assessment on water resources agriculture and the
coastal zone Projects (1997-1999) The projects assessed the vulnerability of the coastal zone to climate change
bull Coastal area management plan for Princess Town (1998-2000) which aimed at providing a plan for the management of Princess Town
bull Keta Sea Defence Project Work (2000-2004) The project aimed at protecting the Keta and its environs from the episodes of erosion faced in the area and also to ensure improvement in environmental and socio-economic conditions at Keta and its immediate surroundings
474 Regional Programmes bull Gulf of Guinea Large Marine Ecosystems Project (1996-1999) The project developed an
effective approach to prevent and control pollution in the Gulf of Guinea and conserve its biodiversity As a result regional institutional capacities were strengthened and also a coastal zone management profile and plans produced
bull UNEP WACAF Projects 1 amp 2 This aims at institutionalising and coordination of national contingency plans monitoring of pollution in the marine environment and control of coastal erosion
475 Other major programmes Other recent programmes and activities in the marine and coastal environments have included
bull Ghana Environmental Resources Management Project in Coastal Wetlands bull Fisheries sub-sector Capacity Building Project bull Establishment of a Protected Wetland Ecosystem on the coast bull Development and Implementation of Oil Spill Contingency Plan bull
48 ONGOING PROJECTS Ghana is currently implementing several projects in the marine and coastal area Some of these projects are linked to developmental projects for which impact assessments are required under the Environmental Assessment Regulations of 1999 Some of the projects are large scale in nature with extensive baseline and monitoring studies like the Keta Sea Defence Project and the West Africa Gas Pipeline project Others are projects being implemented under the auspices of the United Nations agencies and non-governmental organisations include
bull Combating Living Resource Depletion and Coastal Area Degradation in the Guinea Current LME through Ecosystem-based Regional Actions
bull Amansuri Conservation and Integrated Development Project (ACID) bull Danida Water and Sanitation Sector Programme II Support to Integrated Water Resources
Management (IWRM) Component (2004-2008)The Densu Basin aspect of the IWRM component
bull Reduction of Environmental Impact from coastal tourism
bull Bui Hydro Power Project
bull Sea Defence Project at Atorkor
bull Sea Defence Projects in selected towns in the Western Region of Ghana
36
49 CONCLUDING REMARKS
This chapter has highlighted the wide range of conventions laws policies regulations and activities affecting the inland and coastal regions and inland freshwater and marine environment of Ghana It will be important to keep all of these processes and procedures under review as the Fisheries and Aquaculture Sector Development Plan is taken forward to the implementation stage
The main responsibility for ensuring delivery of the Fisheries and Aquaculture Sector Development Programme will rest with the Fisheries Department of the Ministry of Food and Agriculture and the Fisheries Commission supported by the MCS Division and Ghana Navy However a key part of the programme is the development of local co-management arrangements and the Ministry of Local Government and Rural Development and individual District Assemblies will play a key role in helping to form and sustain Community Based Fisheries Management Committees
Over time a significant number of fishermen and individual fish processors are likely to leave the sector as harvesting landing and processing of the catch becomes more efficient Management of these changes especially where disadvantaged and vulnerable sections of the community are affected will need substantial support and investment and a high degree of coordination amongst government ministries and agencies NGOs and international partners to ensure that development assistance is effectively targeted
37
CHAPTER 5 WORLD BANK SAFEGUARD ISSUES
51 INTRODUCTION
The World Bankrsquos proposed funding support to the Government of Ghana covers an initial five yearsrsquo period which could potentially be extended at a later date As the Government of the Republic of Ghana notes in the draft FASDP ldquoimproving the management of the countryrsquos fisheries and ensuring that the impacts on individuals and communities are properly addressed will take 20 or more years to effectrdquo It has therefore been judged important in this report to distinguish between changes that might occur as a direct result of the World Bankrsquos financial assistance thereby triggering the Bankrsquos environmental and social safeguards and changes that could result from longer term adjustments to fisheries and other sectors of Ghanarsquos economy as a result of wider influences by Government other donors and world-wide factors (for example international progress in world trade agreements)
The aim in this chapter is to identify changes which are likely to fall within the purview of the World Banks reputational risks and responsibilities under the first five years of the Fisheries and Aquaculture Sector Development Plan (FASDP) It should be clearly understood that the views expressed are those of the consultancy team and it will be for the World Bankrsquos internal advisors to decide what formal recommendations are made to the World Bank Board
Trends that may emerge in later stages of the implementation of FASDP ndash subsequent to the initial five year period - are discussed in chapter 6
52 THE CURRENT SITUATION
The general status of Ghanarsquos fisheries has been described in Chapters 3 while the legal and policy context has been set out in Chapter 4 The World Bankrsquos investment is being planned specifically to support government policy with the aim of providing a more efficient and better regulated fisheries sector Currently open access is leading to progressive deterioration in fish stocks and lower economic returns Based on many international examples of successful intervention the current proposals (see Chapter 2) are to provide support to introduce formal licensing of all vessels and proper monitoring and control over the seasonal timing and location of fishing activity use of gear and approved nets and self regulation through co-management structures under which the Government and fishing communities will work together to achieve recovery of fish stocks higher income levels for fishers and better returns on catches by reducing post harvest losses and improving processing and marketing operations
53 ANTICIPATED OUTCOMES
It is expected that the proposed reforms and changes will eventually lead to significant improvement in the marine environment restoration of fisheries and enhanced incomes In this respect the provision of grants and loans from the World Bank will bring about major benefits to the economy livelihoods and the environment in the longer term The question that has to be addressed however is - are there likely to be any short term adverse environmental or social consequences from the Bankrsquos own investment strategy Answers are considered in relation to each of the planned components sub-components and activities which are summarised in Table 51 A colour coding and numbering system has been adopted to distinguish those activities that are seen as particularly relevant from the standpoint of the environmental and social assessment Elements highlighted in green are those likely to have positive and beneficial effects on the environment and social conditions those highlighted in orange red have potentially negative or adverse consequences if not handled properly
38
Component 1 Good Governance and Sustainable Management of the Fisheries
Sub-Component 11 seeks to develop the capacity rules procedures and practices that will lead to better governance As such these procedural interventions will have no direct effect on the environment or social conditions of fishing communities However it will be important to ensure that the drafting agencies (government departments and consultants) give due attention to environmental and social objectives during this phase of work Three specific areas are highlighted including undertaking a socio-economic impact assessment with mitigation measures as part of the plan for fishing capacity reduction reviewing the economic and social implications of subsidies and fish import tariffs in the fisheries sector and developing the policy for the development and operation of community-based management networks built around defined fisheries management units
In developing regulations and guidelines it will be important to consider how less able individuals and vulnerable sectors are going to adapt to new systems For example the new regulations on licensing canoes including completion of registration forms the display of registration numbers on vessels and demonstration of basic competence in health and safety standards may prove taxing demands for owners and crew lacking any formal education Similarly legal instruments that are used to remove fuel subsidies or other benefits will need to be carefully explained A socio-economic impact assessment is proposed in the draft PAD to be accompanied by appropriate mitigation measures This assessment should consider amongst other things
bull whether support should be offered and if so under what conditions to any company community or individual who fails to secure a license for a particular class of vessel
bull how the transfer or sale of licenses will be regulated in the wider public interest to ensure transparent processes and avoid the creation of monopolistic and oligopolistic elites
bull who wins and who loses from any planned changes to subsidies and fish import tariff adjustments
bull how the performance of community-based management networks will be judged bull what action will be taken to mitigate the loss of any traditional fishing grounds that become the
subject of marine protected area development or are subject to exclusion zones to protect oil drilling and production platforms
Sub-Component 12 introduces the concept of fishing rights This is to be initiated through a series of four pilot stakeholder-based fishery initiatives and the rolling out of licensing procedures Discussions with stakeholders have made it very clear that the credibility of the entire fisheries policy and programme could be challenged if these pilots do not show positive and constructive ways of moving forward with fisheries reform There is a great deal of distrust for new procedures amongst the fishing communities based on the knowledge that many previous initiatives have failed It is therefore essential that the pilots are led by a strong implementation team are adequately financed and include a credible transparent and inclusive process for debate discussion and consultation Co-operation from the selected communities will be more likely to be achieved if they can see early results in terms of income generating activities
Sub-Component 13 is targeted at adjusting fishing effort and capacity to more sustainable levels and supporting alternative livelihood opportunities These activities are critical in giving effect to the policy decisions that have already been taken to reduce the size of the industrial and semi-industrial fishing fleet and to strengthen the role of the canoe sector Specific measures are proposed for compensating crew members who lose their jobs and for providing training to young men who are willing to transfer
39
out of the fishing sector The scale of this task should not be under-estimated however since there are currently few alternative employment opportunities in the coastal belt for manual workers with low education and skill levels which typify the status of many young fishermen The concept of creating some additional employment with conservation of the coastal littoral and marine ecosystems is strongly supported since this can be linked with development of tourism
Sub-Component 14 is another element that is strongly focused on delivering improved livelihoods with its emphasis on social marketing communication and transparency The focus on stakeholder participation is particularly welcome and should lead to positive response providing it is backed with direct financial support to participating communities
Component 2 - Reduction of Illegal Fishing
There is no Sub-Component 21 within the Ghana Fisheries Programme
Sub-Component 22 aims to develop monitoring control and surveillance (MCS) systems These measures are largely procedural and apart from the relatively small team that will be recruited to operationalise the systems it will have minimal effects on either the environment or social conditions One element that is highlighted in Table 51 relates to provision of facilities and training for participatory coastal surveillance of small-scale fisheries This should have direct and strongly positive benefits for participants and the communities who are enrolled in the training programmes
Component 3 increasing the contribution of the marine fish resources to the local economies
Sub-Component 31 will support the development of basic infrastructure at nine marine fish landing sites and two inland sites The scale of physical construction will be restricted to repair and minor extension of roads and jetties wharves and construction of net mending screens and storage sheds These activities are unlikely to have any significant adverse environmental impacts and should lead to positive social effects
Sub-Component 32 will underpin efforts to improve fish product trade infrastructure information and systems Introduction of new technology for smoking and curing fish and the extension of existing ice preparation plants will start to have positive beneficial effects within the selected communities
Sub-Component 33 provides a modest level of support to marine and inland aquaculture development Aquaculture development should include finalization establishment and enforcement of current draft operational standards to cater for environmental friendliness of fish culture industry for its own survival The main focus will be on developing policy and legal frameworks together with support for stock improvement These measures will have some impact on affected communities in the short term but are clearly aimed at longer term benefits
40
Component 4 Coordination Monitoring and Evaluation and Program Management
Sub-Components 41 and 42 are directed specifically at strengthening the capacity of the Governmentrsquos institutions for national implementation and regional co-ordination As such they will have no direct environmental or social impacts
54 SUMMARY AND CONCLUSIONS
This review of potential environmental and social safeguard issues under the World Bankrsquos targeted programme concludes that there are unlikely to be any significant adverse environmental or social effects as a result of the planned investments
The only possible exception relates to the effectiveness of measures that are put in place under Sub-Component 12 to support pilot stakeholder-based fishery initiatives It is of paramount importance that these pilots are successful and win the confidence of all participants since failure to achieve positive results could set back the entire fisheries programme For this reason it is essential that planning of the pilot initiatives is linked closely with measures for supporting alternative livelihoods and strengthening processing and marketing initiatives under Sub-Components 13 and 14
A number of the planned interventions may have longer term consequences as policies regulations and bye-laws are put into effect but these will be addressed in subsequent work by the Government of Ghana (see Chapter 6)
Table 51 Elements of the World Bank Programme and assessment of potential environmental and social risks
Description of Component Sub-Component and Activities
Measure of Likely Effects
Large (3)
Moderate (2)
Small (1)
None
Beneficial
3
2
1
Adverse
3
2
1
Component 1 Good Governance amp Sustainable Management of the Fisheries
Sub-Component 11 Developing the Capacity Rules Procedures amp Practices for Good Governance of the Fisheries
Reviewing developing programmes and projects designed to support the Fisheries and Aquaculture Development Sector Plan (FASDEP)
Developing an operational policy to enable implementation of the Aquaculture and Fisheries
Plan for fishing capacity reduction (including socio-economic impact assessment and mitigation) 3 2
Commercial vessel and fishing activity licensing plan including allocation criteria rules for transfer of licenses
41
Sector Development Plan and timetable and schedule of license fees
Compliance strategy and plan
Regulations for the management of fisheries including the identification and specification of fisheries management units (ie stocks species areas)
Recommendations for environmental and social safeguards arising from the review of the economic and social implications of subsidies and fish import tariffs in the fisheries sector
3
Policy for the development and operation of community-based management networks built around defined fisheries management units
3
Policy on adaptation strategies for climate change and marine protected area development
2 2
Review of the Ghana Tuna Industry to identify policy or infrastructure needs that threaten Ghanarsquos hub status
Strengthening capture fisheries management systems and capability
Development of fisheries and aquaculture management systems and processes and training
Strengthening fisheries information systems
Installation and operation of fisheries lsquodashboardrsquo database and information collection
Sub-Component 12 Introducing Fishing Rights ($15 M GEF)
Developing 4 pilot Stakeholder-Based Fisheries Management initiatives around defined fisheries units (ie local management initiatives tied to defined fisheries resources including demand-side governance initiatives)
3 2
Introducing and administering a licensing regime (registry establishment training stakeholder education) 2 2
Sub-Component 13 Adjusting Fishing Effort and Capacity to more Sustainable Levels and Supporting Alternative Livelihood Opportunities where Needed
Vessel decommissioning Decommissioning of 60 to 80 industrial trawlers in an environmentally friendly manner
2
Developing alternative livelihoods for crew of decommissioned industrialsemi-industrial
Skills training and small business development training and support for young (18-30 yrs) industrialsemi-industrial crew members willing to transition out of the sector
3
42
vessels
Alternative livelihood development to incentivize voluntary capacity reduction in canoe sector
Alternative livelihoods fund and CDD support to targeted fishing communities
3 2
Marine Resource Conservation
Would include confirming conservation priorities and management regimes and possible provision of support for alternative livelihood options (funded under 133) associated with conservation of coastal littoral and marine ecosystems as well as de facto protected areas associated with the development of oil and gas extraction
3
Sub-Component 14 Social Marketing Communication and Transparency)
Communications stakeholder consultations and awareness raising programs to support fisheries development
3
Component 2 Reduction of Illegal Fishing
Sub-Component 21 does not apply to Ghana
Sub-Component 22 Monitoring Control and Surveillance (MCS) Systems
Developing compliance systems and capability
Development of judicial and policy capacity (training)
Compliance risk assessmentstrategy systems and process development
Enforcement Unit establishment (dedicated facility)
Coastal surveillance stations 2
Facilities and training for participatory coastal surveillance of small-scale fisheries
3
Training for surveillance officers
Operation of aerial and water patrols (vessel leases aerial patrols operational costs patrol vehicles)
Observer program
Compliance education (stakeholder training signage) 1
Upgrademaintenance of the Vessel Monitoring System (VMS)
43
Component 3 Increasing the Contribution of the Marine Fish Resources to the Local Economies
Sub-Component 31 Fish Landing Site Clusters
Product diversificationvalue chain development
9 marine landing sites (basic infrastructure) at Axim Dixcove Fete Jamestown Moree Mumford Senya-Beraku Teshi and Winneba
3 1
2 inland fish landing sites (improved access and berthing infrastructure) at Abotoase and Dzemeni
3 1
2 ports developed (technical studies for 1 new port at Axim and additional berthing space in existing port of Elmina)
3 2
Sub-Component 32 Fish Product Trade Infrastructure Information and Systems
Export certification center development
Fish processing technology improvements 1 1
Technical assistance training and goods to support the National Fisheries Advisory Group
Sub-Component 33 Marine and Inland Aquaculture Development
Developing aquaculture policy and legal framework
Improving genetic quality of Tilapia fingerlings and breedstock
Catalyzing aquaculture development 2
Component 4 Coordination Monitoring and Evaluation and Program Management
Sub-Component 41 National Implementation
Technical assistance for Secretariat to the Fisheries Commission to implement the Project
Sub-Component 42 Regional Coordination
Technical assistance for Regional Coordination Unit at the CSRP support to Fisheries Information Systems (lsquoDashboardrsquo)
45
CHAPTER 6 ENVIRONMENTAL AND SOCIAL ASSESSMENT OF DRAFT FISHERIES AND AQUACULTURE SECTOR DEVELOPMENT PLAN (FASDP)
61 INTRODUCTION
This chapter examines environmental and social issues which need to be considered as part of the overall structural and economic adjustments in Ghanarsquos fisheries sector in the longer term (ie 1-15 years) The assessment deliberately focuses on the longer term because it will take a number of years before current plans start to have their full effect However the same temporal considerations apply to measures that are designed to avoid or mitigate potentially harmful effects so it will be important to start planning remedial actions as part of the joint Government of Ghana and World Bank fisheries programme
611 Key sectors and activities The fishing industry is divided first into marine capture and inland capture fisheries and then aquaculture For each of these three sectors activities are then broken down as follows Marine Capture Fisheries CATEGORY ACTIVITY Stock Management Research Surveillance reef building Harvesting Vessels Gear Skills capacity Marketing Sellers Buyers Processing Fresh fish Sun dried Smoking Freezing Consumers By market sector Support Sectors Boat Canoe Building fuel supply net making kiln construction
refrigeration transport cold store management Legal Enforcement Financing Investment in all elements Infrastructure Harbour wharf processing plant construction
Inland Capture Fisheries CATEGORY ACTIVITY Stock Management Research Surveillance Harvesting Vessels Gear Skills capacity Marketing Sellers Buyers Processing Fresh fish Sun dried Smoking Freezing Support Sectors Boat Canoe Building fuel supply net making kiln construction
refrigeration transport cold store management Legal Enforcement Financing Investment in all elements Infrastructure Harbour wharf processing plant construction
46
Aquaculture and Mariculture CATEGORY ACTIVITY Stock Management Research Surveillance Rearing Roe fingerling production cage -pond rearing Harvesting Vessels Gear Skills capacity Marketing Sellers Buyers Processing Fresh fish Sun dried Smoking Freezing Support Sectors Boat Canoe Building fuel supply cage construction kiln construction
refrigeration transport cold store management Legal Enforcement Financing Investment in all elements Infrastructure Harbour wharf processing plant construction
612 Evaluation Criteria The environmental and social assessment has been undertaken using a matrix (See Annex 114) which analyses the key sectors and activities of the fishing industry and the changes that are envisaged against a set of evaluation criteria Evaluation Criteria are broken down into environmental and social issues distinguishing between beneficial and adverse effects Table 61 below shows the relationship between the groups of criteria Table 61 List of Evaluation Criteria
Environment Social
Positive Adverse Positive Adverse
bull Sea bed rejuvenated
bull Fish stocks recovered
bull Biodiversity enhanced
bull Sea bed degraded
bull Fish stocks reduced
bull Biodiversity reduced
bull Increased harvest (catch volume)
bull Increased catch value
bull Reduced costs of inputs
bull Increased profit
bull Enhanced livelihoods
bull Increased job opportunities
bull Increased local economic multiplier
bull Reduced harvest (catch volume)
bull Reduced catch value
bull Increased costs of inputs
bull Reduced profit
bull Reduced livelihoods
bull Reduced job opportunities
bull Reduced local economic multiplier
The assessment process has involved systematically considering each sectoractivity against the evaluation criteria and recording either positive or negative results by drawing on the judgement of the consultancy specialists The findings are discussed in the paragraphs that follow and are reflected in Table 81 forming part of the Draft Environmental and Social Management Plan
62 DETAILED ASSESSMENT OF THE MARINE AND AQUACULTURE SECTORS
47
TunaIndustrial fleet streamlined and catch per vessel improved At present industrial trawlers have to travel increasing distances to fishing grounds and while the level of catch is remaining broadly static costs are increasing against available economic returns A major shortcoming is lack of investment in re-equipping the aging fishing fleet Many of the 90 vessels that make up this sector are increasingly unseaworthy and need to be replaced with modern trawlers and gear The plan is to buy out owners of substandard vessels by offering compensation at market value based on a full commercial survey Vessels remaining in the fleet will be required to meet exacting standards By reducing the number of old and inefficient boats this will allow each of the remaining vessels to catch a higher proportion of fish The aim is to ensure that Ghana is equipped with the latest vessels and technology in order to preserve the countryrsquos position as the hub of the West African tuna fishing and processing industry (see also the section on canneries below) The effect of these measures on the environment will remain broadly neutral since the same number of fish will be caught Providing other policies and increased surveillance are successful in preventing trawling in inland waters the smaller fleet will have to fish in deep oceanic waters This could potentially transfer some environmental effects on fish populations to other parts of the migratory cycle However this would become part of the international effort through fishing quotas to regulate overall catches Reduction in the size of the industrial fleet will mean that fewer men are needed to crew and service the vessels However in practice many men who work in this sector have only part time work and since a significant percentage of boats no longer put to sea the number of crewmen who will be displaced could be in the range of 1000-30003
It will be important to set up support services for those losing their jobs including retraining and welfare assistance where necessary
Decommissioning will necessitate the sale of seaworthy vessels and their removal from Ghanaian waters Other boats will need to be broken up and scrapped This process requires heavy duty specialized equipment and can release significant quantities of waste oil other toxic chemicals including refrigerants and asbestos used in pipe and engine room cladding Measures will need to be taken to ensure that proper environmental and health safety precautions are taken that decommissioning takes place in properly equipped boatyards and that all waste products are disposed of without environmental risk Cannery sector optimized The Fisheries and Aquaculture Sector Development Plan seeks to maintain the port of Tema as the centre of the Tuna canning industry in Ghana At present a proportion of Ghanarsquos tuna catch is diverted to neighbouring countries due to constraints on processing capacity These limitations include poor port infrastructure ageing equipment and delays in handling catch for some operators due to preferential treatment of vessels that are part-owned by the existing canneries Options for improvement include encouraging upgrading of the capacity of one or more existing canneries or promoting more competition in the processing sector and improving the infrastructure Providing modern building designs and construction techniques are employed and a full environmental assessment is undertaken in accordance with Ghanarsquos EIA regulations there should be no significant environmental or social risks associated with these development possibilities The potential economic benefit resulting from encouraging investment in this sector is very high
Industrial fishing excluded from inshore waters A major longer-term intention under the new fisheries plan (FASDP) is to ensure that existing regulations that restrict industrial and semi-industrial vessels from trawling in inshore waters are properly enforced This requires provision of surveillance
3 Based on an average crew of 20
48
equipment fast patrol vessels capacity building and training and increased staffing within Government agencies together with a full programme of awareness raising training and financial support to local bodies providing self-governance under new co-management services Restriction of industrial trawling in coastal waters will greatly ease pressures on fish stocks and reduce environmental damage to the sea bed In time this should lead to healthier fish population with more fish to be caught by the canoe industry as a result However the task of policing and enforcing regulations will not be easy and will take a number of years to bring into full effect Reduction in fishing activity by inshore trawlers will displace a number of crew members and have a short-term impact on dependent families until these individuals are either absorbed into the canoe fleet or find alternative employment There will therefore be a need to assist genuinely deserving cases where crew members (and their families dependents) need to transfer to other sectors of the economy These measures will only be required in the short term since the anticipated improvement in fish stocks will lead to improved economic performance in the canoe sector within which the bulk of employment exists
Expansion of deep water fisheries The fisheries plan notes that there may be a potential for exploitation or increased exploitation of some deep sea fish resources However the status and population dynamics of some affected species is not well known so any such activities should be scientifically monitored through research and enforced by MCS
Tema Secondi Port infrastructure improvements (equipmentbuildings) Under present conditions the transfer of fish from commercial and industrial vessels to canneries is often delayed by the time taken to offload crates and manouvre within the port area where there are conflicting activities There are also difficulties that arise when vessels owned by the canneries are given priority for landing leaving other boats waiting for many hours which can result in quality deterioration At this stage no details are available about the precise improvements that could be introduced and this will need to be investigated as the fisheries plan is advanced Any environmental effects from infrastructure improvements would be contained within the existing port areas and should be largely positive in reducing fuel (energy) costs and increasing overall efficiency It will however be important to carry out an environmental review of specific development proposals at the design stage especially if these involve plans for any dredging or for altering facilities for discharging waste and disposing of bilge water Both of these activities can have damaging effects on the sea bed (The first through dispersal of silt and sediment and the second through release of potential contaminants) Socio-economic effects from the infrastructure improvements should also be beneficial by removing delays increasing efficiency and reducing waste However there could be some slight reduction in manpower requirements leading to the need for skills retraining Regulating the catch (eg Fishing for selected species reducing juvenile catch to improve value of catch in inshore waters) The fundamental aim of the fisheries plan is to reduce the harmful effects on fish stocks and low economic returns from fish catches by phasing out open access for all and introducing regulation of fishing activity This is to be achieved through close cooperation between the Fisheries Commission Monitoring and Surveillance Unit as well as marine fisheries management division and individual fishing communities working together under a co-management framework The practical details will need to be worked out through each individual co-management group and initially the World Bank is offering to assist in the establishment of four pilots These bodies will test exactly what is required to increase fishersrsquo awareness to build capacity in self regulation and agree on appropriate measures
49
From discussion with stakeholders it is clear that while the broad principles are accepted the majority of the fishing community simply do not believe that the new regulations will be enforced because they have witnessed the failure of so many previous efforts to introduce firm management A major issue for the planned programme is therefore how to change this critical mindset without which very little progress is likely to be made in practice It will be necessary to demonstrate through the pilots that by regulating fishing activity direct benefits will accrue to those participating fishing communities Unfortunately efforts to eliminate harmful practices are unlikely to result in an immediate gain in fish stocks Instead catches are likely to fall in the short term It will therefore be essential to introduce other forms of incentive to cushion short term losses Such measures might include the purchase of new nets and gear for sale at subsidized price to local cooperatives the introduction of cash incentives for canoes demonstrating best practice in the use of gear and nets preservation of the catch using ice and landing and marketing fish of the required size and quality As restriction of open access starts to take effect there should be positive environmental gains in terms of improving fish stocks and less damage of the sea bed On the other hand both fishers and fish processors will feel the adverse temporary effect of reduced catches These social and local economic impacts will need to be monitored closely and assistance provided to help foster alternative livelihoods Cephalopus (Octopus) harvesting encouraged in inshore waters Although most fish species are currently exploited to unacceptably high levels within coastal waters there is a specific opportunity to increase the number of octopus caught by pot fishing This fishery could be developed by both the semi-industrial and canoe sectors Taking octopus in pots would have no adverse physical impacts on the sea bed and could allow very slight expansion in fish species that are preyed on by octopus At the same time it is important to note that there is only limited information on species composition and functioning of selected marine habitats including those of the octopus and more research should be undertaken on this and other species that could be selected for expanded fishing activity There would be clear socio-economic benefits arising from the creation of this new fishery Focusing fish landing at specific landing sites (to improve opportunities for subsequent marketing processing) Plans are already being developed for the enhancement of landing and processing facilities at a number of existing locations along the coast These locations include the construction of harbours at Jamestown and Elmina and development of landing sites at Teshie Ada Axim Dixcove Winneba Mumford SenyaBeraku Gomoa Fetteh Moree Keta Dzemeni and Tapa Abotoase Two sets of issues need to be considered in relation to these improvements all of which affect existing fish landing and processing sites The first is the nature of the physical works and infrastructure and it s potential effect on the marine and terrestrial environment The second is the socio-economic impact Both Elmina and Jamestown are long established fishing ports where the catch is landed either directly onto the beach or shallow wharves It is understood that the primary aim of the improvements will be to increase the area of permanent wharves to make it easier for fish to be offloaded to reduce the time taken in transferring stock to processing plants and to introduce modern technology In the case of other smaller landing sites the scale of improvements will be quite modest involving improvement to existing short stretches of access road the erection of stores for nets and other gear and provision of covered areas to provide shade for net-mending With all proposals for physical infrastructure development there will be a need to consider possible
50
environmental implications Due to the existing nature of these sites there are no major industrial or other commercial processes in the vicinity which could give rise to cumulative impacts including contamination of fish products The scale of plant needed for ice-making and storage and commercial smokeries is commensurate with the artisanal nature of the fishing activity itself and would not give rise to any significant environmental effects on air or water quality Harbour works could potentially involve some small scale dredging (for example the removal of accumulated silt) Where dredging is required it will be important to identify disposal areas (either at sea or on land) where silt can be deposited without damage to sensitive habitats In terms of economic and social impacts it is not clear at this stage who are likely to be the major investors from the private sector although it may be assumed that existing operators who have access to finance will be the main beneficiaries Over time as landing marketing and processing become more efficient it is possible that individuals in the traditional fish smoking sector will lose a significant proportion of their trade as the product switches to fresh or frozen fish sales for transfer to the major urban markets and the beach price for fish rises The draft Ghana fisheries and aquaculture sector development Plan notes in annex 2 that proposed facilities associated with the ports and landing sites may not have support from fish mammies or at least formidable commercial advocates able to resist any opposition from that quarter Inspection of major fish landing areas like Elmina and Sekondi indicates that the existing social and commercial structure of support activities to fish harvesting is very complex and involves almost every member of the community including children and the elderly Such activities include net mending boatbuilding metalworking (for cooking pots stoves and grills supplies (ropes weights tar paint wood) fuel supplies ice crates transport etc Leaders of the fishing community confirmed that in principle the improvements of facilities is welcomed provided that safeguards are in place for those who may lose part or all of their current trading activity through rationalisation Stabilise fleet capacity at a sustainable level Fishery experts consider that there would be significant benefits in reducing the number of canoes from the present 10000-12000 to around 8000-9000 which correlates with the number operating in the mid 1990rsquos when catches were at optimum levels At the same time the Fisheries and Aquaculture Plan stresses that the canoe sector will remain at the heart of the Ghana fishing industry and this has strong political enforcement Consequently there is unlikely to be any enforced reduction in the number of canoes holding licenses and owners of all existing canoes will be able to register their vessels The ability of canoe owners to pay annual licence fees should rise as the overall measures to increase efficiency and improve catches take effect However many people anticipate that over time as the annual cost of holding licenses rises less efficient fishers will sell their licenses (and hence their rights to fish) There may therefore be a de facto reduction in the size of the canoe fleet Even if numbers do not decrease the fleet could be stabilized at its present size by taking a decision not to grant new licences The draft plan discusses the fact that under existing law (section 53) there is a requirement for licenses to be issued on demand (presumably to ensure that Ghanaians are not barred from subsistence fishing) It is argued in the plan that this is a misconception since canoe fishing is largely a commercial activity and it is concluded that lsquoit is therefore essential that the number of canoe licenses can be controlled in future and the legal basis for these controls must be reviewed as a matter of priorityrsquo Decisions of this nature will require the full support of local co-management groups if they are to be effective but committees could easily come under pressure to make exceptions as the coastal population continues to rise and families without alternative livelihoods start lobbying for assistance
51
Accusations of preferential treatment of certain individuals by committees (or committee officials) - possibly linked with suggestions of bribery and corruption -could cause a lot of social tension and start to undermine community trust in the need to work together to improve fisheries management It is therefore most important that the detailed proposals for co-management address this risk and include proposals for mitigating individual hardship of the less advantaged ndash for example by offering voluntary retirement with some form of incentive Influencing marketing to maximise value and reduce post harvest losses (marketing cooperatives strong market structures etc) FAO has estimated that physical post harvest losses in Ghana amount to between 3 and 17 of smoked fish production and 16-20 of gillnet landings The plan notes that introduction of lsquonew generationrsquo small scale fish smokers should be introduced to replace the traditional Chorkor model This would improve fish product quality by eliminating charring of fish over open flames and also protecting operatorsrsquo eyes from the damaging effect of smoke and particles The other major improvement in post harvest value and profits would arise from greater use of ice throughout the supply chain Developing Aquaculture A distinction needs to be made between aquaculture development in ponds and dugouts which are self-contained and fish rearing in cages within open water In the case of farm ponds the commercial rearing of fish is little different to other forms of intensive livestock rearing Providing there is no direct connection to rivers and streams there is little likelihood of interaction between farmed and wild stocks which could spread fish infections and parasites In the case of fish farms in open water (rivers and lakes) there are well known risks of the spread of disease which can arise if overstocking occurs Intensive feeding of large numbers of fish in a confined area can lead to significant deterioration in water quality through the build up of nutrients from wood and waste It is also possible for antibiotics and growth hormones to be dispersed beyond the area of farm cages Genetic modification of farmed fish can also affect the local fish population through escapes All of these issues are capable of being managed and mitigated through good initial planning and design and subsequent maintenance and supervision It will therefore be necessary to develop additional regulations and guidelines specifically for the aquaculture sector 63 SUMMARY OF ENVIRONMENTAL RISKS AND OPPORTUNITIES Review of the full range of governance and development activities suggests that there are no high levels of risk to the marine or littoral environment Successful implementation of the Policy and plan should in fact result in very significant environmental gains Over a timespan of 5-20 years five activities in particular should result in significant improvements in the condition of the sea bed in coastal waters (to a depth of 30 metres) reestablishment of benthic flora and niche habitats increased fish stock and enriched biodiversity These interlinked activities are bull The exclusion of industrial vessels and trawling within coastal waters bull Regulation of fish catches through zonation seasonal control of fishing and standards for vessels
gear bull Stabilisation of the fishing fleet within sustainable harvesting yields bull The adoption of management plans formulated and agreed with full cooperation of local
communities bull The introduction of fishing rights through co-management agreements and bull Well planned consultation and information dissemination throughout the fisheries sector
52
Three components of the development plan have been identified where minor to moderate risk to the physical and biological environment could arise if proper design and implementation standards are not adhered to These relate to bull A potential risk of over-exploitation of new catch species in deep water off the continental shelf if
such development is not accompanied by through research to establish the sustainable yield of target species
bull Strictly localized effects on the physical environment from construction of landing wharves or jetties and other harbour facilities and
bull Infrastructure development at the existing ports of Tema and Takoradi All of these risks are capable of being fully managed by improved governance in the fishing sector and EIA procedures that are well-established in Ghana 64 SUMMARY OF SOCIO-ECONOMIC RISKS AND OPPORTUNITIES Implementation of the Plan Project will bring about substantial change in the fisheries sector and over time increased revenue reduction of post[harvest losses and added value to fish products will bring major economic returns At the same time there will be some individuals who do not participate in direct gains and whose livelihoods could be adversely affected if appropriate safeguarding measures are not put in place The level and extent of these socio-economic risks will be determined by 1 the level of commitment that is entered into by Government and its development partners to
deliver incentives to vulnerable and disadvantaged groups and 2 the speed with which the sector is transformed Rapid change could cause significant
displacement of less-efficient operators especially within the semi-industrial and canoe sector which would have serious ramifications for dependent communities However these effects can be marginalized if the development programme is carefully phased to ensure that alternative livelihood and employment incentives are available
The main risks to local livelihoods relate to the potential for bull loss of employment for crews of unseaworthy obsolete vessels ( from all sectors including
industrial semi-industrial and canoes) that are withdrawn from the fishing fleet because they no longer comply with license regulations
bull the inability of vulnerable and disadvantaged groups including artisanal fishers vendors and individual fish processors in small fishing villages to adjust to new market conditions at selected landing sites
53
CHAPTER 7 ASSESSMENT OF POLICY OPTIONS
71 INTRODUCTION
In order to place the significance of the environmental and social safeguards assessment in context this chapter examines the possible consequences of different policy responses to the existing challenges that face the fisheries sector in Ghana These different policy responses range from a continuation of the status ndashquo effectively a ldquodo-nothingrdquo option (A) to full-scale commitment by all stakeholders to achieving a sustainable fisheries future the ldquoOptimum Solutionrdquo option (C) Various less sustainable outcomes lie in between these two ends of a continuum of policy choices and these are represented by the ldquoWeak Solutionrdquo option (B) 72 OPTION A ndash DO NOTHING Background research and discussion with stakeholders indicates that practical capacity to deliver on clearly stated national goals for sustainable fisheries livelihoods and the reduction of poverty is weak This situation exists despite the fact that Ghana has a strong legal framework for management of its fisheries including the Law Policies and Regulations There is inertia and strong resistance on the part of the majority of players to accept that it is largely their own actions which are responsible for present conditions This in turn leads to the attitude that it is only the lsquoGovernmentrsquo that must act by providing increased subsidies and cushioning the industry against further deterioration in catches Unfortunately there is overwhelming evidence from around the world that where fish stocks are exploited beyond their natural capacity to regenerate this can lead to sudden and near-total collapse Ghana has historically been one of the strongest fisheries in West Africa but the signs are ominous that current levels of exploitation are leading to progressive decreases in annual catches for most species in both marine and inland waters As fishing effort intensifies with an increasing number of all types of vessel using illegal methods and inappropriate gear the distinction between the traditional lsquopeak season and lean season (linked to migration patterns breeding cycles and upwelling) is becoming blurred This is clearly illustrated by a statement from one of Elminarsquos fish mammies ldquowe use to smoke the herring in the peak but now the fishers bring them all the yearrdquo Use of monofilament nets light dynamite and chemicals to obtain fish in the lean season is aggravating a situation where too many boats are chasing too few fish Many fishers blame the reduction of catch on global warming for increasing water temperature the emergent oil and gas industry for restricting access to traditional fishing grounds and industry and urban development for increasing pollution leading to deterioration in water quality Each of these assertions warrants careful consideration but the industry is generally in denial when it comes to the primary fact ndash too many fish including juveniles are caught to allow regeneration of the stock In addition weak governance and lack of resources to ensure implementation of policy result in a situation where the law can be ignored with impunity If collective failure to recognize the seriousness of the current position and lack of commitment to taking hard decisions continues the omens for the future are not good Within a period of 10-15 years fish catches could fall by 50 or more from their present level Impacts on each species would vary and catches of some fish with regional or global migration patterns could remain viable (although this depends on the international conservation effort) On the other hand stocks of fish that provide the mainstay of local food resources herring and sardine could be decimated
54
Complete collapse of all fish species is unlikely but it is possible to envisage a situation where catches might fall below 300000 tonnes a year by 2025 (a reduction of more than 25 from present levels) The most serious consequences would be felt as a result of the social and local economic impact on fishing communities Perhaps 30000 men representing the crews of 3000 canoes and semi industrial boats and 15000 women engaged in marketing and processing would lose their present livelihoods Population migration away from the coast could follow and severe social pressures and local economic hardship This is clearly a ldquoworst caserdquo scenario and if conditions were to worsen gradually it might be possible to intervene but the fact has to be accepted that fish stocks are dynamic and subject to rapid decline (as in the case of the North Sea Herring and Atlantic Cod) 73 OPTION B THE lsquoWEAKrsquo SOLUTION The bleak future painted in Option A is unlikely to arise if the present policy and draft fisheries development plan is followed since these are specifically directed to addressing the major challenges However realization of the aims is dependent upon delivery across a wide range of initiatives by multiple stakeholders The following paragraphs illustrate some of the ways in which delivery of policy objectives might be thwarted These may be summarized as
bull Commitment to good governance and institutional reform bull Political resolve to implement unpopular measures bull Availability of adequate technical and financial resources bull Inertia to necessary changes in fishing practice
Good Governance and Institutional Reform Fundamental reforms are required to fully equip the national fisheries management effort at government level This includes introduction of change management clarification of responsibilities for senior staff rationalization of financial management systems provision of equipment expansion of staff numbers additional training and capacity building As an illustration of the extent of the effort required reference can be made to just one topic area the issue of monitoring control and surveillance At present the Fisheries Commissionrsquos MCS Unit has only 10 employees to oversee implementation of the fisheries regulations throughout Ghana This number will be increased as other institutions are engaged in joint monitoring initiatives but it is obvious that staff numbers and capacity will need to be expanded if regulations on fishing activities are to be affected Enforcement is only one part of the equation however Much greater emphasis will need to be placed on voluntary controls and self-policing at community level through Co-management schemes
Failure to press ahead with governance and institutional reform could delay the process of introducing and registering licenses which represents a crucial first step in moving from open access to managed access in the fisheries sector Given the urgency for action the five years allowed in the current plan for completing the registration process seems very generous Political resolve to implement unpopular measures Stakeholder meetings have confirmed the significance of party political influence as a constraint on achieving progress in the reform of the fisheries sector The offer of incentives like subsidies or the promise of new facilities and equipment are regularly employed by individual politicians to garner votes whether or not these form part of party manifestos Examples have been quoted to the consultants where enabling regulations that might restrict fishing access and prove unpopular amongst the fishing community are quietly ignored and officers may be discouraged from pursuing breaches of the law where the offender has political influence These issues arise with governments of all political
55
persuasions and can apply at all levels from District Assemblies through to regional and national committees
A serious issue with fisheries sector reform is that once actions have been taken to conserve fish stocks it may be years before the full benefits are felt and the results are evident in terms of increased catches This makes it harder for governments to institute unpopular reforms ndash even though these are in the best interests of the nation fishing communities and individuals Fishermen and their families are used to seeing an instant lsquosame day returnrsquo on their catch and are less willing or able than stakeholders in other economic sectors to wait for gradual improvements There is an urgent need to establish cross-party support for the fisheries sector in Ghana and to seek agreements between the main political parties to support established policy and regulations where these are in the interests of delivering sustainable fish stocks Availability of Technical and Financial Resources The process of moving from complete open access to restricted use rights for both marine and inland capture fisheries will take many years to complete Progress will be heavily influenced by the level of political will availability of technical assistance and financial support Existing subsidies (pre-mix fuel and import tariffs) are seen as a deterrent to the encouragement of more efficient business practices However in order to reduce dependencies on these forms of government aid there is also a need to underwrite new forms of economic enterprise by giving help to start-up businesses developing training centres and promoting alternative livelihoods for those individuals who are either displaced or voluntarily give up work in the fisheries sector Inertia to Change Traditional fishing practices are quite literally a way of life for many Ghanaians and have been handed down from generation to generation These traditions are closely interlinked with cultural practices and power and influence resides in specific families with hereditary authority In order to change attitudes and gain acceptance of new approaches to fishing there is a need for a major awareness building and communications strategy targeting in particular the traditional leaders of the fishing industry Without such a plan it will be difficult to break down the internal resistance and inertia towards change The constraints that have been outlined above in relation to the lsquoweakrsquo option are very real and in combination they present a serious barrier to progress It will require real political commitment on the part of Government and strong financial support from international partners to break down these barriers 74 OPTION C THE lsquoOPTIMUMrsquo SOLUTION
The new Draft Fisheries and Aquaculture Plan together with the Act and Policies provide a solid foundation for revitalising the fisheries sector in Ghana However for the reasons discussed in relation to options A and B above there are a number of impediments that need to be overcome In addition to the measures in Option B an ldquoOptimumrdquo solution would also include
A coherent mix of Incentives (carrots) and Regulation (sticks) A top priority in developing existing strategies and plans will be to ensure that measures are in place to offer encouragement and practical assistance to fishers to convert to more sustainable practices while at the same time introducing effective enforcement There are some real challenges with both of these goals
56
New forms of incentive need to be developed to convince boat owners and their crews that it is worth their while to drop illegal methods (dynamiting use of monofilament nets etc) and to reduce the level of fishing effort (through close seasons introduction of restricted zones etc) Without these incentives it is highly unlikely that there will be significant take-up of the fisheries stock management and conservation message Special attention needs to be given to the role of chief fishermen and local community councils in developing effective local policing since it is impractical to rely on a national MCS team to regulate canoe activity in either the marine or inland capture fisheries The national MCS team will have its own responsibilities for policing local and international waters in relation to industrial and semi-industrial sized vessels Integrated Coastal Development The long term success of the fisheries strategy depends upon reducing fishing effort to a level at which catches become both sustainable and profitable for those who remain in the business This in turn requires that those displaced from the industry are able to find gainful employment and livelihoods in other sectors of the economy The fisheries industry is often seen as a separate economic sector which attracts its own funding and support but in order for the necessary reforms to take place these attitudes will need to change A new approach is required to lsquointegrated coastal developmentrsquo following the lessons from integrated rural development Many fishing inland and marine fishing communities are almost wholly dependent on fishing with less than 10 of the local economy being devoted to other industries Reform of the fishing sector therefore requires that as much ndash if not more ndash effort is devoted by government and its international partners to building up complementary economic activities in construction transportation manufacturing food processing environmental conservation and tourism There is a need to explore new state industry partnerships to establish appropriate economic development agencies and to coordinate activities between relevant state institutions ministries and departments under the current decentralisation initiatives with district assemblies taking a prominent role If initiatives of this sort are taken forward it will make the task much easier in persuading conservatively ndashminded fishing communities that they need to simultaneously develop their own entrepreneurial flair and impose their own discipline
57
Chapter 8 DRAFT ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK (ESMF) 81 INTRODUCTION Previous chapters of this report have described the principal environmental and social impacts that are likely to arise from reform in the fisheries sector This chapter sets out the Framework (ESMF) for an Environmental and Social Management Plan (ESMP)The first step has been to outline specific objectives to be achieved through implementation of the ESMF These objectives relate specifically to the issues described in earlier chapters Subsequent sections of the chapter detail the measures which are required to respond to specific areas of environmental and social impact through mitigation and amelioration works They also describe the types and level of environmental monitoring required together with the institutional aspects which need to be improved in order to support the fisheries sector 82 STRATEGY AND OBJECTIVES The basic aim of the environmental and social management plan is to set out guidelines for participatory programs under which members of local fishing communities and civil society in general can become involved in the design and implementation of local fishery co-management maintaining sustainable local livelihoods and achieving local monitoring of fishery efforts The basic principle for future fisheries management is that both marine and inland waters will be demarcated as territories for use rights to fisheries (TURFs) The principal goal of government policy in the fisheries sector is to ensure that the fisheries industry plays an increasingly important role in supporting the growth of the economy as outlined in the Ghana poverty reduction strategy (GPRS II) and the Republic of Ghana fisheries and aquaculture policy This goal will be supported by implementation of the fisheries and aquaculture sector development plan over the next five years In this timescale the aim will be to bull improve management of fisheries the conservation of aquatic resources and protection of the
natural environment bull promote value addition in the fisheries sector and the improvement of livelihoods in fisheries
communities bull encourage sustainable development of aquaculture bull improve the services provided to the fisheries sector by the fisheries commission and supporting
institutions The overall consequences of this strategy and the investments that are being made by the government and its aid partners will be stabilisation of fish stocks and sustainable catch levels a strengthening of the national economy and creation of a more robust fisheries industry with consequent benefits for fishing communities Impact assessment confirms that the result will be significant benefits for the marine environment and local economy However depending on the rate of transition from an open access to a fully regulated market a number of adverse effects could arise unless appropriate mitigation measures are put in place Specific issues which require attention in this plan are listed below bull potential risks of environmental degradation through development of new fishing targets in
deep water
58
bull localised environmental impacts at construction sites bull loss of resources for individual operators due to restricted or controlled access to fishing
grounds bull displacement of labour from crews of vessels that are withdrawn from the industrial and semi-
industrial fleet bull Decommissioning of obsolete industrial vessels may not necessarily lead to recovery of fish
stocks Catch Per Unit Effort (CPUE) may increase This could lead to loss of livelihoods to crew members and the owners of the decommissioned vessels it could increase catch for the few vessels remaining in the system
bull increase production costs due to idling time in closed seasons for fishing bull exclusion of some groups and individuals seeking entrance to the industry following completion
of licensing bull concentration of processing and marketing at selected landing sites leaving Fish Mammies and
their dependents in other smaller fishing communities at an economic disadvantage bull displacement of traditional canoe building and other ancillary support industries by more
efficient and modern methods of construction and the inability of some workers in these trades to train and re-skill in the use of modern materials
bull lack of employment opportunities in alternative sectors The ESMF will set out specific actions to address these concerns through a coordinated set of interlinked proposals as follows 1) Preparation of local management plans and close surveillance of all new fishing enterprises in
deep waters
2) Preparation of environmental protection clauses to be included in all contracts and agreements for physical development work
3) Regular inspection by environmental protection officers of construction work at harbours and landing sites
4) Establishment of community management plans to provide support to those groups and individuals who are adversely affected by any of the measures listed above
5) Creation of community liaison groups to actively support community development alternative livelihoods and conversion to new areas of economic activity for those Fisher families or individual fishers who are adversely impacted
6) Introduction of skills training centres and business advice for small and medium enterprise development
7) Establishment of a coastal development agency drawing on the resources of the ministry of local government agriculture and tourism (others to be added) to coordinate integrated projects and initiatives for economic development linked with the existing coastal zone management plans
8) Creation of a liaison group between the government of Ghana and its international development partners to ensure that investment in the fisheries sector is targeted in the most effective way to deliver plan objectives and avoid duplication of effort
59
83 COMPONENTS OF THE ESMF The following paragraphs provide a summary of the draft ESMF 831 Local Management Plans these plans will be prepared for discrete zones of influence around specified fishing settlements Each plan will contain the same standard list of relevant activities that are to be monitored 832 Environmental Protection In relation to construction activity a checklist will be prepared identifying precisely what level of environmental scrutiny is required for specific types of development This checklist will be prepared by the Fisheries Commission with the support and advice of the Environmental Protection Agency 833 Small-Scale Project Development and Livelihood Restoration a list of potential micro-projects will be prepared by the Fisheries Commission which are regarded as suitable for support funding Demand for these micro-projects will be determined at the local level (ie in villages and fishing communities) Applications for funding of micro-projects will be submitted to the community liaison group for vetting and recommendation based on pre-established eligibility criteria Recommended projects will be referred for formal approval at national level (or through the Coastal Development Agency) 84 POTENTIAL PROJECT IMPACTS ON ASSETS AND LIVELIHOODS The project will have some adverse impacts on assets and livelihoods Therefore provisions will be made under the ESMF to minimize all such impacts including those of socio- economic significance and on any environmentally sensitive sites Provisions are also made in the RPF to accommodate all potential situations including cases that may entail actual displacement and livelihood restoration assistance in accordance with the Governmentrsquos policy and World Bank Policy on Involuntary Resettlement OP412 (see Chapters 9 and 10) The potential social and environmental impacts associated with the project (see Chapters 5 and 6) are summarised in Table 81 and the approach to related mitigation measures is defined in section 85 and Table 82 below
Table 81 Potential Environmental impacts and Social issues
Type of Activity Description Environmental Significance
Social Significance
Decommissioning of obsolete industrial vessels
Scrapping of vessels may release toxic waste (contaminated oils asbestos pipe wrapping and insulation etc)
Contamination of landfill dumps
Related health hazards
Laying off of work force Recovery of fish stocks in areas currently over-fished by trawling
Decommissioning of excessovercapacity would result in loss of livelihoods for crew members
60
Plan for fishing capacity reduction
introduction of licensing system for canoes and enforcement of licensing system for semi industrial vessels
Reduced catch from the decline in the use of prohibited fishing methods (activities) as stipulated in the Fisheries Regulation 2010 (LI1968) eg use of light dynamite etc
Reduction in fishing capacity should lead to significant recovery of fish stocks with long term benefits for all
Short term reduction in fishing effort and increased regulation may prejudice vulnerable sectors (illiterate elderly fishers) Capping on new entrants may remove the safety net opportunity offered by fisheries to would-be fishers who may be without alternative livelihoods
Harbour development and landing site improvements
Construction of access road improvements Erection of fish processing and ice making plant The Project could give rise to a small level of physical displacement for some sectors of individual communities
Removal of shelters homes Displacement of boat repair and trading sites for local community
Possible non-voluntary resettlement including vulnerable groups (women children and the elderly)
Adaptation Strategies to climate change
Introduction over time of regulations relating to fishing activity in rivers lakes estuaries lagoons and lsquoareas of upwelling affected by climate change
Measures to combat tackle rising temperature and other climate induced changes should ameliorate environmental impacts
Both beneficial and adverse effects may result from changes in climate (eg faster growth rates from higher water temperature spread of invasive species)
Establishment of exclusion zones ndash oil production and marine protection areas
Restrictions on fishing in oil production areas and marine protection areas
Positive ndash recovery of fish stocks but also potential risks of pollution from oil leaks and human waste
Temporary loss of livelihood for those fishers displaced from lsquotraditionalrsquo fishing grounds
Development of Co-Management System
Creation of 4 pilot Stakeholder ndashbased Fisheries Management Initiatives
Demonstration of practical benefits for the marine environment resulting from elimination of damaging practices
Greater social cohesion and sense of purpose established
61
Type of Activity Description Environmental Significance
Social Significance
Support for PAPs Establishment of enterprise training programmes
Development of criteria for defining Project Affected Persons (PAP) Development of skills training schemes enterprise allowances alternative livelihoods fund
Major benefits for PAPs ndash but scope for misinterpretation mismanagement of programme at local level Jobs created under social significance should be familiar to the fishers ie things they will be willing to do
Developing Compliance Systems
Establishment of enforcement unit and development of facilities and training for participatory coastal surveillance of small-scale fisheries
This component will greatly improve controls over environmentally unfriendly damaging activities
A number of new jobs should be created under this programme
Improvements in fish processing technology
Development of more efficient fish processing plant
This measure should reduce significantly the proportion of fish lost or degraded post harvest Improved fish processing technology will also reduce wood used from the forest as firewood for fish smoking
Potential displacement of vulnerable groups (women children and the elderly)who currently participate in fish drying curing using basic equipment
Construction of fish ponds
Expanding areas of dug-outs and other farm ponds
Small scale impacts on vegetation stream flow
Displacement of existing land users
Catalysing aquaculture development
Encouragement of larger fish farming enterprises Installation of fish cage aquaculture
Localised deterioration in water quality increased nutrients leading to eutrophication potential spread of fish parasites disease
Potential competition with free capture fisheries displacing vulnerable groups in existing fishing villages
62
85 PROPOSED MITIGATION MEASURES AND COST ESTIMATES Mitigation measures The potential environmental and social impacts to be addressed within the context of preparing this Environmental and Social Management Framework are generalized as shown in Table 82 below It is not possible at this time to prepare specific mitigation measures It is expected though that environmental and social assessment studies will be carried out within specific localities as and when required The framework for compensationresettlement (See Chapters 9 and 10) will then be applied incorporating (1) specific institutional arrangements (2) resettlementcompensation eligibility criteria (3) implementation procedures (4) financial responsibilities and (5) monitoring and evaluation plan Livelihood restoration measures Furthermore the livelihood restoration measures will consider issues such as
(1) income levels of affected persons
(2) other non-monetary sources of livelihood
(3) constraints and opportunities for income generation
(4) number of persons not able to revert to previous occupation and
(5) existing skills of affected persons
Table 82 Proposed mitigation measures for some potential impacts
Type of Impact Description of mitigation measures
1 Decommissioning of obsolete industrial vessels
a) A register will be prepared of all industrial vessels that are due to be decommissioned recording the owner and location of each vessel b) A system will be introduced for tracking progress on decommissioning including the means of disposal and measures taken to dispose of all potentially toxic or hazardous materials c) Persons who lose their job or livelihood as a result of a decision to decommission any particular vessel will be entitled to benefit from the skills training schemes enterprise allowances alternative livelihoods fund being developed
2 Plan for fishing capacity reduction
a) A full Social and Environmental Impact Assessment will be carried out on the Plan for fishing capacity reduction and appropriate measures for ameliorating and mitigating adverse effects on affected sectors of the community and PAPs will be incorporated in a revised edition of this Fisheries Environmental and Social Management Framework
63
3 Harbour development and landing site improvements
a) All harbour development proposals will be subject to Environmental and Social Impact Assessment (ESSA) in accordance with EPA Regulations b) Proposals for improvement of individual landing sites will be assessed in accordance with the checklist (832) and submitted to EPA for a ruling on the level of environmental assessment that is required which will depend on the nature of the intended works
4 Adaptation Strategies to climate change
a) An adaptation Strategy shall include proposals for mitigating any impacts on the environment or social welfare of local communities
b) Any strategy for responding to potential effects of climate change on the fisheries sector will be submitted to EPA for review to determine whether an SEA or EIA is required
5 Establishment of exclusion zones ndash oil production and marine protection areas
a) Proposals for restricting access of fishing vessels to oil production areas and marine production areas shall be subject to an Environmental and Social Assessment which shall be submitted for approval to EPA b) In the event that restrictions are likely to adversely affect fishersrsquo livelihoods the provisions set out in 7 below will apply
6 Development of Co-Management System
a) Development of co-management systems will require full cooperation and engagement of all stakeholders In the unlikely event that the provisions of any scheme are challenged by local communities there shall be a right of appeal to the Minister of Food and Agriculture and the Fisheries Commission acting jointly
7 Support for PAPs
Establishment of enterprise training programmes
a) Identification of vulnerable people including women children and the elderly and identification of the cause and impacts of their vulnerability shall be established through direct interviews and procedures to be developed as part of 6 above b) A high priority within the Fisheries and Aquaculture Sector Development Plansrsquo first five year programme will be the development of specific proposals for the establishment of skills training programmes and the establishment of enterprise allowances and an alternative livelihoods fund c) The measures outlined in 7b) above will be targeted specifically at PAPs and vulnerable sectors of the community
8 Developing Compliance Systems
a) All proposals for securing compliance with fisheries regulations shall be subject to review by a fisheries stakeholder committee to be established by the Fisheries Commission with the remit of ensuring that the measures themselves and penalties for failure to comply are commensurate with the ability of offenders to make restitution and do not unfairly penalize vulnerable sectors of the community
9 Improvements in fish processing technology
a) All plans and proposals for the introduction of new fish processing technology shall be published and shall include a statement on the likely impact of the project on existing processors within the local community
64
b) Any members of the public who consider they are unfairly disadvantaged by proposals for the introduction of new technology may apply to the local co-management committee to determine whether or not they fall within the category of PAP (see 6 and 7 above)
10 Construction of fish ponds Proposals for the construction of new fish ponds shall be assessed in accordance with the checklist (see section 832)
11 Catalysing aquaculture development
a) All proposals for aquaculture development shall be in accordance with the provisions laid down in Local Management Plans applying to specific TURFs
65
4
Chapter 10 looks in more detail at specific safeguards relating to possible involuntary relocation of people as a result of the long term fisheries programme It constitutes the Resettlement Policy Framework (RPF) which while not a formal legal requirement of the World Bankrsquos lending policy is nevertheless recommended as good practice
5
PART A ENVIRONMENTAL AND SOCIAL SAFEGUARDS ASSESSMENT
The Environmental and Social Safeguard Assessment comprises bull Three background chapters (1-3) bull Two chapters which deal with assessment of the potential effects of the World Bankrsquos financial
and technical support for the Ghana Fisheries Programme over the initial five years (Chapter 4) and the longer term effects of the overall Fisheries Programme which is expected to run for 10-15 years (Chapter 5)
bull Analysis of the consequences of taking no action (the do-nothing option) in Chapter 7 and bull A draft Environmental and Social Management Framework (Chapter 8)
7
CHAPTER 1 INTRODUCTION
11 INTRODUCTION The government of Ghana is embarking on a Fisheries and Aquaculture Sector Development Plan (FASDP) for restructuring its coastal and inland fisheries The aim is to reverse the current trend whereby fish stocks are increasingly diminishing and the current rate of fishing is unsustainable resulting in less productive fisheries increased costs with declining profitability and the risk of exacerbating nutritional deficiencies and poverty within fishing communities To date the government has enacted legislation (Fisheries Act 2002) prepared policies (2008 updated in 2010) and published regulations (August 2010) but the Ministry of Food and Agriculture and the Fisheries Commission lack the capacity and financial resources to implement all of these initiatives The World Bank is therefore considering a supporting programme of technical assistance and finance which will assist with governance reforms the introduction of licensing for all vessels a reduction in the size of the industrial and semi-industrial fishing fleets and the progressive transfer of fishing activity to the canoe sector International support for Ghanas fishing industry is being coordinated under the West Africa Regional Fisheries Programme (WARFP) This initiative began with four countries Cape Verde Liberia Sierra Leone and Senegal It is now being extended to the following countries Ghana Guinea Guinea Bissau and Gambia A process framework has been developed by the Commission sous Regionale des Peche (Based in Dakar Senegal) to assist member countries of WARFP to prepare their own national process frameworks together with accompanying environmental and social safeguards assessment an environmental management plan and resettlement policy This report has been designed to provide the outline structure and contents for these documents on behalf of the Government of Ghana Another important function of the report is to review the application of the World Banks own Environmental and Social Safeguard policy to the planned investment Both the governments development plan (FASDP) and preparation of the World Banks financial assistance package are at an early stage Consequently this report covers (and can only cover) the broad principles and sets out initial conclusions It will be necessary for further reviews to be undertaken when the Government of Ghanarsquos programme has been developed in more detail Objectives of the Environmental and Social Assessment (ESA) The overall aims of planned interventions in the fisheries industry of Ghana are to improve fish stocks and increase the sustainability of fishing activity which will have long-term environmental and social benefits for the country However the process of introducing change is likely to have some short-term adverse effects on individuals and particularly those who are vulnerable or disadvantaged within poorer fishing communities unless appropriate mitigation measures are taken The purpose of the environmental and social assessment set out in chapter 6 is to identify potential environmental and social impacts both individually and cumulatively and to assess their relative magnitude duration reversibility and importance Based on these findings the draft management framework (see chapter 8) sets out proposals for avoiding or mitigating unacceptable change The process of reforming the fisheries sector will take a number of years and the existing FASDP covers only the first five years With the exception of proposals to scale down the size of the industrial and semi-industrial fishing fleets it is unlikely that major changes will take effect in terms of fishing activity during this five-year period Consequently from the standpoint of the World Banks investment there are likely to be relatively few issues in terms of potential conflict with safeguarding policies Later
8
however significant change is within the fishing industry and particularly onshore processing and marketing of fish products An important element in this report has therefore been the need to define the point at which the banksrsquo responsibilities are seen to terminate and all liabilities are transferred to other supporting donors and the government of Ghana In the short term a reduction in the industrial fleet may lead to the loss of 1000 to 3000 jobs for crew members although in practice most of this work is only part time and many of the vessels that are due to be withdrawn are no longer seaworthy In the longer term it is intended to encourage more selective fishing by limiting open and unfettered access to fish stocks eliminating illegal and damaging processes including dynamiting uncontrolled light fishing and the use of small size monofilament nets and introducing seasonal restrictions to protect breeding cycles The intention is that these measures will be managed jointly by the government and communities through co-management systems At the same time major efforts will be made to reduce the level of post-harvest losses and to increase the value of fish products The expectation is that the number of industrial semi-industrial vessels and canoes will be stabilised at a fixed lower level within five years Once this point is reached and no further licences are granted individual licences will acquire higher values especially as fish stocks recover and the size and value of fish catches starts to increase Subsequently licenses are likely to be sold and traded as less efficient owners drop out of the market and sell on to stronger individuals and companies In terms of onshore activities fish landing processing and marketing will become more efficient and losses will be reduced through use of better smokers freezing and drying equipment Previous studies in West Africa and elsewhere (Bennett et al 2001) have shown that the transition away from open access to a more regulated system of access management can give rise to social risks Specifically older men are likely to be displaced when they are no longer fit enough to withstand the rigours of fishing while a rising number of young men may find it harder to enter a career in fishing Women who currently manage or assist with all areas of buying processing and marketing using traditional clay ovens may also experience competition as new companies and enterprises are established to take advantage of higher profitability in the fishing sector perhaps using better equipment newer technologies and different logistics arrangements or their own transportation Methodology This study has followed the methodology developed within the process framework for the West Africa regional fisheries programme (WARFP) Figure 1 sets out both sequence and timescale for the work
The range of jobs at risk is based on assumptions about the number of vessels and average crew size and cannot be determined with any degree of accuracy until the necessary surveys are undertaken
9
The report is based on three major areas of activity 1 documentary analysis and utilisation of the studies already carried out by the fisheries commission 2 meetings with institutional stakeholders principally affected by the project and 3 Consultations and visits to some of the key fishing villages and communities The planned presentation of findings to Stakeholders has been postponed at the Clientrsquos request due to other pressing commitments in the agriculture and fisheries sectors This presentation will however need to be subsequently undertaken by the Ministry and the Fisheries Commission
11
CHAPTER 2 PLAN AND PROGRAMME DESCRIPTION
INTRODUCTION This chapter is divided into two parts Part 1 sets out the progress which the government Ghana is making in giving effect to the legislation policy and regulations Part 2 describes the proposed programme of assistance being offered by the World Bank with the specific aims of strengthening governance and enforcement systems (Components 1 and 2) and in promoting value addition and reduction of post-harvest losses
PART 1- THE DRAFT FISHERIES AND AQUACULTURE SECTOR DEVELOPMENT PLAN (FASDP) This plan (FASDP) covers the period 2010-2015 It recognises the importance of Ghanarsquos fisheries which generate in the order of US$ 1 billion a year contribute 45 to GDP and indirectly support the livelihoods of 22 million people However through over-fishing and lack of investment in management and value addition the average income per canoe has dropped by up to 40 over the last ten years to the point where it costs as much to fish as the catch is worth By comparison well managed fisheries in other parts of the world are capable of generating economic returns of 30-60 on investment (equivalent to a potential income of US$ 300 million a year for Ghanarsquos fisheries) The Draft FASDP acknowledges that the fishing sector is expected to make a substantial contribution towards doubling the size of the Ghanaian economy by 2015 (GPRS II) as part of the Republic of Ghana Fisheries and Aquaculture Policy Seven targets are set in the draft FASDP 1 Maintaining capture fisheries production at current levels 2amp3 Increasing revenue and profitability in capture fisheries by at least US$ 50 million a year after
five years 4 Increasing aquaculture production to 35000 tonnes a year after five years 5 Retaining Ghana as a landing and processing hub for the West Africa tuna industry 6 Developing fisheries management to allow effective control of all commercial fishing effort in
Ghanaian waters and 7 Ensuring fisheries management costs are sustainable and that the fisheries sector overall make a
fiscal contribution to Government revenues There is an underlying presumption that the canoe sector will remain at the heart of Ghanarsquos fishing industry but the plan is not prescriptive and leaves open the ways of achieving the overall goals At the same time there is an underlying assumption that the long term sustainability of Ghanarsquos fisheries will depend upon discouraging further entry by new operators
PART 2 THE WORLD BANKrsquos CONTRIBUTION TO GHANA FISHERIESPLAN (FASDP)
The essential aim of the World Bankrsquos contribution to FASDP is to provide investment which will build the necessary policy and capacity for effective fisheries management designed to reduce fishing effort while maintaining approximately the same catch levels and to address the impacts of change for fishers
12
and the communities in which they live Based on the currently available draft Project Appraisal Document (PAD) each of the components is now described in turn Component 1 - Good governance and sustainable management of the fisheries This component on good governance comprises four subcomponents which are broken down in turn into a number of separate activities Sub-component 11 developing the capacity rules procedures and practices for good governance of the fisheries Activity 111 reviewing the Fisheries Act and developing regulations to support the Sector Policy and the Fisheries and Aquaculture Sector Development Plan Activity 112 Developing an operational policy to enable implementation of the aquaculture and fisheries sector development plan Activity 11 3 strengthening fisheries management systems and capability (fisheries management plan development aquaculture implementation technical support and training) Activity 114 strengthening fisheries Information Systems (catch recording and monitoring systems statistical analysis and training)
Sub-component 12 introducing fishing rights
Activity 121 developing pilot stakeholder-based fisheries management initiatives around defined fisheries units (ie local management initiatives tighter defining fisheries resources in up to 6 selected Fisher communities) Activity 122 introducing and administering a licensing regime
Subcomponent 13 Adjusting fishing effort and capacity to more sustainable levels marine resource conservation and supporting alternative livelihood opportunities when needed Activity 131 vessel decommissioning Activity 132 compensation packages for crew of decommissioned industrialsemi-industrial vessels Activity 133 alternative livelihood development to incentivise voluntary capacity reduction in the canoe sector Activity 134 marine resources management and conservation
Subcomponent 14 social marketing communication and transparency Activity 141 communications stakeholder consultations and awareness raising programmes to support fishery development Component 2 reduction of illegal fishing Under the West Africa regional fisheries programme subcomponent 21 allows for enabling environment for reduction of illegal fishing These provisions already exist within Ghana and this subcomponent is therefore omitted Subcomponent 22 monitoring control and surveillance (MCS) systems Activity 221 developing compliant systems and capability
13
Component 3 increasing the contribution of the marine fish resources to the local economies Subcomponent 31 product diversificationvalue chain development (freshfrozen producttrade facilitation) Activity 311 landing site development Activity 312 Port development Subcomponent 32 fish product trade infrastructure information and systems - regional minimum integrated trade expansion platform (MITEP) Activity 321 export certification centre development Activity 322 fish processing technology improvements Activity 323 national fisheries advisory group Subcomponent 33 marine and inland aquaculture development Activity 331 space developing aquaculture policy and legal framework Activity 332 improving genetic policy of tilapia fingerlings and breedstock Activity 333 catalysing aquaculture development Component 4 Coordination monitoring and evaluation and program management Subcomponent 41 national implementation subcomponent 42 regional coordination Each of the components sub-components and activities are described in more detail in Chapter 5 which assesses the nature of environmental and social safeguards issues in terms of the World Bankrsquos planned investment
15
CHAPTER 3 BASELINE CONDITIONS
INTRODUCTION This chapter discusses the existing fishery resources of Ghana and describes recent environmental and social trends It identifies some of the pressures that led to the reduction in value of fishing activity and indicates the threats that could be posed if no action is taken in accordance with the planned fisheries and aquaculture program to deal with them FISHERY RESOURCES The continental and coastal waters of Ghana are potentially very rich due to a combination of warm waters and nutrients carried in ocean currents which up-well seasonally on the continental shelf The tonnage of fish caught in marine waters peaked in the mid-1990s around 500000 tonnes and currently averages around 400000 t(See Figure 1) Figure 1 Wild Capture Production in Ghana 1950-2005
2
Table31 Top 10 Species Exported (by value)
1 Canned tuna ($72000000) 2 Fresh tuna ($7200000) 3 Tilapia (no figure available) 4 Miscellaneous dried fish ($1000000) 5 Salmonids frozen ($900000) 6 Marine fish frozen ($600000) 7 Cuttlefish and squid ($600000) 8 Shrimps and prawns ($90000) 9 Sardines ($80000) 10 Crustaceans frozen ($50000) Source FAO Fishstat
The principal catch from deep waters is tuna Industrial vessels registered in Ghana target these species in international waters but also illegally in coastal waters Herring sardine and anchovies are fished in coastal waters by semi-industrial vessels and canoes Table 31 shows the top 10 species of fish exported from Ghana in 2005 PROFILE OF THE FISHING INDUSTRY Fishing is of vital importance in Ghana not only in terms of its contribution to gross domestic product (45 per annum) but because fish provides 65 of the countrys protein In recent years (between 2003-2008) and more specifically in 2004 the countryrsquos annual fish requirement has been estimated to be 882000 tonnes of which the country produces just about half (Tetteh 2007) Of the total population of 22 million people it has been estimated that between 15 and 22 million people are employed or gain their livelihoods from fishing (8-10) Of these there are 210000 men who are directly employed as
2 This figure is the Fisheries Departmentrsquos estimate for 2008
16
fishers The total export of seafood was valued US$824 billion in 2005 Ghanas fishing industry can be divided into three sections marine capture inland capture and aquaculture It can be further analysed by scale of operations distinguishing between industrial semi-industrial and artisanal sectors Marine fisheries Industrial sector Commercial fishing for tuna began in 1962 In the early 1980s Ghana sought to develop an industrial fishing fleet and there are currently 90 industrial trawlers and other vessels which are located in Tema and Takoradi Sekondi The port of Tema was expanded from 1962 to create four main areas the Inner Harbour Outer Harbour Canoe Basin and Commercial Area In 1999 fish landing facilities were improved at the Albert Bosumtwi Sam Fishing Harbour built in Sekondi This harbour is equipped with a cold store an ice-making plant offices a berthing bay for inshore vessels a jetty for canoes and a net drying area Under Ghanaian law more than 50 of the ownership of industrial vessels must be registered with a Ghanaian company or individuals However in practice many vessels are owned by foreign nationals with token Ghanaian ownership Relatively few of these large vessels regularly put to sea and a number are in poor condition or obsolete Nevertheless the impact of trawling activities by Ghanaian registered and foreign owned vessels has been very considerable in coastal waters in recent years Fish landed from industrial vessels is usually transferred directly to Canning factories in Tema and Takoradi Ghana has the largest canning industry in West Africa In the region of 30000 tonnes of tuna are landed In addition to trawling some industrial vessels are engaged in shrimping the use of tuna lines and polls purse seining and demersal trawling Semi-industrial sector in addition to deep sea trawlers there are around 230 large semi-industrial ships propelled by inboard motors which are used for trawling in shallow waters during the off-season and purse seining during upwelling seasons There are currently reported to be 48 bottom trawlers 14 pair trawlers 2 shrimpers 33 pole and line vessels and 10 tuna purse seiners operating from 2 of the 7 landing sites Canoe sector Ghanas artisanal fishing sector is based on between 10000 and 12000 wooden canoes Fifty seven per cent of the fleet is powered by outboard motors supported by paddle and occasionally sail Each Canoe carries a crew of between three and 20 men depending on size and length There are over 334 landing sites along the 550 km coast of Ghana and the majority of fish caught by canoe (180000 tonnes) is returned to these sites accounting for 70 of Ghanarsquos fish production The principal landing sites are at Teshie Jamestown Chorkor Shama Axim Elmina Winneba Mumford Akplabonya Adina Atiteti Abutiakope and more Fishing is undertaken by men but the majority of canoes are owned by women who pre-finance fishing trips (purchasing gear and premixed fuel) and purchase the catch Women also predominate in processing and marketing fish and fish products Only about 20 of fish sold fresh a further 20 is salted and the majority (60) is smoked It is estimated that up to 30 of the catch is spoilt through lack of ice for storage or alternative processing facilities
17
Inland fisheries Water Resources Ghanarsquos inland fishery resources consist of a natural lake( Lake Bosomtwe) and nine major river basins which from east to west of the country are
bull the Volta bull Densu bull Ayensu bull Ochi bull Kakum bull Pra bull Ankobra and bull the Tano
The River Tano forms the border between Ghana and Cote drsquo Ivoire The largest of the rivers is the Volta which drains more than two-thirds of the country through several large tributaries in virtually all regions of the country The Volta river system also incorporates the Volta reservoir generally known as the Volta Lake which has a surface area of around 8400 km2 The Volta lake discharges through the Akosombo dam before flowing through a delta into the Atlantic Ocean The eight other river systems are relatively smaller simpler and open more directly into the Atlantic There are also several reservoirs created on the smaller river systems mainly for potable water production irrigation and flood control These reservoirs irrespective of their primary purposes enhance availability of more permanent aquatic habitable space for fish and therefore support some fisheries Finally with all the river systems opening into the Atlantic there are a series of lagoons and estuaries which act as interfaces between the rivers and the sea These water areas constitute another type of inland water resource for salt and brackish water fishes Inland Fish resources Within the inland water resources of Ghana there are over 150 fish species more than 90 of which are fished for food
In commenting on inland fisheries in Ghana it must be noted that virtually all available information on inland fisheries is obtained from the Volta Lake No national fish production records have been kept on the fisheries of the eight smaller river systems and the lagoons and estuaries Thus the usual statement that inland fish production constitutes about 20 of what the country produces should refer to fish production from the Volta Lake In practice the total inland fish contribution could more realistically be estimated at about 30-35 of national fish production This is a very considerable but understated contribution to national food security and nutrition
Fishing vessels The dominant fishing vessel on the Volta Lake is the canoe the majority of which are built from wooden planks On some other river systems while plank canoes predominate a small number are carved as dug-outs from single tree trunks There is some variety in sizes of the canoes depending on how many planks are used to build the boat and the size of tree trunk used in building a canoe The total number of canoes estimated on the Volta Lake during a survey in 2000 was 24035 On the tributary rivers of the Volta Lake and other river systems in the country the planked canoe is the main vessel used in fishing
18
Fishing gear There are about eleven main kinds of gear used for fishing on the Volta Lake They are Gill Nets Cast Nets Hook and Line Basket and wire mesh traps Winch net Beach seine Bamboo Nifa-nifa Wangara Spears and Atidzas On other rivers in the country Gill nets Cast nets Hook and Line and traps are the fishing gear used On both the lake and rivers the Gill net is the main gear
People Involved In the 2000 frame survey of the Volta Lake conducted by the Fisheries Directorate of Ghana the estimate of fishers on the Volta Lake was put at 71861 Fishers on the lake work in collaboration with a host of fishmongers or handlers who also function as wholesalers for individual fishing groups Assuming that the fisher population on the lake has increased by a modest 3 in the ten years from 1998 to 2010 a fisher population of about 93500 could be considered to be on the Volta Lake now If again it is estimated that number of fishers on rivers in the country were to be a tenth of those on the lake this would put the fisher population on inland waters (apart from the Volta Lake) at about 9350 fishers A very conservative estimate therefore puts the total number of individuals who are directly engaged in inland fishing at over 100000 This excludes all directly associated groups such as fish handlers processors and traders An estimate of secondary fisheries operators such as boat builders out-board motor operators and mechanics as well as bulk salt and fuel wood sellers and those engaged in buying selling and distributing fish would have to be considered in developing estimates for both direct and indirect employment in inland fisheries but the number can be assumed to lie between 125000 and 150000 people
Aquaculture Under Ghanarsquos legal framework aquaculture is defined as ldquoany activity designed to cultivate or farm fish and other aquatic living resourcesrdquo Currently only fin fishes are involved in aquaculture in Ghana
Current culture media and environment Currently fish culture takes place almost exclusively in fresh water in Ghana either in cages brush parks or dugouts Dug-outs are excavations made in floodplains in the savannah parts of the country were water scarcity has been a major hindrance to development in general and food security in particular Dug-outs get filled with flood waters and whatever the water carries during major wet periods of a year in the savannah areas Waters that fill Dug-outs invariably contain fish which are trapped in the Dug-out after the wet period These water bodies are managed until the end of the dry period and the fish are harvested before the next flood period Since the 1960rsquos various strategies to augment fish production from Dug-outs have been developed and tested These involve adding fingerlings of selected fish species to those which are lsquonaturally stockedrsquo in Dug-outs by floods Dug-outs are the major fish culture production approach in the savannah parts of the country which accounts for a little more than half the area of the country The Environment of fish culture Currently fish culture is taking place mainly in freshwater environments Brackish water fish culture and mari-culture activities which will bring lagoons estuaries and the sea into fish culture production have long term potential for development Fishes in culture Fishes being cultivated in Ghana In order of importance are Nile tilapia Oreochromis niloticus the African catfish Clarias gariepinus species of the catfish Heterobranchus and the Bony tongue Heterotis niloticus Scale of Culture Based on level of production fish culture operations can be categorized as follows
bull Large scale commercial where an enterprise produces up to 10000 tonnes per year
19
bull Medium scale commercial where a single enterprise produces between 50 and 500 tonnes bull Small scale commercial where an enterprise produces between one and 20 tonnes and bull Very small scale commercial with productions below 20 tonnes
Fish culture production Cultured fish contribution to national production was officially stated as 9000 tonnes for the year 2009 However informed opinion amongst fish farmers indicates that a figure of between 16000 and 20000 tonnes in 2010 would be closer to reality This statement is based on the facts that most producersrsquo published figures are underestimates several small to medium scale producers are not recorded in official lists and the recording of newly established fish farms has lagged actual establishment especially since 2009 Although cultured production up till 2009 may not have been significant considering a shortfall of about 460000 mt (as recorded in 2004) between captured fish production and national demand this reflected the fact that there were only two large scale commercial producers in the country each of which had had less than ten years of operation Anticipated growth in fish culture production within the next five years is expected to be dramatic as some of the critical challenges of the industry are resolved
CHALLENGES AND PROSPECTS Marine Fisheries The fishing sector is vital for food security and job creation to help alleviate rural poverty in Ghana However the levels of fisheries harvests are generally considered to be close to or to have exceeded the maximum sustained yield Future sustainability in the industry will depend upon the restriction of open access to fisheries and the introduction of management systems which allow fish stocks to recover and the establishment of consistent yields in both marine and inland waters Inland Fisheries Environmental conditions on the Volta Lake constitute the major environmental and social challenges for fisheries its sustainability and profitability In terms of future prospects success will depend heavily on implementation of the lsquoGhana Fisheries and Aquaculture Sector Development Planrsquo and the capacity of the system in Ghana to enforce the Fisheries Regulations passed by parliament in August 2010 Aspects of the Development plan that offers great prospects for the lakes fisheries include the provisions for eventually licensing boats (although the scale of this task should not be underestimated) and measures to involve communities in management of fisheries resources of the Lake
Aquaculture The main challenges facing aquaculture development in Ghana relate to bull The high cost of fish feed (significantly due to its importation from other countries) bull None availability of commercial fish hatcheries as enterprises bull Lack of a nation-wide distribution network for fish seed and cultured fish producers Most
sources of fingerlings are concentrated in one part of the country and since farms all over Ghana obtain their fingerlings individually transportation costs add significantly to overall production costs
bull Now emerging certification and monitoring to check the health and safety of aquaculture processes and products
bull The absence of adequate regulations regarding establishment of an aquaculture enterprise until August 2010 (In the absence of regulations only the large and medium scale commercial farms worked towards conforming to international performance Standards and operational regulations for certification of farms and their products still remain in a draft state)
bull Low national support for research to support expansion and systematic development of aquaculture
20
The prospects for development of aquaculture as an industry in Ghana are good since a number of practical policy and legal frameworks have been put in place to resolve the basic challenges to the industry listed above These include
bull Construction of the first local fish feed plant by an international fish feed company with the expectation of having initial products on the Ghanaian market during 2011
bull A lsquoLarge scale commercial fish farmrsquo with great capacity for fingerling production is shifting emphasis to fish seed production And several localized fish seed producers are expanding operations
bull Distribution strategies by cultured fish producers have started to emerge on a limited scale and are expected to evolve with increasing production as existing commercial farms expand and new ones join in
Now that regulations regarding establishment of aquaculture enterprises have been gazetted there is likely to be a positive response amongst fish farmers of all size categories New operational standards are being prepared which will introduce minimum standards for local certification This should set the stage for preparation of fish culture products and the broadening of choice for consumers while also qualifying Ghanaian producers to enter external markets
ENVIRONMENTAL CONDITIONS The coastal and marine environment a critical zone of influence for this study comprises a 550 km coastline a coastal belt ranging from 1 to 20 km in width and coastal waters extending to 200 nautical mile limit which was established in 1977(under the territorial waters and continental shelf act 1973 as amended by the territorial waters and continental shelf amendment decree 1977) The Coastal Belt The coastal belt accounts for only 65 of the land mass of Ghana but it is one of the most densely settled areas accounting for 25 of the population and80 of the industrial establishments in Ghana Historically the coastal zone was cultivated for coconut (copra) but this industry is in decline Vegetables and other agricultural produce are grown on better soils but the principal economic activities are fishing transportation salt production and sand and stone winning Tourism also offers great potential There is considerable expectation that the discovery of offshore oil and gas deposits will bring new wealth to parts of the coastal corridor However present plans to transfer crude products to tankers at sea and then export them directly will limit industrial activity to a support role A high percentage of industrial and municipal wastes is dumped at landfill sites within the coastal zone which creates pollution risks The coastal belt is generally a low-lying area less than 200 m above sea level Vegetation types reflect the rainfall gradient and consist of coastal shrub and Savannah to Winneba southern marginal forest to the east of Sekondi dry semi-deciduous and moist semi-deciduous forest to the east of Cape Three Points estuary and wet evergreen forest in the extreme south Soils are variable within this area ranging from fertile pockets river valleys to Sandy poorer quality soils close to the sea The Coast The coast line divides into three sections (Ly 1980)
bull West of Cape Three Points this area has a wide and flat beaches backed by coastal lagoons and
21
wave heights are generally low bull Between Cape three points and Tema the coast consists of a series of rock headlands enclosing
shallow bays together with sandbars or spits enclosing coastal lagoons The surf zone is a medium to high energy environment with wave heights often exceeding 1 m South-westerly prevailing winds give rise to longshore drift in an easterly direction
bull Between Tema and Aflao most of the shore is sandy although there are rocky outlets The coastal zone is important internationally in providing feeding roosting and nesting sites for thousands of migratory birds Environmental degradation is significant in Ghana and is recognized in the countryrsquos environmental action plan It contributes to rising poverty levels coupled with poor human health and inadequately planned urbanization which fuel a vicious cycle inhibiting human development The core issues include
bull Domestic sanitation bull Increased urbanization without appropriate infrastructure bull Wetlands and mangrove degradation bull Coastal erosion and bull General biodiversity loss
Briefly each of the above could directly or indirectly adversely influence fisheries and aquaculture separately or together For example in a recently completed study of water quality scenarios of the Volta Lake in relation to fish production as a component of a comprehensive study (The Challenge Program Project of Water amp Food) it was concluded among others that poor sanitation in highly populated fisheries communities adversely influenced water quality to the detriment of fish life and thus fish production With reference to aquaculture the same unsanitary conditions in highly populated shore communities adversely influenced water quality especially in terms of oxygen depletion when lake waters extend to the shore in high water periods This is a situation which has caused fish kills in cages because caged fish cannot escape lsquopollutedrsquo waters Degradation of wetlands and mangroves leads directly to a reduction in their capacities as spawning and nursery zones for both marine and inland water fishes which reduce fish production in both environments The situation outlined above is often contributed to by anthropogenic and industrial pollution due to urbanization without appropriate infrastructure Another issue linking human activity to a deteriorating environment is demonstrated by the encroachment of aquatic weeds on inland waters such as the Volta Lake Weed growth is accelerated by farming reservoir catchments which increases nutrient levels and the building of dams which reduce or cut off intrusion of sea water into rivers Currently as climatic change observable impacts such as floods seem to escape predictions The project could possibly contribute to mitigating against direct and indirect effects of climate change on fishing and aquaculture through investment into climate change orientation and education of fishers and fish farmers to mainly influence reasonable precautions they take Marine waters The continental shelf is relatively narrow projecting out to 25-35 km except in the area of Cape Coast to Salt Pond where it extends to almost 80 kms Sandy and rocky substrates which previously supported coral and seaweeds have been severely affected by former trawling activity which indiscriminately
22
dredges material from the seabed Coastal waters are enriched by freshwater discharges from the relatively small number of rivers and by two seasonal up-wellings which occur between late June and early October (the main upwelling) and January and March (the minor upwelling) The origin and driving mechanisms of these up-wellings are not fully understood and both their location and strength varies from year to year
Lake Volta and other inland water
Major environmental issues on the Volta Lake which might also be considered as challenges to sustainable fisheries on the major inland fisheries resource can be summarised as follows
bull The Volta Lake is known to be low in nutrients It therefore has low standing crops of phytoplankton and zoo plankton to support high fish production
bull The northern segment of the lake together with tributary rivers constitute the spawning and feeding grounds for majority of fish species in the lake during the wet season however these segments are intensely fished during the same period
bull The Volta Lake is divided into eight unequal strata with different distribution of boats per Km2 At the last estimation of carrying capacity in 2000 stratum V and II had the highest (527) and lowest(157) number of boatsKm2 respectively
bull The rate of siltation in the lake is considered to be increasing due to erosion associated with high rates of deforestation
bull A major challenge exists in getting fishers fishing communities and fishing entrepreneurs to understand and comply with fishing regulations aimed at conserving fish and fisheries resources
bull There is a lack of resources studies and research to support fisheries management of the Lake
bull High illiteracy exists amongst lake shore communities
bull Open access to the fish resources of the Lake has been in operation since its formation
bull Declining fish yields are occurring in the lake (468 Kgha in 1976 to 320 Kgha in 2003-MOFA) brought about by the constraints listed above
bull The commonly assumed estimate of potential fish production from the lake of around 75500 mtyr) is considered to be a serious underestimate since Stratum VII alone was estimated to produce 33800mtyr in 1996
bull The policy environment for aquaculture is currently strongly supportive of the industry and related enterprises
bull There is good quality and more than sufficient water to allow some kind of aquaculture to be developed in every region of the country with the Volta lake (about 8400 Km2) as the single most important water unit for fish culture Currently it appears that the free access to the fish resources of the lake has to some extent been applied to establishment of small scale caged fish culture enterprises a situation constituting environmental risk to investments of large scale commercial fish culture establishments in the lake
bull The Volta Lake is low in nutrients (Obeng 1964) resulting in a situation where higher fish yields could be sustained if greater quantities of fish feed were available
23
bull In Ghana the Nile tilapia O niloticus occurred naturally only in the Volta system Due to positive culture characteristics of the fish it has been moved into virtually all other river basins in the country The situation provides opportunities for hybridization of the Nile tilapia with other tilapia species native to the river basin into which the Nile tilapia has been moved
25
CHAPTER 4 POLICY AND LEGAL FRAMEWORK FOR ENVIRONMENTAL AND SOCIAL ISSUES
41 INTRODUCTION
Development and implementation of the Ghana Fisheries and Aquaculture Sector Development Plan and the World Bankrsquos supporting program need to be developed with full regard to existing international conventions national legislation policies and regulations This chapter highlights the main legislative and policy considerations for the protection of the environment natural resources fisheries and social and economic development It begins with reference to the World Bankrsquos safeguard framework and those of other donors This is followed by a section on the governance framework in Ghana
42 WORLD BANK AND OTHER DONORSrsquo SAFEGUARDS POLICIES
The World Bankrsquos safeguard policies exist to ensure that all projects which it finances are developed and implemented on environmentally and socially sound principles A range of different policies exist and these have been carefully considered to ensure that the Ghana Fisheries and Aquaculture Development Sector Development Plan complies with these safeguards All policies have been screened and those that have no bearing on the fisheries programme have been excluded from Table 41 below Table 41 lists policies which could have some applicability to the FASDP even if this interaction might be very slight It is important to stress that the comments in the third column of Table 41 relate to the entirety of the Fisheries and Aquaculture Sector Development Plan whose effects will continue to be experienced long after the World Bankrsquos financial support has been expended Most of the activities in the FASDP will have no effect in relation to safeguard objectives and where there are implications these are likely to occur at precise locations (for example at fish landing sites) rather than throughout the industry Where potential interactions have been noted the necessary mitigating measures are incorporated in the Draft Process Framework
Table 41 World Bank Safeguard Policies in Context
Safeguard Policy
Safeguard Policy Objective Brief Description and relevance to FASDP
OP 401 Environmental Assessment
This policy aims to ensure that Bank-financed projects are environmentally sound and sustainable and that the decision-making process is improved through appropriate analysis of actions and mitigation of their likely environmental impacts This policy is triggered if a project is likely to carry potentially adverse environmental risks and impacts on its area of influence OP 401 covers impacts on the natural environment (air water and land)
The majority of actions planned under FASDP will be beneficial to the marine environment and to inland waters However new construction activities could have impacts and depending on the project and the nature of impacts a range of instruments can be used to ameliorate and mitigate adverse effects while enhancing beneficial effects These include EIA environmental audit risk assessment and environmental management plans (EMP) The need for EIA and EMP is considered in this report
26
OP 404 Natural Habitats
This policy recognizes that conservation of natural habitats is essential to safeguard their unique biodiversity and to maintain environmental services and goods for human society and for long-term sustainable development The Bank therefore supports the protection management and restoration of natural habitats in its project financing as well as policy dialogue and economic and sectoral work Natural habitats comprise many types of terrestrial freshwater coastal and marine ecosystems They include areas lightly modified by human activities but retaining their ecological functions and most native species
This policy is triggered by any project (including any sub-project under a sector investment or financial intermediary) with the potential to cause significant conversion (loss) or degradation of natural habitats whether directly (through construction) or indirectly (through human activities induced by the project) This policy is applicable to the Ghana Fisheries Programme because the project focuses on the integrated management of natural habitats However by screening all proposals under the ESMF any sub-projects that might impact these habitats will not be funded
OP 409 Pest Management
The objective of this project is to (i) promote the use of biological or environmental control and reduce reliance on synthetic chemical pesticides and (ii) strengthen the capacity of the countryrsquos regulatory framework and institutions to promote and support safe effective and environmentally sound pest management
The policy is triggered if (i) procurement of pesticides or pesticide application equipment is envisaged either directly through the project or indirectly through on-lending co-financing or government counterpart funding (ii) the project supports an activity requiring the use of pesticides that may have negative effects on the environment The only instance in which this policy might be triggered by the Ghana Fisheries Programme is if aquatic herbicides or antibiotics were to be used in connection with aquaculture This is most unlikely but can be monitored through the implementation programme
OP 411 Physical Cultural Resources
The policy objective is to assist countries in avoiding or mitigating adverse impacts of development projects on physical cultural resources For the purposes of this policy ldquophysical cultural resourcesrdquo are defined as movable or immovable objects sites structures groups of structures natural features and landscapes that have
Under the Ghana Fisheries Programme construction and rehabilitation activities that could have negative impacts on cultural property will be avoided In the case of discovery of remains national procedures will be applied
27
archaeological paleontological historical architectural religious aesthetic or other cultural significance
OP 412 Involuntary Resettlement
The objective of this policy is to (i) avoid or minimize involuntary resettlement where feasible while exploring all viable alternative project designs (ii) to assist displaced persons in raising their former living standards income-earning capacity and production levels or at least in restoring them (iii) encourage community participation in planning and implementing resettlement and (iv) provide assistance to affected people regardless of the legality of land tenure
The policy covers not only physical relocation but any loss of land or other assets resulting in (i) relocation or loss of shelter (ii) loss of assets or access to assets (iii) loss of income sources or means of livelihood whether or not the affected people must move to another location The activities of the Ghana Fisheries Programme are likely to result in loss of assets or access to assets and loss of income sources or means of livelihood for some groups and individuals The potential for such losses will be carefully scrutinised and compensated for through the National Process Framework and Resettlement Policy Framework described in this report and appropriate procedures will be followed where necessary
Other donors and aid agencies including International and National NGOs play an active role within the fisheries sector in Ghana and their safeguards standards will be observed through operation of the Environmental and Social Safeguards Management Plan
28
43 THE GOVERNANCE FRAMEWORK IN GHANA
The Ministry of Food and Agriculture (MOFA) Preparation of Fisheries laws and policies fall under the responsibilities of the Minister of Food and Agriculture who in turn delegates functions including implementation to a semi-autonomous body the Fisheries Commission
The Fisheries Commission (FC) was established under the Fisheries Commission Act (625 2002) It oversees management regulation and utilisation of the fisheries resources of Ghana drawing on powers set out in the Fisheries Law (PNDC 256 1991) Fisheries Act 625 provided for the establishment of a more robust Fisheries Commission (FC) which is an amalgamation of the erstwhile FC and Department of Fisheries
Ten individuals constitute the Board which is led by a chairman (appointed by the President of Ghana in consultation with the Council of State) supported by three members drawn from the ministries of transport defence and environment There are three representatives from the following parastatal organizations - the Ghana Marine Fishing Officers Association Water Research Institute and Ghana Irrigation Development Authority- and two representatives (one from the artisanal and one from the industrial sections )of the National Fisheries Association of Ghana Finally the tenth member is a person with requisite knowledge of the fishing industry or natural resources renewal management
The day to day work of the Fisheries Commission is undertaken by the Department of Fisheries (DOF) which serves as the implementation secretariat of the Fisheries Commission as stipulated by the Fisheries Act 625 of 2002 Specific tasks that are undertaken by the Department of Fisheries include
bull preparing fishery resource management plans bull developing regulations for the fishing industry bull organizing monitoring surveillance and enforcement for the national fishery resources and
ensuring compliance with national fisheries law and institutionalizing co-management concepts
The MCS Division of the DoF (established under the Fisheries Sub sector Capacity Building project) works in conjunction with the Ghana Navy and undertakes sea patrols to exclude industrial fishing vessels from the 30-metre depth IEZ reserved for artisanal fisheries The MCS also conducts inspection of industrial vessels at the fishing ports of Tema and Takoradi for
bull valid fishing licences bull legality of fishing gear bull skipperrsquos certificate bull log book and crew composition
The MCS undertakes similar functions for inland fisheries on Lake Volta
The Ministry of Local Government and Rural Development (MLGRD) is responsible for managing fishers fish processors and fishery resources at district and sub-district levels which it undertakes through the District Assemblies In 2002 the District Assemblies in collaboration with DoF were mandated to facilitate fishery resource management by
bull helping to form and sustain Community Based Fisheries Management Committees (CBFMCs) bull cooperating with the DoF MCS units bull providing legal and financial support to the CBFMCs and bull approving levies proposed by the CBFMCs
29
Community-Based Fisheries Management Committees are charged with the responsibility of enforcing national fisheries laws at community level as well as initiating and enforcing their own by-laws
44 THE LEGAL FRAMEWORK
441 International Conventions
Ghana has ratified a number of international conventions and treaties which have an important bearing on the state of its marine and inland waters and the condition of the fisheries These are listed in Box 1 below
Box 1 International Conventions treaties and agreements to which Ghana is a signatory 1 International Convention for the Prevention of Pollution of the sea by Oil 21 October 1962 2 Convention on the Africa Migratory Locust 25 May 1962 3 Treaty Banning Nuclear Weapon Tests in the Atmosphere in Outer Space and Under Water 5th August 1963 4 International Convention for the Conservation of Atlantic Tunas 4 May 1966 5 Africa Convention on the Conservation of Nature and Natural Resources 15 September 1968 6 International Convention on Civil Liability for Oil Pollution Damage 29 November 1969 7 International Convention Relating to Intervention on the High Seas in Cases of Oil Pollution Causalities 8 Convention on Wetlands of International Importance Especially as Waterfowl Habitats 2 February 1971 9 Treaty and Prohibition of the Emplacement of Nuclear Weapons of Mass Destruction on the Seabed and the Ocean Floor and in the Subsoil Thereof 11 January 1971 10 International Convention on the Establishment of an International Fund for Compensation of Oil Pollution Damage 18th December 1971 11 Convention Concerning the Protection of World Cultural and Natural Heritage 16 November 1972 12 Convention on International Trade on Endangered Species of Wild Fauna and For a 3 March 1973 13 Convention on the Military or Any other Hostile Use of the Environmental Modification Techniques 10 December 1976 14 Convention on the Conservation of Migratory Species of Wild Animals 23 June 1979 15 Convention for the Cooperation in the Protection and Development of the Marine and Coastal Environment of the West and Central African Region1981(Abidjan Convention) 16 United Nation Convention on the Law of the Sea 10 December 1982 17 Montreal Protocol on Substances that Deplete the Ozone Layer 24 July 1989 18 Convention to Combat Drought and Desertification 19 Framework Convention on Climate Change June 1992 20 Convention on Biological Diversity1992 442 Environmental-Related Conventions Environmentally related conventions ratified by Ghana include
bull International Convention for the Prevention of Pollution of the sea by Oil 21 October 1962
bull Convention on the Africa Migratory Locust 25 May 1962 Treaty Banning Nuclear Weapon Tests in the Atmosphere in Outer Space and Under Water 5th August 1963
bull International Convention for the Conservation of Atlantic Tunas 4 May 1966 bull Africa Convention on the Conservation of Nature and Natural Resources 15 September 1968 bull 992256International Convention on Civil Liability for Oil Pollution Damage 29 November
1969 bull International Convention Relating to Intervention on the High Seas in Cases of Oil
30
Pollution Causalities bull Convention on Wetlands of International Importance Especially as Waterfowl Habitats
2 February 1971 bull Treaty and Prohibition of the Emplacement of Nuclear Weapons of Mass Destruction
on the Seabed and the Ocean Floor and in the Subsoil Thereof 11 January 1971 bull International Convention on the Establishment of an International Fund for
Compensation of Oil Pollution Damage 18th December 1971 bull Convention Concerning the Protection of World Cultural and Natural Heritage 16
November 1972 bull Convention on International Trade on Endangered Species of Wild Fauna and For a 3
March 1973 bull Convention on the Military or Any other Hostile Use of the Environmental
Modification Techniques 10 December 1976 bull Convention on the Conservation of Migratory Species of Wild Animals 23 June 1979 bull Convention for the Cooperation in the Protection and Development of the Marine and
Coastal Environment of the West and Central African Region1981(Abidjan Convention)
bull United Nation Convention on the Law of the Sea 10 December 1982 bull Montreal Protocol on Substances that Deplete the Ozone Layer 24 July 1989 bull Convention to Combat Drought and Desertification bull Framework Convention on Climate Change June 1992 bull Convention on Biological Diversity1992
443 National Legislation
The principal national legislation that affects fisheries in Ghana is listed below
1 Fisheries Regulation 1984 LI 1294 2 Fisheries (Amendment) Regulation 1977 3 Maritime Zones (Delimitation) Law 1986 4 PNDC Law 256 of 1991 5 Fisheries Commission Act of 1993 and 6 Fisheries Act 625 of 2002 7 Fisheries Regulations passed in 2010 LI 1968
Other laws that have relevance to the fisheries sector include
1 Wild Animals Preservation Act 1961 (Act 43) 2 Volta River Development Act 1961 (Act 46) 3 Ghana Water and Sewerage Corporation Act 1965 (Act 310) 4 Oil in Navigable Waters Act 1964 (Act 235) 5 Irrigation Development Authority Decree 1977 (SMCD 85) 6 Minerals and Mining Law 1986 (PNDCL 153) 7 Environmental Protection Agency Act 1994 (Act 490) 8 Ghana Highway Authority Act 1997 (Act 540) 9 Timber Resources Management Act 1998 (Act 547) and 10 Minerals and Mining Act 2006 (Act 703
31
434 Policies A number of Environmental related Policies exist in Ghana however there is no specific policy on the coastal zone These include
bull The National Environment Policy bull National Wetlands Policy bull Agricultural Policy bull Tourism Development Policy bull Land Management Policy bull National Health Policy bull Energy Policy bull Minerals Policy bull Wildlife Conservation Policy
The main thrust and orientation of national policies on the protection management and development of the marine and coastal environment focuses on the following three major areas
bull Integrated coastal zone management and sustainable development bull Marine environmental protection both from land-based activities and from sea-based
activities and bull Sustainable use and conservation of marine living resources (both of the high seas and
under national jurisdiction) Specific plans have been developed to ensure the realization of prudent management of the marine and coastal environment These include
bull Coastal Zone Management Indicative Plan 1990 bull National Environmental Action Plan 1994 bull Draft Integrated Coastal Zone Plan 1998 bull Coastal Zone Profile of Ghana 1998 bull National Oil Spill Contingency Plan with specific reference to the marine environment
2002 bull Environmental sensitivity map of the coastal areas of Ghana 1999 and 2004
Despite the existence of these plans active integration and coordination has been lacking in practice at local level 434 Regulations Though several legislations exist on coastal protection and sustainable development there is no omnibus legislation on the environment Legislation relating to the area include the following
bull Beaches Obstruction Ordinance 1897 (Cap 240) bull The Mineral and Mining Law 1986 (PNDC 153) bull Rivers Ordinance 1903 (Cap 226) bull Land Planning and Soil Conservation Ordinance No 32 of 1953 as Amended by the bull Land Planning and Soil Conservation (Amendment) Act 1957 (No 35 of 1957) bull Maritime Zones (Delimitation) Law 1986 (PNDCL 159) urban planning and
32
bull development bull Town and Country Planning Ordinance (Cap 84) bull Wild Animals Preservation Act Act 235 1964 bull The Towns Ordinance (Cap 86) bull National Building Regulations 1996 (LI 1630) bull Volta River Development Act 1961 bull Fisheries Act 2002 Act 625 bull Fisheries Law 1991 (PNDC 256) bull Fisheries (Amended) Regulations 1977 and 1984
The sustainable use and conservation of marine resources is encouraged through legislation regulations education and awareness creation programmes as well as the enforcement of existing regulations and legislation The legal framework for coastal zones issues and management in the country are contained in the following documents
bull The 1992 constitution bull EPA Act 1994 (Act 490) bull Environmental Assessment Regulations 1999 (LI 1652) bull Local Government Act 1993 (Act 462) bull Environmental Standards and Guidelines bull
In addition there are other specific legal frameworks which include a) The legal framework for Ecosystem Protection which are
bull Wild Animals Preservation Act 1961 (Act 43) bull Wildlife Conservation Regulations 1971 (LI685) bull Wild Reserves Regulations 1971 (LI 740) bull The Wetland Management (Ramsar sites) Regulation 1999 bull Oil in Navigable Waters Act 1964 (Act 235)
b) The legal framework for Fisheries Resources which are bull Fisheries Law 1971 (PNDCL 256) bull Fisheries Act 2000
c) The legal framework for Oil and Gas Industry bull Petroleum (Exploration and production) Law 1984 (PNDCL 84) bull Mineral (Offshore) Regulations 1963 (LI 257) bull Mineral (Oil and Gas) Regulations 1963 (LI 256) bull Oil and Mining Regulations 1957 (LI 221)
d) The legal framework for Tourism Promotion (including coastal tourism) bull Ghana investment Promotion Centre Act 1994 (Act 478) bull Companies Code 1963 (Act 179) bull Free Zone Act 1995 (Act 504) bull Ghana Tourism Board bull Ghana Commission on Culture
44 ACTIVITIES RELATING TO FISHERIES INTERESTS
33
Over the years several activities have been undertaken which are of relevance to protection of the marine environment and fisheries These include
bull Ghana Environmental Resource Management Project in Coastal Wetlands Management Component
bull Gulf of Guinea Large Marine Ecosystem Project bull Fisheries Sub-sector Capacity Building Project bull Establishment of a Protected Wetland Ecosystem on the coast bull Development and Implementation of Oil Spill Contingency Plan bull Monitoring of fish stock levels and associated oceanographic parameters bull Institution of a programme of Monitoring Compliance and Surveillance of the marine
environment bull Development of industrial pollution standards bull Development of University course on Coastal Zone Management bull Increased public education on sound coastal and marine environmental practices
45 RELEVANT INSTITUTIONS With regards to protection management and development of the marine and coastal environment a number of ministries and agencies have been identified as potential stakeholders Those shown with an asterisk are likely to have a particularly active role
bull Ministry of Environment and Science bull The Environmental Protection Agency bull Ministry of Tourism bull Ministry of Local Government and Rural Development bull Ministry of Ports bull District Assemblies bull Ghana Ports and Harbours Authority bull Hydrological Services Department bull Ministry of Food and Agriculture bull Ghana Tourist Board bull Ghana Investment Promotion Centre bull Fisheries Commission Ministry of trade Industries and PSI bull Ministry of Lands and Natural Resources Forestry and Mines bull Ministry of Energy bull Ministry of Health bull Ministry of Education Youth and Sports bull Ministry of Defence bull Ghana Navy bull Ministry of Works and Housing bull Ministry of Women and Childrenrsquos Affairs bull Ministry of Roads and Transport bull National Development Planning Commission bull Council for Scientific and Industrial Research bull Universities and Research Institutions bull Ghana Meteorological Agency bull Town and Country Planning Department bull Water Resources Commission
34
bull Ghana National Petroleum Corporation bull Volta River Authority bull Geological Survey Department bull Forestry Commission (Forestry and Wildlife Division) bull Traditional Rulers and their analogous ministry and laws
Non-Governmental Organisations including Resource Development amp Environmental Oriented Development Organisation
bull Friends of the Earth bull Green Earth bull Wildlife Society bull Recerca e Cooperazione bull Centre for African Wetlands bull And many others
46 PARTNERSHIPS Few formal partnerships exist However support for coastal conservation activities has been received from the private sector as well as from Government Regional and sub-regional collaboration efforts occur at various levels although the level of practical intervention is sometimes limited The science and technology unit of ECOWAS is engaged on issues relating to the management of the Gulf of Guinea In addition a bilateral arrangement exists between Ghana and Cote drsquoIvoire for the management of and datasharing on Sardinella stocks which migrate between the two countries The NEPAD framework among the coastal states of Africa is also developing an interest in marine and coastal management 461 Technical and financial support Ghana receives technical support in the form of training research and project implementation from national bilateral and multi-lateral sources Financing of activities in the sector is primarily supported from the national budget However donor support from both bilateral and multilateral sources has also been obtained for specific programmes such as the World Bank sponsored Fisheries Sub-sector Capacity Building Project UNOPS sponsored Environmental Sensitivity Map for Coastal Areas The Ghana Coastal Wetland Project of the World Bank UNEPrsquos WACAF Programmes and The Darwin Marine Biodiversity of West Africa Project by DFID implemented by the University of Ghana 47 ACTIVITIES Activities undertaken in the country with importance to the marine and coastal area are outlined in the following sections 471 Environment-related activities
bull Ecological Baseline studies of Korle Lagoon (1990-2000) This was carried out to satisfy EIA requirement and as a result pollution status of the lagoon was established
bull Lower Volta Mangrove Project (1996-1998) The objective is to ensure sustainable management of mangrove stands and as such baseline information was documented
bull Save the Seashore Birds Project (1985-1995) This was to protect the seashore birds and as a result conservation awareness of seashore birds was achieved
bull Ghana coastal wetlands management project (1996-1999) In this management of the five coastal wetlands designated as Ramsar Site was put in place
bull Darwin Marine Biodiversity of West Africa Project It is a training project in marine biodiversity assessment
35
472 Social-related activities bull A considerable amount of attention is currently being given to the potential impact of oil-related
development in coastal regions following the publication of Environmental and Social Impact Assessments and Management Plans relating to the Jubilee Oil Field discoveries
473 Coastal area management bull Climate and vulnerability and adaptation assessment on water resources agriculture and the
coastal zone Projects (1997-1999) The projects assessed the vulnerability of the coastal zone to climate change
bull Coastal area management plan for Princess Town (1998-2000) which aimed at providing a plan for the management of Princess Town
bull Keta Sea Defence Project Work (2000-2004) The project aimed at protecting the Keta and its environs from the episodes of erosion faced in the area and also to ensure improvement in environmental and socio-economic conditions at Keta and its immediate surroundings
474 Regional Programmes bull Gulf of Guinea Large Marine Ecosystems Project (1996-1999) The project developed an
effective approach to prevent and control pollution in the Gulf of Guinea and conserve its biodiversity As a result regional institutional capacities were strengthened and also a coastal zone management profile and plans produced
bull UNEP WACAF Projects 1 amp 2 This aims at institutionalising and coordination of national contingency plans monitoring of pollution in the marine environment and control of coastal erosion
475 Other major programmes Other recent programmes and activities in the marine and coastal environments have included
bull Ghana Environmental Resources Management Project in Coastal Wetlands bull Fisheries sub-sector Capacity Building Project bull Establishment of a Protected Wetland Ecosystem on the coast bull Development and Implementation of Oil Spill Contingency Plan bull
48 ONGOING PROJECTS Ghana is currently implementing several projects in the marine and coastal area Some of these projects are linked to developmental projects for which impact assessments are required under the Environmental Assessment Regulations of 1999 Some of the projects are large scale in nature with extensive baseline and monitoring studies like the Keta Sea Defence Project and the West Africa Gas Pipeline project Others are projects being implemented under the auspices of the United Nations agencies and non-governmental organisations include
bull Combating Living Resource Depletion and Coastal Area Degradation in the Guinea Current LME through Ecosystem-based Regional Actions
bull Amansuri Conservation and Integrated Development Project (ACID) bull Danida Water and Sanitation Sector Programme II Support to Integrated Water Resources
Management (IWRM) Component (2004-2008)The Densu Basin aspect of the IWRM component
bull Reduction of Environmental Impact from coastal tourism
bull Bui Hydro Power Project
bull Sea Defence Project at Atorkor
bull Sea Defence Projects in selected towns in the Western Region of Ghana
36
49 CONCLUDING REMARKS
This chapter has highlighted the wide range of conventions laws policies regulations and activities affecting the inland and coastal regions and inland freshwater and marine environment of Ghana It will be important to keep all of these processes and procedures under review as the Fisheries and Aquaculture Sector Development Plan is taken forward to the implementation stage
The main responsibility for ensuring delivery of the Fisheries and Aquaculture Sector Development Programme will rest with the Fisheries Department of the Ministry of Food and Agriculture and the Fisheries Commission supported by the MCS Division and Ghana Navy However a key part of the programme is the development of local co-management arrangements and the Ministry of Local Government and Rural Development and individual District Assemblies will play a key role in helping to form and sustain Community Based Fisheries Management Committees
Over time a significant number of fishermen and individual fish processors are likely to leave the sector as harvesting landing and processing of the catch becomes more efficient Management of these changes especially where disadvantaged and vulnerable sections of the community are affected will need substantial support and investment and a high degree of coordination amongst government ministries and agencies NGOs and international partners to ensure that development assistance is effectively targeted
37
CHAPTER 5 WORLD BANK SAFEGUARD ISSUES
51 INTRODUCTION
The World Bankrsquos proposed funding support to the Government of Ghana covers an initial five yearsrsquo period which could potentially be extended at a later date As the Government of the Republic of Ghana notes in the draft FASDP ldquoimproving the management of the countryrsquos fisheries and ensuring that the impacts on individuals and communities are properly addressed will take 20 or more years to effectrdquo It has therefore been judged important in this report to distinguish between changes that might occur as a direct result of the World Bankrsquos financial assistance thereby triggering the Bankrsquos environmental and social safeguards and changes that could result from longer term adjustments to fisheries and other sectors of Ghanarsquos economy as a result of wider influences by Government other donors and world-wide factors (for example international progress in world trade agreements)
The aim in this chapter is to identify changes which are likely to fall within the purview of the World Banks reputational risks and responsibilities under the first five years of the Fisheries and Aquaculture Sector Development Plan (FASDP) It should be clearly understood that the views expressed are those of the consultancy team and it will be for the World Bankrsquos internal advisors to decide what formal recommendations are made to the World Bank Board
Trends that may emerge in later stages of the implementation of FASDP ndash subsequent to the initial five year period - are discussed in chapter 6
52 THE CURRENT SITUATION
The general status of Ghanarsquos fisheries has been described in Chapters 3 while the legal and policy context has been set out in Chapter 4 The World Bankrsquos investment is being planned specifically to support government policy with the aim of providing a more efficient and better regulated fisheries sector Currently open access is leading to progressive deterioration in fish stocks and lower economic returns Based on many international examples of successful intervention the current proposals (see Chapter 2) are to provide support to introduce formal licensing of all vessels and proper monitoring and control over the seasonal timing and location of fishing activity use of gear and approved nets and self regulation through co-management structures under which the Government and fishing communities will work together to achieve recovery of fish stocks higher income levels for fishers and better returns on catches by reducing post harvest losses and improving processing and marketing operations
53 ANTICIPATED OUTCOMES
It is expected that the proposed reforms and changes will eventually lead to significant improvement in the marine environment restoration of fisheries and enhanced incomes In this respect the provision of grants and loans from the World Bank will bring about major benefits to the economy livelihoods and the environment in the longer term The question that has to be addressed however is - are there likely to be any short term adverse environmental or social consequences from the Bankrsquos own investment strategy Answers are considered in relation to each of the planned components sub-components and activities which are summarised in Table 51 A colour coding and numbering system has been adopted to distinguish those activities that are seen as particularly relevant from the standpoint of the environmental and social assessment Elements highlighted in green are those likely to have positive and beneficial effects on the environment and social conditions those highlighted in orange red have potentially negative or adverse consequences if not handled properly
38
Component 1 Good Governance and Sustainable Management of the Fisheries
Sub-Component 11 seeks to develop the capacity rules procedures and practices that will lead to better governance As such these procedural interventions will have no direct effect on the environment or social conditions of fishing communities However it will be important to ensure that the drafting agencies (government departments and consultants) give due attention to environmental and social objectives during this phase of work Three specific areas are highlighted including undertaking a socio-economic impact assessment with mitigation measures as part of the plan for fishing capacity reduction reviewing the economic and social implications of subsidies and fish import tariffs in the fisheries sector and developing the policy for the development and operation of community-based management networks built around defined fisheries management units
In developing regulations and guidelines it will be important to consider how less able individuals and vulnerable sectors are going to adapt to new systems For example the new regulations on licensing canoes including completion of registration forms the display of registration numbers on vessels and demonstration of basic competence in health and safety standards may prove taxing demands for owners and crew lacking any formal education Similarly legal instruments that are used to remove fuel subsidies or other benefits will need to be carefully explained A socio-economic impact assessment is proposed in the draft PAD to be accompanied by appropriate mitigation measures This assessment should consider amongst other things
bull whether support should be offered and if so under what conditions to any company community or individual who fails to secure a license for a particular class of vessel
bull how the transfer or sale of licenses will be regulated in the wider public interest to ensure transparent processes and avoid the creation of monopolistic and oligopolistic elites
bull who wins and who loses from any planned changes to subsidies and fish import tariff adjustments
bull how the performance of community-based management networks will be judged bull what action will be taken to mitigate the loss of any traditional fishing grounds that become the
subject of marine protected area development or are subject to exclusion zones to protect oil drilling and production platforms
Sub-Component 12 introduces the concept of fishing rights This is to be initiated through a series of four pilot stakeholder-based fishery initiatives and the rolling out of licensing procedures Discussions with stakeholders have made it very clear that the credibility of the entire fisheries policy and programme could be challenged if these pilots do not show positive and constructive ways of moving forward with fisheries reform There is a great deal of distrust for new procedures amongst the fishing communities based on the knowledge that many previous initiatives have failed It is therefore essential that the pilots are led by a strong implementation team are adequately financed and include a credible transparent and inclusive process for debate discussion and consultation Co-operation from the selected communities will be more likely to be achieved if they can see early results in terms of income generating activities
Sub-Component 13 is targeted at adjusting fishing effort and capacity to more sustainable levels and supporting alternative livelihood opportunities These activities are critical in giving effect to the policy decisions that have already been taken to reduce the size of the industrial and semi-industrial fishing fleet and to strengthen the role of the canoe sector Specific measures are proposed for compensating crew members who lose their jobs and for providing training to young men who are willing to transfer
39
out of the fishing sector The scale of this task should not be under-estimated however since there are currently few alternative employment opportunities in the coastal belt for manual workers with low education and skill levels which typify the status of many young fishermen The concept of creating some additional employment with conservation of the coastal littoral and marine ecosystems is strongly supported since this can be linked with development of tourism
Sub-Component 14 is another element that is strongly focused on delivering improved livelihoods with its emphasis on social marketing communication and transparency The focus on stakeholder participation is particularly welcome and should lead to positive response providing it is backed with direct financial support to participating communities
Component 2 - Reduction of Illegal Fishing
There is no Sub-Component 21 within the Ghana Fisheries Programme
Sub-Component 22 aims to develop monitoring control and surveillance (MCS) systems These measures are largely procedural and apart from the relatively small team that will be recruited to operationalise the systems it will have minimal effects on either the environment or social conditions One element that is highlighted in Table 51 relates to provision of facilities and training for participatory coastal surveillance of small-scale fisheries This should have direct and strongly positive benefits for participants and the communities who are enrolled in the training programmes
Component 3 increasing the contribution of the marine fish resources to the local economies
Sub-Component 31 will support the development of basic infrastructure at nine marine fish landing sites and two inland sites The scale of physical construction will be restricted to repair and minor extension of roads and jetties wharves and construction of net mending screens and storage sheds These activities are unlikely to have any significant adverse environmental impacts and should lead to positive social effects
Sub-Component 32 will underpin efforts to improve fish product trade infrastructure information and systems Introduction of new technology for smoking and curing fish and the extension of existing ice preparation plants will start to have positive beneficial effects within the selected communities
Sub-Component 33 provides a modest level of support to marine and inland aquaculture development Aquaculture development should include finalization establishment and enforcement of current draft operational standards to cater for environmental friendliness of fish culture industry for its own survival The main focus will be on developing policy and legal frameworks together with support for stock improvement These measures will have some impact on affected communities in the short term but are clearly aimed at longer term benefits
40
Component 4 Coordination Monitoring and Evaluation and Program Management
Sub-Components 41 and 42 are directed specifically at strengthening the capacity of the Governmentrsquos institutions for national implementation and regional co-ordination As such they will have no direct environmental or social impacts
54 SUMMARY AND CONCLUSIONS
This review of potential environmental and social safeguard issues under the World Bankrsquos targeted programme concludes that there are unlikely to be any significant adverse environmental or social effects as a result of the planned investments
The only possible exception relates to the effectiveness of measures that are put in place under Sub-Component 12 to support pilot stakeholder-based fishery initiatives It is of paramount importance that these pilots are successful and win the confidence of all participants since failure to achieve positive results could set back the entire fisheries programme For this reason it is essential that planning of the pilot initiatives is linked closely with measures for supporting alternative livelihoods and strengthening processing and marketing initiatives under Sub-Components 13 and 14
A number of the planned interventions may have longer term consequences as policies regulations and bye-laws are put into effect but these will be addressed in subsequent work by the Government of Ghana (see Chapter 6)
Table 51 Elements of the World Bank Programme and assessment of potential environmental and social risks
Description of Component Sub-Component and Activities
Measure of Likely Effects
Large (3)
Moderate (2)
Small (1)
None
Beneficial
3
2
1
Adverse
3
2
1
Component 1 Good Governance amp Sustainable Management of the Fisheries
Sub-Component 11 Developing the Capacity Rules Procedures amp Practices for Good Governance of the Fisheries
Reviewing developing programmes and projects designed to support the Fisheries and Aquaculture Development Sector Plan (FASDEP)
Developing an operational policy to enable implementation of the Aquaculture and Fisheries
Plan for fishing capacity reduction (including socio-economic impact assessment and mitigation) 3 2
Commercial vessel and fishing activity licensing plan including allocation criteria rules for transfer of licenses
41
Sector Development Plan and timetable and schedule of license fees
Compliance strategy and plan
Regulations for the management of fisheries including the identification and specification of fisheries management units (ie stocks species areas)
Recommendations for environmental and social safeguards arising from the review of the economic and social implications of subsidies and fish import tariffs in the fisheries sector
3
Policy for the development and operation of community-based management networks built around defined fisheries management units
3
Policy on adaptation strategies for climate change and marine protected area development
2 2
Review of the Ghana Tuna Industry to identify policy or infrastructure needs that threaten Ghanarsquos hub status
Strengthening capture fisheries management systems and capability
Development of fisheries and aquaculture management systems and processes and training
Strengthening fisheries information systems
Installation and operation of fisheries lsquodashboardrsquo database and information collection
Sub-Component 12 Introducing Fishing Rights ($15 M GEF)
Developing 4 pilot Stakeholder-Based Fisheries Management initiatives around defined fisheries units (ie local management initiatives tied to defined fisheries resources including demand-side governance initiatives)
3 2
Introducing and administering a licensing regime (registry establishment training stakeholder education) 2 2
Sub-Component 13 Adjusting Fishing Effort and Capacity to more Sustainable Levels and Supporting Alternative Livelihood Opportunities where Needed
Vessel decommissioning Decommissioning of 60 to 80 industrial trawlers in an environmentally friendly manner
2
Developing alternative livelihoods for crew of decommissioned industrialsemi-industrial
Skills training and small business development training and support for young (18-30 yrs) industrialsemi-industrial crew members willing to transition out of the sector
3
42
vessels
Alternative livelihood development to incentivize voluntary capacity reduction in canoe sector
Alternative livelihoods fund and CDD support to targeted fishing communities
3 2
Marine Resource Conservation
Would include confirming conservation priorities and management regimes and possible provision of support for alternative livelihood options (funded under 133) associated with conservation of coastal littoral and marine ecosystems as well as de facto protected areas associated with the development of oil and gas extraction
3
Sub-Component 14 Social Marketing Communication and Transparency)
Communications stakeholder consultations and awareness raising programs to support fisheries development
3
Component 2 Reduction of Illegal Fishing
Sub-Component 21 does not apply to Ghana
Sub-Component 22 Monitoring Control and Surveillance (MCS) Systems
Developing compliance systems and capability
Development of judicial and policy capacity (training)
Compliance risk assessmentstrategy systems and process development
Enforcement Unit establishment (dedicated facility)
Coastal surveillance stations 2
Facilities and training for participatory coastal surveillance of small-scale fisheries
3
Training for surveillance officers
Operation of aerial and water patrols (vessel leases aerial patrols operational costs patrol vehicles)
Observer program
Compliance education (stakeholder training signage) 1
Upgrademaintenance of the Vessel Monitoring System (VMS)
43
Component 3 Increasing the Contribution of the Marine Fish Resources to the Local Economies
Sub-Component 31 Fish Landing Site Clusters
Product diversificationvalue chain development
9 marine landing sites (basic infrastructure) at Axim Dixcove Fete Jamestown Moree Mumford Senya-Beraku Teshi and Winneba
3 1
2 inland fish landing sites (improved access and berthing infrastructure) at Abotoase and Dzemeni
3 1
2 ports developed (technical studies for 1 new port at Axim and additional berthing space in existing port of Elmina)
3 2
Sub-Component 32 Fish Product Trade Infrastructure Information and Systems
Export certification center development
Fish processing technology improvements 1 1
Technical assistance training and goods to support the National Fisheries Advisory Group
Sub-Component 33 Marine and Inland Aquaculture Development
Developing aquaculture policy and legal framework
Improving genetic quality of Tilapia fingerlings and breedstock
Catalyzing aquaculture development 2
Component 4 Coordination Monitoring and Evaluation and Program Management
Sub-Component 41 National Implementation
Technical assistance for Secretariat to the Fisheries Commission to implement the Project
Sub-Component 42 Regional Coordination
Technical assistance for Regional Coordination Unit at the CSRP support to Fisheries Information Systems (lsquoDashboardrsquo)
45
CHAPTER 6 ENVIRONMENTAL AND SOCIAL ASSESSMENT OF DRAFT FISHERIES AND AQUACULTURE SECTOR DEVELOPMENT PLAN (FASDP)
61 INTRODUCTION
This chapter examines environmental and social issues which need to be considered as part of the overall structural and economic adjustments in Ghanarsquos fisheries sector in the longer term (ie 1-15 years) The assessment deliberately focuses on the longer term because it will take a number of years before current plans start to have their full effect However the same temporal considerations apply to measures that are designed to avoid or mitigate potentially harmful effects so it will be important to start planning remedial actions as part of the joint Government of Ghana and World Bank fisheries programme
611 Key sectors and activities The fishing industry is divided first into marine capture and inland capture fisheries and then aquaculture For each of these three sectors activities are then broken down as follows Marine Capture Fisheries CATEGORY ACTIVITY Stock Management Research Surveillance reef building Harvesting Vessels Gear Skills capacity Marketing Sellers Buyers Processing Fresh fish Sun dried Smoking Freezing Consumers By market sector Support Sectors Boat Canoe Building fuel supply net making kiln construction
refrigeration transport cold store management Legal Enforcement Financing Investment in all elements Infrastructure Harbour wharf processing plant construction
Inland Capture Fisheries CATEGORY ACTIVITY Stock Management Research Surveillance Harvesting Vessels Gear Skills capacity Marketing Sellers Buyers Processing Fresh fish Sun dried Smoking Freezing Support Sectors Boat Canoe Building fuel supply net making kiln construction
refrigeration transport cold store management Legal Enforcement Financing Investment in all elements Infrastructure Harbour wharf processing plant construction
46
Aquaculture and Mariculture CATEGORY ACTIVITY Stock Management Research Surveillance Rearing Roe fingerling production cage -pond rearing Harvesting Vessels Gear Skills capacity Marketing Sellers Buyers Processing Fresh fish Sun dried Smoking Freezing Support Sectors Boat Canoe Building fuel supply cage construction kiln construction
refrigeration transport cold store management Legal Enforcement Financing Investment in all elements Infrastructure Harbour wharf processing plant construction
612 Evaluation Criteria The environmental and social assessment has been undertaken using a matrix (See Annex 114) which analyses the key sectors and activities of the fishing industry and the changes that are envisaged against a set of evaluation criteria Evaluation Criteria are broken down into environmental and social issues distinguishing between beneficial and adverse effects Table 61 below shows the relationship between the groups of criteria Table 61 List of Evaluation Criteria
Environment Social
Positive Adverse Positive Adverse
bull Sea bed rejuvenated
bull Fish stocks recovered
bull Biodiversity enhanced
bull Sea bed degraded
bull Fish stocks reduced
bull Biodiversity reduced
bull Increased harvest (catch volume)
bull Increased catch value
bull Reduced costs of inputs
bull Increased profit
bull Enhanced livelihoods
bull Increased job opportunities
bull Increased local economic multiplier
bull Reduced harvest (catch volume)
bull Reduced catch value
bull Increased costs of inputs
bull Reduced profit
bull Reduced livelihoods
bull Reduced job opportunities
bull Reduced local economic multiplier
The assessment process has involved systematically considering each sectoractivity against the evaluation criteria and recording either positive or negative results by drawing on the judgement of the consultancy specialists The findings are discussed in the paragraphs that follow and are reflected in Table 81 forming part of the Draft Environmental and Social Management Plan
62 DETAILED ASSESSMENT OF THE MARINE AND AQUACULTURE SECTORS
47
TunaIndustrial fleet streamlined and catch per vessel improved At present industrial trawlers have to travel increasing distances to fishing grounds and while the level of catch is remaining broadly static costs are increasing against available economic returns A major shortcoming is lack of investment in re-equipping the aging fishing fleet Many of the 90 vessels that make up this sector are increasingly unseaworthy and need to be replaced with modern trawlers and gear The plan is to buy out owners of substandard vessels by offering compensation at market value based on a full commercial survey Vessels remaining in the fleet will be required to meet exacting standards By reducing the number of old and inefficient boats this will allow each of the remaining vessels to catch a higher proportion of fish The aim is to ensure that Ghana is equipped with the latest vessels and technology in order to preserve the countryrsquos position as the hub of the West African tuna fishing and processing industry (see also the section on canneries below) The effect of these measures on the environment will remain broadly neutral since the same number of fish will be caught Providing other policies and increased surveillance are successful in preventing trawling in inland waters the smaller fleet will have to fish in deep oceanic waters This could potentially transfer some environmental effects on fish populations to other parts of the migratory cycle However this would become part of the international effort through fishing quotas to regulate overall catches Reduction in the size of the industrial fleet will mean that fewer men are needed to crew and service the vessels However in practice many men who work in this sector have only part time work and since a significant percentage of boats no longer put to sea the number of crewmen who will be displaced could be in the range of 1000-30003
It will be important to set up support services for those losing their jobs including retraining and welfare assistance where necessary
Decommissioning will necessitate the sale of seaworthy vessels and their removal from Ghanaian waters Other boats will need to be broken up and scrapped This process requires heavy duty specialized equipment and can release significant quantities of waste oil other toxic chemicals including refrigerants and asbestos used in pipe and engine room cladding Measures will need to be taken to ensure that proper environmental and health safety precautions are taken that decommissioning takes place in properly equipped boatyards and that all waste products are disposed of without environmental risk Cannery sector optimized The Fisheries and Aquaculture Sector Development Plan seeks to maintain the port of Tema as the centre of the Tuna canning industry in Ghana At present a proportion of Ghanarsquos tuna catch is diverted to neighbouring countries due to constraints on processing capacity These limitations include poor port infrastructure ageing equipment and delays in handling catch for some operators due to preferential treatment of vessels that are part-owned by the existing canneries Options for improvement include encouraging upgrading of the capacity of one or more existing canneries or promoting more competition in the processing sector and improving the infrastructure Providing modern building designs and construction techniques are employed and a full environmental assessment is undertaken in accordance with Ghanarsquos EIA regulations there should be no significant environmental or social risks associated with these development possibilities The potential economic benefit resulting from encouraging investment in this sector is very high
Industrial fishing excluded from inshore waters A major longer-term intention under the new fisheries plan (FASDP) is to ensure that existing regulations that restrict industrial and semi-industrial vessels from trawling in inshore waters are properly enforced This requires provision of surveillance
3 Based on an average crew of 20
48
equipment fast patrol vessels capacity building and training and increased staffing within Government agencies together with a full programme of awareness raising training and financial support to local bodies providing self-governance under new co-management services Restriction of industrial trawling in coastal waters will greatly ease pressures on fish stocks and reduce environmental damage to the sea bed In time this should lead to healthier fish population with more fish to be caught by the canoe industry as a result However the task of policing and enforcing regulations will not be easy and will take a number of years to bring into full effect Reduction in fishing activity by inshore trawlers will displace a number of crew members and have a short-term impact on dependent families until these individuals are either absorbed into the canoe fleet or find alternative employment There will therefore be a need to assist genuinely deserving cases where crew members (and their families dependents) need to transfer to other sectors of the economy These measures will only be required in the short term since the anticipated improvement in fish stocks will lead to improved economic performance in the canoe sector within which the bulk of employment exists
Expansion of deep water fisheries The fisheries plan notes that there may be a potential for exploitation or increased exploitation of some deep sea fish resources However the status and population dynamics of some affected species is not well known so any such activities should be scientifically monitored through research and enforced by MCS
Tema Secondi Port infrastructure improvements (equipmentbuildings) Under present conditions the transfer of fish from commercial and industrial vessels to canneries is often delayed by the time taken to offload crates and manouvre within the port area where there are conflicting activities There are also difficulties that arise when vessels owned by the canneries are given priority for landing leaving other boats waiting for many hours which can result in quality deterioration At this stage no details are available about the precise improvements that could be introduced and this will need to be investigated as the fisheries plan is advanced Any environmental effects from infrastructure improvements would be contained within the existing port areas and should be largely positive in reducing fuel (energy) costs and increasing overall efficiency It will however be important to carry out an environmental review of specific development proposals at the design stage especially if these involve plans for any dredging or for altering facilities for discharging waste and disposing of bilge water Both of these activities can have damaging effects on the sea bed (The first through dispersal of silt and sediment and the second through release of potential contaminants) Socio-economic effects from the infrastructure improvements should also be beneficial by removing delays increasing efficiency and reducing waste However there could be some slight reduction in manpower requirements leading to the need for skills retraining Regulating the catch (eg Fishing for selected species reducing juvenile catch to improve value of catch in inshore waters) The fundamental aim of the fisheries plan is to reduce the harmful effects on fish stocks and low economic returns from fish catches by phasing out open access for all and introducing regulation of fishing activity This is to be achieved through close cooperation between the Fisheries Commission Monitoring and Surveillance Unit as well as marine fisheries management division and individual fishing communities working together under a co-management framework The practical details will need to be worked out through each individual co-management group and initially the World Bank is offering to assist in the establishment of four pilots These bodies will test exactly what is required to increase fishersrsquo awareness to build capacity in self regulation and agree on appropriate measures
49
From discussion with stakeholders it is clear that while the broad principles are accepted the majority of the fishing community simply do not believe that the new regulations will be enforced because they have witnessed the failure of so many previous efforts to introduce firm management A major issue for the planned programme is therefore how to change this critical mindset without which very little progress is likely to be made in practice It will be necessary to demonstrate through the pilots that by regulating fishing activity direct benefits will accrue to those participating fishing communities Unfortunately efforts to eliminate harmful practices are unlikely to result in an immediate gain in fish stocks Instead catches are likely to fall in the short term It will therefore be essential to introduce other forms of incentive to cushion short term losses Such measures might include the purchase of new nets and gear for sale at subsidized price to local cooperatives the introduction of cash incentives for canoes demonstrating best practice in the use of gear and nets preservation of the catch using ice and landing and marketing fish of the required size and quality As restriction of open access starts to take effect there should be positive environmental gains in terms of improving fish stocks and less damage of the sea bed On the other hand both fishers and fish processors will feel the adverse temporary effect of reduced catches These social and local economic impacts will need to be monitored closely and assistance provided to help foster alternative livelihoods Cephalopus (Octopus) harvesting encouraged in inshore waters Although most fish species are currently exploited to unacceptably high levels within coastal waters there is a specific opportunity to increase the number of octopus caught by pot fishing This fishery could be developed by both the semi-industrial and canoe sectors Taking octopus in pots would have no adverse physical impacts on the sea bed and could allow very slight expansion in fish species that are preyed on by octopus At the same time it is important to note that there is only limited information on species composition and functioning of selected marine habitats including those of the octopus and more research should be undertaken on this and other species that could be selected for expanded fishing activity There would be clear socio-economic benefits arising from the creation of this new fishery Focusing fish landing at specific landing sites (to improve opportunities for subsequent marketing processing) Plans are already being developed for the enhancement of landing and processing facilities at a number of existing locations along the coast These locations include the construction of harbours at Jamestown and Elmina and development of landing sites at Teshie Ada Axim Dixcove Winneba Mumford SenyaBeraku Gomoa Fetteh Moree Keta Dzemeni and Tapa Abotoase Two sets of issues need to be considered in relation to these improvements all of which affect existing fish landing and processing sites The first is the nature of the physical works and infrastructure and it s potential effect on the marine and terrestrial environment The second is the socio-economic impact Both Elmina and Jamestown are long established fishing ports where the catch is landed either directly onto the beach or shallow wharves It is understood that the primary aim of the improvements will be to increase the area of permanent wharves to make it easier for fish to be offloaded to reduce the time taken in transferring stock to processing plants and to introduce modern technology In the case of other smaller landing sites the scale of improvements will be quite modest involving improvement to existing short stretches of access road the erection of stores for nets and other gear and provision of covered areas to provide shade for net-mending With all proposals for physical infrastructure development there will be a need to consider possible
50
environmental implications Due to the existing nature of these sites there are no major industrial or other commercial processes in the vicinity which could give rise to cumulative impacts including contamination of fish products The scale of plant needed for ice-making and storage and commercial smokeries is commensurate with the artisanal nature of the fishing activity itself and would not give rise to any significant environmental effects on air or water quality Harbour works could potentially involve some small scale dredging (for example the removal of accumulated silt) Where dredging is required it will be important to identify disposal areas (either at sea or on land) where silt can be deposited without damage to sensitive habitats In terms of economic and social impacts it is not clear at this stage who are likely to be the major investors from the private sector although it may be assumed that existing operators who have access to finance will be the main beneficiaries Over time as landing marketing and processing become more efficient it is possible that individuals in the traditional fish smoking sector will lose a significant proportion of their trade as the product switches to fresh or frozen fish sales for transfer to the major urban markets and the beach price for fish rises The draft Ghana fisheries and aquaculture sector development Plan notes in annex 2 that proposed facilities associated with the ports and landing sites may not have support from fish mammies or at least formidable commercial advocates able to resist any opposition from that quarter Inspection of major fish landing areas like Elmina and Sekondi indicates that the existing social and commercial structure of support activities to fish harvesting is very complex and involves almost every member of the community including children and the elderly Such activities include net mending boatbuilding metalworking (for cooking pots stoves and grills supplies (ropes weights tar paint wood) fuel supplies ice crates transport etc Leaders of the fishing community confirmed that in principle the improvements of facilities is welcomed provided that safeguards are in place for those who may lose part or all of their current trading activity through rationalisation Stabilise fleet capacity at a sustainable level Fishery experts consider that there would be significant benefits in reducing the number of canoes from the present 10000-12000 to around 8000-9000 which correlates with the number operating in the mid 1990rsquos when catches were at optimum levels At the same time the Fisheries and Aquaculture Plan stresses that the canoe sector will remain at the heart of the Ghana fishing industry and this has strong political enforcement Consequently there is unlikely to be any enforced reduction in the number of canoes holding licenses and owners of all existing canoes will be able to register their vessels The ability of canoe owners to pay annual licence fees should rise as the overall measures to increase efficiency and improve catches take effect However many people anticipate that over time as the annual cost of holding licenses rises less efficient fishers will sell their licenses (and hence their rights to fish) There may therefore be a de facto reduction in the size of the canoe fleet Even if numbers do not decrease the fleet could be stabilized at its present size by taking a decision not to grant new licences The draft plan discusses the fact that under existing law (section 53) there is a requirement for licenses to be issued on demand (presumably to ensure that Ghanaians are not barred from subsistence fishing) It is argued in the plan that this is a misconception since canoe fishing is largely a commercial activity and it is concluded that lsquoit is therefore essential that the number of canoe licenses can be controlled in future and the legal basis for these controls must be reviewed as a matter of priorityrsquo Decisions of this nature will require the full support of local co-management groups if they are to be effective but committees could easily come under pressure to make exceptions as the coastal population continues to rise and families without alternative livelihoods start lobbying for assistance
51
Accusations of preferential treatment of certain individuals by committees (or committee officials) - possibly linked with suggestions of bribery and corruption -could cause a lot of social tension and start to undermine community trust in the need to work together to improve fisheries management It is therefore most important that the detailed proposals for co-management address this risk and include proposals for mitigating individual hardship of the less advantaged ndash for example by offering voluntary retirement with some form of incentive Influencing marketing to maximise value and reduce post harvest losses (marketing cooperatives strong market structures etc) FAO has estimated that physical post harvest losses in Ghana amount to between 3 and 17 of smoked fish production and 16-20 of gillnet landings The plan notes that introduction of lsquonew generationrsquo small scale fish smokers should be introduced to replace the traditional Chorkor model This would improve fish product quality by eliminating charring of fish over open flames and also protecting operatorsrsquo eyes from the damaging effect of smoke and particles The other major improvement in post harvest value and profits would arise from greater use of ice throughout the supply chain Developing Aquaculture A distinction needs to be made between aquaculture development in ponds and dugouts which are self-contained and fish rearing in cages within open water In the case of farm ponds the commercial rearing of fish is little different to other forms of intensive livestock rearing Providing there is no direct connection to rivers and streams there is little likelihood of interaction between farmed and wild stocks which could spread fish infections and parasites In the case of fish farms in open water (rivers and lakes) there are well known risks of the spread of disease which can arise if overstocking occurs Intensive feeding of large numbers of fish in a confined area can lead to significant deterioration in water quality through the build up of nutrients from wood and waste It is also possible for antibiotics and growth hormones to be dispersed beyond the area of farm cages Genetic modification of farmed fish can also affect the local fish population through escapes All of these issues are capable of being managed and mitigated through good initial planning and design and subsequent maintenance and supervision It will therefore be necessary to develop additional regulations and guidelines specifically for the aquaculture sector 63 SUMMARY OF ENVIRONMENTAL RISKS AND OPPORTUNITIES Review of the full range of governance and development activities suggests that there are no high levels of risk to the marine or littoral environment Successful implementation of the Policy and plan should in fact result in very significant environmental gains Over a timespan of 5-20 years five activities in particular should result in significant improvements in the condition of the sea bed in coastal waters (to a depth of 30 metres) reestablishment of benthic flora and niche habitats increased fish stock and enriched biodiversity These interlinked activities are bull The exclusion of industrial vessels and trawling within coastal waters bull Regulation of fish catches through zonation seasonal control of fishing and standards for vessels
gear bull Stabilisation of the fishing fleet within sustainable harvesting yields bull The adoption of management plans formulated and agreed with full cooperation of local
communities bull The introduction of fishing rights through co-management agreements and bull Well planned consultation and information dissemination throughout the fisheries sector
52
Three components of the development plan have been identified where minor to moderate risk to the physical and biological environment could arise if proper design and implementation standards are not adhered to These relate to bull A potential risk of over-exploitation of new catch species in deep water off the continental shelf if
such development is not accompanied by through research to establish the sustainable yield of target species
bull Strictly localized effects on the physical environment from construction of landing wharves or jetties and other harbour facilities and
bull Infrastructure development at the existing ports of Tema and Takoradi All of these risks are capable of being fully managed by improved governance in the fishing sector and EIA procedures that are well-established in Ghana 64 SUMMARY OF SOCIO-ECONOMIC RISKS AND OPPORTUNITIES Implementation of the Plan Project will bring about substantial change in the fisheries sector and over time increased revenue reduction of post[harvest losses and added value to fish products will bring major economic returns At the same time there will be some individuals who do not participate in direct gains and whose livelihoods could be adversely affected if appropriate safeguarding measures are not put in place The level and extent of these socio-economic risks will be determined by 1 the level of commitment that is entered into by Government and its development partners to
deliver incentives to vulnerable and disadvantaged groups and 2 the speed with which the sector is transformed Rapid change could cause significant
displacement of less-efficient operators especially within the semi-industrial and canoe sector which would have serious ramifications for dependent communities However these effects can be marginalized if the development programme is carefully phased to ensure that alternative livelihood and employment incentives are available
The main risks to local livelihoods relate to the potential for bull loss of employment for crews of unseaworthy obsolete vessels ( from all sectors including
industrial semi-industrial and canoes) that are withdrawn from the fishing fleet because they no longer comply with license regulations
bull the inability of vulnerable and disadvantaged groups including artisanal fishers vendors and individual fish processors in small fishing villages to adjust to new market conditions at selected landing sites
53
CHAPTER 7 ASSESSMENT OF POLICY OPTIONS
71 INTRODUCTION
In order to place the significance of the environmental and social safeguards assessment in context this chapter examines the possible consequences of different policy responses to the existing challenges that face the fisheries sector in Ghana These different policy responses range from a continuation of the status ndashquo effectively a ldquodo-nothingrdquo option (A) to full-scale commitment by all stakeholders to achieving a sustainable fisheries future the ldquoOptimum Solutionrdquo option (C) Various less sustainable outcomes lie in between these two ends of a continuum of policy choices and these are represented by the ldquoWeak Solutionrdquo option (B) 72 OPTION A ndash DO NOTHING Background research and discussion with stakeholders indicates that practical capacity to deliver on clearly stated national goals for sustainable fisheries livelihoods and the reduction of poverty is weak This situation exists despite the fact that Ghana has a strong legal framework for management of its fisheries including the Law Policies and Regulations There is inertia and strong resistance on the part of the majority of players to accept that it is largely their own actions which are responsible for present conditions This in turn leads to the attitude that it is only the lsquoGovernmentrsquo that must act by providing increased subsidies and cushioning the industry against further deterioration in catches Unfortunately there is overwhelming evidence from around the world that where fish stocks are exploited beyond their natural capacity to regenerate this can lead to sudden and near-total collapse Ghana has historically been one of the strongest fisheries in West Africa but the signs are ominous that current levels of exploitation are leading to progressive decreases in annual catches for most species in both marine and inland waters As fishing effort intensifies with an increasing number of all types of vessel using illegal methods and inappropriate gear the distinction between the traditional lsquopeak season and lean season (linked to migration patterns breeding cycles and upwelling) is becoming blurred This is clearly illustrated by a statement from one of Elminarsquos fish mammies ldquowe use to smoke the herring in the peak but now the fishers bring them all the yearrdquo Use of monofilament nets light dynamite and chemicals to obtain fish in the lean season is aggravating a situation where too many boats are chasing too few fish Many fishers blame the reduction of catch on global warming for increasing water temperature the emergent oil and gas industry for restricting access to traditional fishing grounds and industry and urban development for increasing pollution leading to deterioration in water quality Each of these assertions warrants careful consideration but the industry is generally in denial when it comes to the primary fact ndash too many fish including juveniles are caught to allow regeneration of the stock In addition weak governance and lack of resources to ensure implementation of policy result in a situation where the law can be ignored with impunity If collective failure to recognize the seriousness of the current position and lack of commitment to taking hard decisions continues the omens for the future are not good Within a period of 10-15 years fish catches could fall by 50 or more from their present level Impacts on each species would vary and catches of some fish with regional or global migration patterns could remain viable (although this depends on the international conservation effort) On the other hand stocks of fish that provide the mainstay of local food resources herring and sardine could be decimated
54
Complete collapse of all fish species is unlikely but it is possible to envisage a situation where catches might fall below 300000 tonnes a year by 2025 (a reduction of more than 25 from present levels) The most serious consequences would be felt as a result of the social and local economic impact on fishing communities Perhaps 30000 men representing the crews of 3000 canoes and semi industrial boats and 15000 women engaged in marketing and processing would lose their present livelihoods Population migration away from the coast could follow and severe social pressures and local economic hardship This is clearly a ldquoworst caserdquo scenario and if conditions were to worsen gradually it might be possible to intervene but the fact has to be accepted that fish stocks are dynamic and subject to rapid decline (as in the case of the North Sea Herring and Atlantic Cod) 73 OPTION B THE lsquoWEAKrsquo SOLUTION The bleak future painted in Option A is unlikely to arise if the present policy and draft fisheries development plan is followed since these are specifically directed to addressing the major challenges However realization of the aims is dependent upon delivery across a wide range of initiatives by multiple stakeholders The following paragraphs illustrate some of the ways in which delivery of policy objectives might be thwarted These may be summarized as
bull Commitment to good governance and institutional reform bull Political resolve to implement unpopular measures bull Availability of adequate technical and financial resources bull Inertia to necessary changes in fishing practice
Good Governance and Institutional Reform Fundamental reforms are required to fully equip the national fisheries management effort at government level This includes introduction of change management clarification of responsibilities for senior staff rationalization of financial management systems provision of equipment expansion of staff numbers additional training and capacity building As an illustration of the extent of the effort required reference can be made to just one topic area the issue of monitoring control and surveillance At present the Fisheries Commissionrsquos MCS Unit has only 10 employees to oversee implementation of the fisheries regulations throughout Ghana This number will be increased as other institutions are engaged in joint monitoring initiatives but it is obvious that staff numbers and capacity will need to be expanded if regulations on fishing activities are to be affected Enforcement is only one part of the equation however Much greater emphasis will need to be placed on voluntary controls and self-policing at community level through Co-management schemes
Failure to press ahead with governance and institutional reform could delay the process of introducing and registering licenses which represents a crucial first step in moving from open access to managed access in the fisheries sector Given the urgency for action the five years allowed in the current plan for completing the registration process seems very generous Political resolve to implement unpopular measures Stakeholder meetings have confirmed the significance of party political influence as a constraint on achieving progress in the reform of the fisheries sector The offer of incentives like subsidies or the promise of new facilities and equipment are regularly employed by individual politicians to garner votes whether or not these form part of party manifestos Examples have been quoted to the consultants where enabling regulations that might restrict fishing access and prove unpopular amongst the fishing community are quietly ignored and officers may be discouraged from pursuing breaches of the law where the offender has political influence These issues arise with governments of all political
55
persuasions and can apply at all levels from District Assemblies through to regional and national committees
A serious issue with fisheries sector reform is that once actions have been taken to conserve fish stocks it may be years before the full benefits are felt and the results are evident in terms of increased catches This makes it harder for governments to institute unpopular reforms ndash even though these are in the best interests of the nation fishing communities and individuals Fishermen and their families are used to seeing an instant lsquosame day returnrsquo on their catch and are less willing or able than stakeholders in other economic sectors to wait for gradual improvements There is an urgent need to establish cross-party support for the fisheries sector in Ghana and to seek agreements between the main political parties to support established policy and regulations where these are in the interests of delivering sustainable fish stocks Availability of Technical and Financial Resources The process of moving from complete open access to restricted use rights for both marine and inland capture fisheries will take many years to complete Progress will be heavily influenced by the level of political will availability of technical assistance and financial support Existing subsidies (pre-mix fuel and import tariffs) are seen as a deterrent to the encouragement of more efficient business practices However in order to reduce dependencies on these forms of government aid there is also a need to underwrite new forms of economic enterprise by giving help to start-up businesses developing training centres and promoting alternative livelihoods for those individuals who are either displaced or voluntarily give up work in the fisheries sector Inertia to Change Traditional fishing practices are quite literally a way of life for many Ghanaians and have been handed down from generation to generation These traditions are closely interlinked with cultural practices and power and influence resides in specific families with hereditary authority In order to change attitudes and gain acceptance of new approaches to fishing there is a need for a major awareness building and communications strategy targeting in particular the traditional leaders of the fishing industry Without such a plan it will be difficult to break down the internal resistance and inertia towards change The constraints that have been outlined above in relation to the lsquoweakrsquo option are very real and in combination they present a serious barrier to progress It will require real political commitment on the part of Government and strong financial support from international partners to break down these barriers 74 OPTION C THE lsquoOPTIMUMrsquo SOLUTION
The new Draft Fisheries and Aquaculture Plan together with the Act and Policies provide a solid foundation for revitalising the fisheries sector in Ghana However for the reasons discussed in relation to options A and B above there are a number of impediments that need to be overcome In addition to the measures in Option B an ldquoOptimumrdquo solution would also include
A coherent mix of Incentives (carrots) and Regulation (sticks) A top priority in developing existing strategies and plans will be to ensure that measures are in place to offer encouragement and practical assistance to fishers to convert to more sustainable practices while at the same time introducing effective enforcement There are some real challenges with both of these goals
56
New forms of incentive need to be developed to convince boat owners and their crews that it is worth their while to drop illegal methods (dynamiting use of monofilament nets etc) and to reduce the level of fishing effort (through close seasons introduction of restricted zones etc) Without these incentives it is highly unlikely that there will be significant take-up of the fisheries stock management and conservation message Special attention needs to be given to the role of chief fishermen and local community councils in developing effective local policing since it is impractical to rely on a national MCS team to regulate canoe activity in either the marine or inland capture fisheries The national MCS team will have its own responsibilities for policing local and international waters in relation to industrial and semi-industrial sized vessels Integrated Coastal Development The long term success of the fisheries strategy depends upon reducing fishing effort to a level at which catches become both sustainable and profitable for those who remain in the business This in turn requires that those displaced from the industry are able to find gainful employment and livelihoods in other sectors of the economy The fisheries industry is often seen as a separate economic sector which attracts its own funding and support but in order for the necessary reforms to take place these attitudes will need to change A new approach is required to lsquointegrated coastal developmentrsquo following the lessons from integrated rural development Many fishing inland and marine fishing communities are almost wholly dependent on fishing with less than 10 of the local economy being devoted to other industries Reform of the fishing sector therefore requires that as much ndash if not more ndash effort is devoted by government and its international partners to building up complementary economic activities in construction transportation manufacturing food processing environmental conservation and tourism There is a need to explore new state industry partnerships to establish appropriate economic development agencies and to coordinate activities between relevant state institutions ministries and departments under the current decentralisation initiatives with district assemblies taking a prominent role If initiatives of this sort are taken forward it will make the task much easier in persuading conservatively ndashminded fishing communities that they need to simultaneously develop their own entrepreneurial flair and impose their own discipline
57
Chapter 8 DRAFT ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK (ESMF) 81 INTRODUCTION Previous chapters of this report have described the principal environmental and social impacts that are likely to arise from reform in the fisheries sector This chapter sets out the Framework (ESMF) for an Environmental and Social Management Plan (ESMP)The first step has been to outline specific objectives to be achieved through implementation of the ESMF These objectives relate specifically to the issues described in earlier chapters Subsequent sections of the chapter detail the measures which are required to respond to specific areas of environmental and social impact through mitigation and amelioration works They also describe the types and level of environmental monitoring required together with the institutional aspects which need to be improved in order to support the fisheries sector 82 STRATEGY AND OBJECTIVES The basic aim of the environmental and social management plan is to set out guidelines for participatory programs under which members of local fishing communities and civil society in general can become involved in the design and implementation of local fishery co-management maintaining sustainable local livelihoods and achieving local monitoring of fishery efforts The basic principle for future fisheries management is that both marine and inland waters will be demarcated as territories for use rights to fisheries (TURFs) The principal goal of government policy in the fisheries sector is to ensure that the fisheries industry plays an increasingly important role in supporting the growth of the economy as outlined in the Ghana poverty reduction strategy (GPRS II) and the Republic of Ghana fisheries and aquaculture policy This goal will be supported by implementation of the fisheries and aquaculture sector development plan over the next five years In this timescale the aim will be to bull improve management of fisheries the conservation of aquatic resources and protection of the
natural environment bull promote value addition in the fisheries sector and the improvement of livelihoods in fisheries
communities bull encourage sustainable development of aquaculture bull improve the services provided to the fisheries sector by the fisheries commission and supporting
institutions The overall consequences of this strategy and the investments that are being made by the government and its aid partners will be stabilisation of fish stocks and sustainable catch levels a strengthening of the national economy and creation of a more robust fisheries industry with consequent benefits for fishing communities Impact assessment confirms that the result will be significant benefits for the marine environment and local economy However depending on the rate of transition from an open access to a fully regulated market a number of adverse effects could arise unless appropriate mitigation measures are put in place Specific issues which require attention in this plan are listed below bull potential risks of environmental degradation through development of new fishing targets in
deep water
58
bull localised environmental impacts at construction sites bull loss of resources for individual operators due to restricted or controlled access to fishing
grounds bull displacement of labour from crews of vessels that are withdrawn from the industrial and semi-
industrial fleet bull Decommissioning of obsolete industrial vessels may not necessarily lead to recovery of fish
stocks Catch Per Unit Effort (CPUE) may increase This could lead to loss of livelihoods to crew members and the owners of the decommissioned vessels it could increase catch for the few vessels remaining in the system
bull increase production costs due to idling time in closed seasons for fishing bull exclusion of some groups and individuals seeking entrance to the industry following completion
of licensing bull concentration of processing and marketing at selected landing sites leaving Fish Mammies and
their dependents in other smaller fishing communities at an economic disadvantage bull displacement of traditional canoe building and other ancillary support industries by more
efficient and modern methods of construction and the inability of some workers in these trades to train and re-skill in the use of modern materials
bull lack of employment opportunities in alternative sectors The ESMF will set out specific actions to address these concerns through a coordinated set of interlinked proposals as follows 1) Preparation of local management plans and close surveillance of all new fishing enterprises in
deep waters
2) Preparation of environmental protection clauses to be included in all contracts and agreements for physical development work
3) Regular inspection by environmental protection officers of construction work at harbours and landing sites
4) Establishment of community management plans to provide support to those groups and individuals who are adversely affected by any of the measures listed above
5) Creation of community liaison groups to actively support community development alternative livelihoods and conversion to new areas of economic activity for those Fisher families or individual fishers who are adversely impacted
6) Introduction of skills training centres and business advice for small and medium enterprise development
7) Establishment of a coastal development agency drawing on the resources of the ministry of local government agriculture and tourism (others to be added) to coordinate integrated projects and initiatives for economic development linked with the existing coastal zone management plans
8) Creation of a liaison group between the government of Ghana and its international development partners to ensure that investment in the fisheries sector is targeted in the most effective way to deliver plan objectives and avoid duplication of effort
59
83 COMPONENTS OF THE ESMF The following paragraphs provide a summary of the draft ESMF 831 Local Management Plans these plans will be prepared for discrete zones of influence around specified fishing settlements Each plan will contain the same standard list of relevant activities that are to be monitored 832 Environmental Protection In relation to construction activity a checklist will be prepared identifying precisely what level of environmental scrutiny is required for specific types of development This checklist will be prepared by the Fisheries Commission with the support and advice of the Environmental Protection Agency 833 Small-Scale Project Development and Livelihood Restoration a list of potential micro-projects will be prepared by the Fisheries Commission which are regarded as suitable for support funding Demand for these micro-projects will be determined at the local level (ie in villages and fishing communities) Applications for funding of micro-projects will be submitted to the community liaison group for vetting and recommendation based on pre-established eligibility criteria Recommended projects will be referred for formal approval at national level (or through the Coastal Development Agency) 84 POTENTIAL PROJECT IMPACTS ON ASSETS AND LIVELIHOODS The project will have some adverse impacts on assets and livelihoods Therefore provisions will be made under the ESMF to minimize all such impacts including those of socio- economic significance and on any environmentally sensitive sites Provisions are also made in the RPF to accommodate all potential situations including cases that may entail actual displacement and livelihood restoration assistance in accordance with the Governmentrsquos policy and World Bank Policy on Involuntary Resettlement OP412 (see Chapters 9 and 10) The potential social and environmental impacts associated with the project (see Chapters 5 and 6) are summarised in Table 81 and the approach to related mitigation measures is defined in section 85 and Table 82 below
Table 81 Potential Environmental impacts and Social issues
Type of Activity Description Environmental Significance
Social Significance
Decommissioning of obsolete industrial vessels
Scrapping of vessels may release toxic waste (contaminated oils asbestos pipe wrapping and insulation etc)
Contamination of landfill dumps
Related health hazards
Laying off of work force Recovery of fish stocks in areas currently over-fished by trawling
Decommissioning of excessovercapacity would result in loss of livelihoods for crew members
60
Plan for fishing capacity reduction
introduction of licensing system for canoes and enforcement of licensing system for semi industrial vessels
Reduced catch from the decline in the use of prohibited fishing methods (activities) as stipulated in the Fisheries Regulation 2010 (LI1968) eg use of light dynamite etc
Reduction in fishing capacity should lead to significant recovery of fish stocks with long term benefits for all
Short term reduction in fishing effort and increased regulation may prejudice vulnerable sectors (illiterate elderly fishers) Capping on new entrants may remove the safety net opportunity offered by fisheries to would-be fishers who may be without alternative livelihoods
Harbour development and landing site improvements
Construction of access road improvements Erection of fish processing and ice making plant The Project could give rise to a small level of physical displacement for some sectors of individual communities
Removal of shelters homes Displacement of boat repair and trading sites for local community
Possible non-voluntary resettlement including vulnerable groups (women children and the elderly)
Adaptation Strategies to climate change
Introduction over time of regulations relating to fishing activity in rivers lakes estuaries lagoons and lsquoareas of upwelling affected by climate change
Measures to combat tackle rising temperature and other climate induced changes should ameliorate environmental impacts
Both beneficial and adverse effects may result from changes in climate (eg faster growth rates from higher water temperature spread of invasive species)
Establishment of exclusion zones ndash oil production and marine protection areas
Restrictions on fishing in oil production areas and marine protection areas
Positive ndash recovery of fish stocks but also potential risks of pollution from oil leaks and human waste
Temporary loss of livelihood for those fishers displaced from lsquotraditionalrsquo fishing grounds
Development of Co-Management System
Creation of 4 pilot Stakeholder ndashbased Fisheries Management Initiatives
Demonstration of practical benefits for the marine environment resulting from elimination of damaging practices
Greater social cohesion and sense of purpose established
61
Type of Activity Description Environmental Significance
Social Significance
Support for PAPs Establishment of enterprise training programmes
Development of criteria for defining Project Affected Persons (PAP) Development of skills training schemes enterprise allowances alternative livelihoods fund
Major benefits for PAPs ndash but scope for misinterpretation mismanagement of programme at local level Jobs created under social significance should be familiar to the fishers ie things they will be willing to do
Developing Compliance Systems
Establishment of enforcement unit and development of facilities and training for participatory coastal surveillance of small-scale fisheries
This component will greatly improve controls over environmentally unfriendly damaging activities
A number of new jobs should be created under this programme
Improvements in fish processing technology
Development of more efficient fish processing plant
This measure should reduce significantly the proportion of fish lost or degraded post harvest Improved fish processing technology will also reduce wood used from the forest as firewood for fish smoking
Potential displacement of vulnerable groups (women children and the elderly)who currently participate in fish drying curing using basic equipment
Construction of fish ponds
Expanding areas of dug-outs and other farm ponds
Small scale impacts on vegetation stream flow
Displacement of existing land users
Catalysing aquaculture development
Encouragement of larger fish farming enterprises Installation of fish cage aquaculture
Localised deterioration in water quality increased nutrients leading to eutrophication potential spread of fish parasites disease
Potential competition with free capture fisheries displacing vulnerable groups in existing fishing villages
62
85 PROPOSED MITIGATION MEASURES AND COST ESTIMATES Mitigation measures The potential environmental and social impacts to be addressed within the context of preparing this Environmental and Social Management Framework are generalized as shown in Table 82 below It is not possible at this time to prepare specific mitigation measures It is expected though that environmental and social assessment studies will be carried out within specific localities as and when required The framework for compensationresettlement (See Chapters 9 and 10) will then be applied incorporating (1) specific institutional arrangements (2) resettlementcompensation eligibility criteria (3) implementation procedures (4) financial responsibilities and (5) monitoring and evaluation plan Livelihood restoration measures Furthermore the livelihood restoration measures will consider issues such as
(1) income levels of affected persons
(2) other non-monetary sources of livelihood
(3) constraints and opportunities for income generation
(4) number of persons not able to revert to previous occupation and
(5) existing skills of affected persons
Table 82 Proposed mitigation measures for some potential impacts
Type of Impact Description of mitigation measures
1 Decommissioning of obsolete industrial vessels
a) A register will be prepared of all industrial vessels that are due to be decommissioned recording the owner and location of each vessel b) A system will be introduced for tracking progress on decommissioning including the means of disposal and measures taken to dispose of all potentially toxic or hazardous materials c) Persons who lose their job or livelihood as a result of a decision to decommission any particular vessel will be entitled to benefit from the skills training schemes enterprise allowances alternative livelihoods fund being developed
2 Plan for fishing capacity reduction
a) A full Social and Environmental Impact Assessment will be carried out on the Plan for fishing capacity reduction and appropriate measures for ameliorating and mitigating adverse effects on affected sectors of the community and PAPs will be incorporated in a revised edition of this Fisheries Environmental and Social Management Framework
63
3 Harbour development and landing site improvements
a) All harbour development proposals will be subject to Environmental and Social Impact Assessment (ESSA) in accordance with EPA Regulations b) Proposals for improvement of individual landing sites will be assessed in accordance with the checklist (832) and submitted to EPA for a ruling on the level of environmental assessment that is required which will depend on the nature of the intended works
4 Adaptation Strategies to climate change
a) An adaptation Strategy shall include proposals for mitigating any impacts on the environment or social welfare of local communities
b) Any strategy for responding to potential effects of climate change on the fisheries sector will be submitted to EPA for review to determine whether an SEA or EIA is required
5 Establishment of exclusion zones ndash oil production and marine protection areas
a) Proposals for restricting access of fishing vessels to oil production areas and marine production areas shall be subject to an Environmental and Social Assessment which shall be submitted for approval to EPA b) In the event that restrictions are likely to adversely affect fishersrsquo livelihoods the provisions set out in 7 below will apply
6 Development of Co-Management System
a) Development of co-management systems will require full cooperation and engagement of all stakeholders In the unlikely event that the provisions of any scheme are challenged by local communities there shall be a right of appeal to the Minister of Food and Agriculture and the Fisheries Commission acting jointly
7 Support for PAPs
Establishment of enterprise training programmes
a) Identification of vulnerable people including women children and the elderly and identification of the cause and impacts of their vulnerability shall be established through direct interviews and procedures to be developed as part of 6 above b) A high priority within the Fisheries and Aquaculture Sector Development Plansrsquo first five year programme will be the development of specific proposals for the establishment of skills training programmes and the establishment of enterprise allowances and an alternative livelihoods fund c) The measures outlined in 7b) above will be targeted specifically at PAPs and vulnerable sectors of the community
8 Developing Compliance Systems
a) All proposals for securing compliance with fisheries regulations shall be subject to review by a fisheries stakeholder committee to be established by the Fisheries Commission with the remit of ensuring that the measures themselves and penalties for failure to comply are commensurate with the ability of offenders to make restitution and do not unfairly penalize vulnerable sectors of the community
9 Improvements in fish processing technology
a) All plans and proposals for the introduction of new fish processing technology shall be published and shall include a statement on the likely impact of the project on existing processors within the local community
64
b) Any members of the public who consider they are unfairly disadvantaged by proposals for the introduction of new technology may apply to the local co-management committee to determine whether or not they fall within the category of PAP (see 6 and 7 above)
10 Construction of fish ponds Proposals for the construction of new fish ponds shall be assessed in accordance with the checklist (see section 832)
11 Catalysing aquaculture development
a) All proposals for aquaculture development shall be in accordance with the provisions laid down in Local Management Plans applying to specific TURFs
65
5
PART A ENVIRONMENTAL AND SOCIAL SAFEGUARDS ASSESSMENT
The Environmental and Social Safeguard Assessment comprises bull Three background chapters (1-3) bull Two chapters which deal with assessment of the potential effects of the World Bankrsquos financial
and technical support for the Ghana Fisheries Programme over the initial five years (Chapter 4) and the longer term effects of the overall Fisheries Programme which is expected to run for 10-15 years (Chapter 5)
bull Analysis of the consequences of taking no action (the do-nothing option) in Chapter 7 and bull A draft Environmental and Social Management Framework (Chapter 8)
7
CHAPTER 1 INTRODUCTION
11 INTRODUCTION The government of Ghana is embarking on a Fisheries and Aquaculture Sector Development Plan (FASDP) for restructuring its coastal and inland fisheries The aim is to reverse the current trend whereby fish stocks are increasingly diminishing and the current rate of fishing is unsustainable resulting in less productive fisheries increased costs with declining profitability and the risk of exacerbating nutritional deficiencies and poverty within fishing communities To date the government has enacted legislation (Fisheries Act 2002) prepared policies (2008 updated in 2010) and published regulations (August 2010) but the Ministry of Food and Agriculture and the Fisheries Commission lack the capacity and financial resources to implement all of these initiatives The World Bank is therefore considering a supporting programme of technical assistance and finance which will assist with governance reforms the introduction of licensing for all vessels a reduction in the size of the industrial and semi-industrial fishing fleets and the progressive transfer of fishing activity to the canoe sector International support for Ghanas fishing industry is being coordinated under the West Africa Regional Fisheries Programme (WARFP) This initiative began with four countries Cape Verde Liberia Sierra Leone and Senegal It is now being extended to the following countries Ghana Guinea Guinea Bissau and Gambia A process framework has been developed by the Commission sous Regionale des Peche (Based in Dakar Senegal) to assist member countries of WARFP to prepare their own national process frameworks together with accompanying environmental and social safeguards assessment an environmental management plan and resettlement policy This report has been designed to provide the outline structure and contents for these documents on behalf of the Government of Ghana Another important function of the report is to review the application of the World Banks own Environmental and Social Safeguard policy to the planned investment Both the governments development plan (FASDP) and preparation of the World Banks financial assistance package are at an early stage Consequently this report covers (and can only cover) the broad principles and sets out initial conclusions It will be necessary for further reviews to be undertaken when the Government of Ghanarsquos programme has been developed in more detail Objectives of the Environmental and Social Assessment (ESA) The overall aims of planned interventions in the fisheries industry of Ghana are to improve fish stocks and increase the sustainability of fishing activity which will have long-term environmental and social benefits for the country However the process of introducing change is likely to have some short-term adverse effects on individuals and particularly those who are vulnerable or disadvantaged within poorer fishing communities unless appropriate mitigation measures are taken The purpose of the environmental and social assessment set out in chapter 6 is to identify potential environmental and social impacts both individually and cumulatively and to assess their relative magnitude duration reversibility and importance Based on these findings the draft management framework (see chapter 8) sets out proposals for avoiding or mitigating unacceptable change The process of reforming the fisheries sector will take a number of years and the existing FASDP covers only the first five years With the exception of proposals to scale down the size of the industrial and semi-industrial fishing fleets it is unlikely that major changes will take effect in terms of fishing activity during this five-year period Consequently from the standpoint of the World Banks investment there are likely to be relatively few issues in terms of potential conflict with safeguarding policies Later
8
however significant change is within the fishing industry and particularly onshore processing and marketing of fish products An important element in this report has therefore been the need to define the point at which the banksrsquo responsibilities are seen to terminate and all liabilities are transferred to other supporting donors and the government of Ghana In the short term a reduction in the industrial fleet may lead to the loss of 1000 to 3000 jobs for crew members although in practice most of this work is only part time and many of the vessels that are due to be withdrawn are no longer seaworthy In the longer term it is intended to encourage more selective fishing by limiting open and unfettered access to fish stocks eliminating illegal and damaging processes including dynamiting uncontrolled light fishing and the use of small size monofilament nets and introducing seasonal restrictions to protect breeding cycles The intention is that these measures will be managed jointly by the government and communities through co-management systems At the same time major efforts will be made to reduce the level of post-harvest losses and to increase the value of fish products The expectation is that the number of industrial semi-industrial vessels and canoes will be stabilised at a fixed lower level within five years Once this point is reached and no further licences are granted individual licences will acquire higher values especially as fish stocks recover and the size and value of fish catches starts to increase Subsequently licenses are likely to be sold and traded as less efficient owners drop out of the market and sell on to stronger individuals and companies In terms of onshore activities fish landing processing and marketing will become more efficient and losses will be reduced through use of better smokers freezing and drying equipment Previous studies in West Africa and elsewhere (Bennett et al 2001) have shown that the transition away from open access to a more regulated system of access management can give rise to social risks Specifically older men are likely to be displaced when they are no longer fit enough to withstand the rigours of fishing while a rising number of young men may find it harder to enter a career in fishing Women who currently manage or assist with all areas of buying processing and marketing using traditional clay ovens may also experience competition as new companies and enterprises are established to take advantage of higher profitability in the fishing sector perhaps using better equipment newer technologies and different logistics arrangements or their own transportation Methodology This study has followed the methodology developed within the process framework for the West Africa regional fisheries programme (WARFP) Figure 1 sets out both sequence and timescale for the work
The range of jobs at risk is based on assumptions about the number of vessels and average crew size and cannot be determined with any degree of accuracy until the necessary surveys are undertaken
9
The report is based on three major areas of activity 1 documentary analysis and utilisation of the studies already carried out by the fisheries commission 2 meetings with institutional stakeholders principally affected by the project and 3 Consultations and visits to some of the key fishing villages and communities The planned presentation of findings to Stakeholders has been postponed at the Clientrsquos request due to other pressing commitments in the agriculture and fisheries sectors This presentation will however need to be subsequently undertaken by the Ministry and the Fisheries Commission
11
CHAPTER 2 PLAN AND PROGRAMME DESCRIPTION
INTRODUCTION This chapter is divided into two parts Part 1 sets out the progress which the government Ghana is making in giving effect to the legislation policy and regulations Part 2 describes the proposed programme of assistance being offered by the World Bank with the specific aims of strengthening governance and enforcement systems (Components 1 and 2) and in promoting value addition and reduction of post-harvest losses
PART 1- THE DRAFT FISHERIES AND AQUACULTURE SECTOR DEVELOPMENT PLAN (FASDP) This plan (FASDP) covers the period 2010-2015 It recognises the importance of Ghanarsquos fisheries which generate in the order of US$ 1 billion a year contribute 45 to GDP and indirectly support the livelihoods of 22 million people However through over-fishing and lack of investment in management and value addition the average income per canoe has dropped by up to 40 over the last ten years to the point where it costs as much to fish as the catch is worth By comparison well managed fisheries in other parts of the world are capable of generating economic returns of 30-60 on investment (equivalent to a potential income of US$ 300 million a year for Ghanarsquos fisheries) The Draft FASDP acknowledges that the fishing sector is expected to make a substantial contribution towards doubling the size of the Ghanaian economy by 2015 (GPRS II) as part of the Republic of Ghana Fisheries and Aquaculture Policy Seven targets are set in the draft FASDP 1 Maintaining capture fisheries production at current levels 2amp3 Increasing revenue and profitability in capture fisheries by at least US$ 50 million a year after
five years 4 Increasing aquaculture production to 35000 tonnes a year after five years 5 Retaining Ghana as a landing and processing hub for the West Africa tuna industry 6 Developing fisheries management to allow effective control of all commercial fishing effort in
Ghanaian waters and 7 Ensuring fisheries management costs are sustainable and that the fisheries sector overall make a
fiscal contribution to Government revenues There is an underlying presumption that the canoe sector will remain at the heart of Ghanarsquos fishing industry but the plan is not prescriptive and leaves open the ways of achieving the overall goals At the same time there is an underlying assumption that the long term sustainability of Ghanarsquos fisheries will depend upon discouraging further entry by new operators
PART 2 THE WORLD BANKrsquos CONTRIBUTION TO GHANA FISHERIESPLAN (FASDP)
The essential aim of the World Bankrsquos contribution to FASDP is to provide investment which will build the necessary policy and capacity for effective fisheries management designed to reduce fishing effort while maintaining approximately the same catch levels and to address the impacts of change for fishers
12
and the communities in which they live Based on the currently available draft Project Appraisal Document (PAD) each of the components is now described in turn Component 1 - Good governance and sustainable management of the fisheries This component on good governance comprises four subcomponents which are broken down in turn into a number of separate activities Sub-component 11 developing the capacity rules procedures and practices for good governance of the fisheries Activity 111 reviewing the Fisheries Act and developing regulations to support the Sector Policy and the Fisheries and Aquaculture Sector Development Plan Activity 112 Developing an operational policy to enable implementation of the aquaculture and fisheries sector development plan Activity 11 3 strengthening fisheries management systems and capability (fisheries management plan development aquaculture implementation technical support and training) Activity 114 strengthening fisheries Information Systems (catch recording and monitoring systems statistical analysis and training)
Sub-component 12 introducing fishing rights
Activity 121 developing pilot stakeholder-based fisheries management initiatives around defined fisheries units (ie local management initiatives tighter defining fisheries resources in up to 6 selected Fisher communities) Activity 122 introducing and administering a licensing regime
Subcomponent 13 Adjusting fishing effort and capacity to more sustainable levels marine resource conservation and supporting alternative livelihood opportunities when needed Activity 131 vessel decommissioning Activity 132 compensation packages for crew of decommissioned industrialsemi-industrial vessels Activity 133 alternative livelihood development to incentivise voluntary capacity reduction in the canoe sector Activity 134 marine resources management and conservation
Subcomponent 14 social marketing communication and transparency Activity 141 communications stakeholder consultations and awareness raising programmes to support fishery development Component 2 reduction of illegal fishing Under the West Africa regional fisheries programme subcomponent 21 allows for enabling environment for reduction of illegal fishing These provisions already exist within Ghana and this subcomponent is therefore omitted Subcomponent 22 monitoring control and surveillance (MCS) systems Activity 221 developing compliant systems and capability
13
Component 3 increasing the contribution of the marine fish resources to the local economies Subcomponent 31 product diversificationvalue chain development (freshfrozen producttrade facilitation) Activity 311 landing site development Activity 312 Port development Subcomponent 32 fish product trade infrastructure information and systems - regional minimum integrated trade expansion platform (MITEP) Activity 321 export certification centre development Activity 322 fish processing technology improvements Activity 323 national fisheries advisory group Subcomponent 33 marine and inland aquaculture development Activity 331 space developing aquaculture policy and legal framework Activity 332 improving genetic policy of tilapia fingerlings and breedstock Activity 333 catalysing aquaculture development Component 4 Coordination monitoring and evaluation and program management Subcomponent 41 national implementation subcomponent 42 regional coordination Each of the components sub-components and activities are described in more detail in Chapter 5 which assesses the nature of environmental and social safeguards issues in terms of the World Bankrsquos planned investment
15
CHAPTER 3 BASELINE CONDITIONS
INTRODUCTION This chapter discusses the existing fishery resources of Ghana and describes recent environmental and social trends It identifies some of the pressures that led to the reduction in value of fishing activity and indicates the threats that could be posed if no action is taken in accordance with the planned fisheries and aquaculture program to deal with them FISHERY RESOURCES The continental and coastal waters of Ghana are potentially very rich due to a combination of warm waters and nutrients carried in ocean currents which up-well seasonally on the continental shelf The tonnage of fish caught in marine waters peaked in the mid-1990s around 500000 tonnes and currently averages around 400000 t(See Figure 1) Figure 1 Wild Capture Production in Ghana 1950-2005
2
Table31 Top 10 Species Exported (by value)
1 Canned tuna ($72000000) 2 Fresh tuna ($7200000) 3 Tilapia (no figure available) 4 Miscellaneous dried fish ($1000000) 5 Salmonids frozen ($900000) 6 Marine fish frozen ($600000) 7 Cuttlefish and squid ($600000) 8 Shrimps and prawns ($90000) 9 Sardines ($80000) 10 Crustaceans frozen ($50000) Source FAO Fishstat
The principal catch from deep waters is tuna Industrial vessels registered in Ghana target these species in international waters but also illegally in coastal waters Herring sardine and anchovies are fished in coastal waters by semi-industrial vessels and canoes Table 31 shows the top 10 species of fish exported from Ghana in 2005 PROFILE OF THE FISHING INDUSTRY Fishing is of vital importance in Ghana not only in terms of its contribution to gross domestic product (45 per annum) but because fish provides 65 of the countrys protein In recent years (between 2003-2008) and more specifically in 2004 the countryrsquos annual fish requirement has been estimated to be 882000 tonnes of which the country produces just about half (Tetteh 2007) Of the total population of 22 million people it has been estimated that between 15 and 22 million people are employed or gain their livelihoods from fishing (8-10) Of these there are 210000 men who are directly employed as
2 This figure is the Fisheries Departmentrsquos estimate for 2008
16
fishers The total export of seafood was valued US$824 billion in 2005 Ghanas fishing industry can be divided into three sections marine capture inland capture and aquaculture It can be further analysed by scale of operations distinguishing between industrial semi-industrial and artisanal sectors Marine fisheries Industrial sector Commercial fishing for tuna began in 1962 In the early 1980s Ghana sought to develop an industrial fishing fleet and there are currently 90 industrial trawlers and other vessels which are located in Tema and Takoradi Sekondi The port of Tema was expanded from 1962 to create four main areas the Inner Harbour Outer Harbour Canoe Basin and Commercial Area In 1999 fish landing facilities were improved at the Albert Bosumtwi Sam Fishing Harbour built in Sekondi This harbour is equipped with a cold store an ice-making plant offices a berthing bay for inshore vessels a jetty for canoes and a net drying area Under Ghanaian law more than 50 of the ownership of industrial vessels must be registered with a Ghanaian company or individuals However in practice many vessels are owned by foreign nationals with token Ghanaian ownership Relatively few of these large vessels regularly put to sea and a number are in poor condition or obsolete Nevertheless the impact of trawling activities by Ghanaian registered and foreign owned vessels has been very considerable in coastal waters in recent years Fish landed from industrial vessels is usually transferred directly to Canning factories in Tema and Takoradi Ghana has the largest canning industry in West Africa In the region of 30000 tonnes of tuna are landed In addition to trawling some industrial vessels are engaged in shrimping the use of tuna lines and polls purse seining and demersal trawling Semi-industrial sector in addition to deep sea trawlers there are around 230 large semi-industrial ships propelled by inboard motors which are used for trawling in shallow waters during the off-season and purse seining during upwelling seasons There are currently reported to be 48 bottom trawlers 14 pair trawlers 2 shrimpers 33 pole and line vessels and 10 tuna purse seiners operating from 2 of the 7 landing sites Canoe sector Ghanas artisanal fishing sector is based on between 10000 and 12000 wooden canoes Fifty seven per cent of the fleet is powered by outboard motors supported by paddle and occasionally sail Each Canoe carries a crew of between three and 20 men depending on size and length There are over 334 landing sites along the 550 km coast of Ghana and the majority of fish caught by canoe (180000 tonnes) is returned to these sites accounting for 70 of Ghanarsquos fish production The principal landing sites are at Teshie Jamestown Chorkor Shama Axim Elmina Winneba Mumford Akplabonya Adina Atiteti Abutiakope and more Fishing is undertaken by men but the majority of canoes are owned by women who pre-finance fishing trips (purchasing gear and premixed fuel) and purchase the catch Women also predominate in processing and marketing fish and fish products Only about 20 of fish sold fresh a further 20 is salted and the majority (60) is smoked It is estimated that up to 30 of the catch is spoilt through lack of ice for storage or alternative processing facilities
17
Inland fisheries Water Resources Ghanarsquos inland fishery resources consist of a natural lake( Lake Bosomtwe) and nine major river basins which from east to west of the country are
bull the Volta bull Densu bull Ayensu bull Ochi bull Kakum bull Pra bull Ankobra and bull the Tano
The River Tano forms the border between Ghana and Cote drsquo Ivoire The largest of the rivers is the Volta which drains more than two-thirds of the country through several large tributaries in virtually all regions of the country The Volta river system also incorporates the Volta reservoir generally known as the Volta Lake which has a surface area of around 8400 km2 The Volta lake discharges through the Akosombo dam before flowing through a delta into the Atlantic Ocean The eight other river systems are relatively smaller simpler and open more directly into the Atlantic There are also several reservoirs created on the smaller river systems mainly for potable water production irrigation and flood control These reservoirs irrespective of their primary purposes enhance availability of more permanent aquatic habitable space for fish and therefore support some fisheries Finally with all the river systems opening into the Atlantic there are a series of lagoons and estuaries which act as interfaces between the rivers and the sea These water areas constitute another type of inland water resource for salt and brackish water fishes Inland Fish resources Within the inland water resources of Ghana there are over 150 fish species more than 90 of which are fished for food
In commenting on inland fisheries in Ghana it must be noted that virtually all available information on inland fisheries is obtained from the Volta Lake No national fish production records have been kept on the fisheries of the eight smaller river systems and the lagoons and estuaries Thus the usual statement that inland fish production constitutes about 20 of what the country produces should refer to fish production from the Volta Lake In practice the total inland fish contribution could more realistically be estimated at about 30-35 of national fish production This is a very considerable but understated contribution to national food security and nutrition
Fishing vessels The dominant fishing vessel on the Volta Lake is the canoe the majority of which are built from wooden planks On some other river systems while plank canoes predominate a small number are carved as dug-outs from single tree trunks There is some variety in sizes of the canoes depending on how many planks are used to build the boat and the size of tree trunk used in building a canoe The total number of canoes estimated on the Volta Lake during a survey in 2000 was 24035 On the tributary rivers of the Volta Lake and other river systems in the country the planked canoe is the main vessel used in fishing
18
Fishing gear There are about eleven main kinds of gear used for fishing on the Volta Lake They are Gill Nets Cast Nets Hook and Line Basket and wire mesh traps Winch net Beach seine Bamboo Nifa-nifa Wangara Spears and Atidzas On other rivers in the country Gill nets Cast nets Hook and Line and traps are the fishing gear used On both the lake and rivers the Gill net is the main gear
People Involved In the 2000 frame survey of the Volta Lake conducted by the Fisheries Directorate of Ghana the estimate of fishers on the Volta Lake was put at 71861 Fishers on the lake work in collaboration with a host of fishmongers or handlers who also function as wholesalers for individual fishing groups Assuming that the fisher population on the lake has increased by a modest 3 in the ten years from 1998 to 2010 a fisher population of about 93500 could be considered to be on the Volta Lake now If again it is estimated that number of fishers on rivers in the country were to be a tenth of those on the lake this would put the fisher population on inland waters (apart from the Volta Lake) at about 9350 fishers A very conservative estimate therefore puts the total number of individuals who are directly engaged in inland fishing at over 100000 This excludes all directly associated groups such as fish handlers processors and traders An estimate of secondary fisheries operators such as boat builders out-board motor operators and mechanics as well as bulk salt and fuel wood sellers and those engaged in buying selling and distributing fish would have to be considered in developing estimates for both direct and indirect employment in inland fisheries but the number can be assumed to lie between 125000 and 150000 people
Aquaculture Under Ghanarsquos legal framework aquaculture is defined as ldquoany activity designed to cultivate or farm fish and other aquatic living resourcesrdquo Currently only fin fishes are involved in aquaculture in Ghana
Current culture media and environment Currently fish culture takes place almost exclusively in fresh water in Ghana either in cages brush parks or dugouts Dug-outs are excavations made in floodplains in the savannah parts of the country were water scarcity has been a major hindrance to development in general and food security in particular Dug-outs get filled with flood waters and whatever the water carries during major wet periods of a year in the savannah areas Waters that fill Dug-outs invariably contain fish which are trapped in the Dug-out after the wet period These water bodies are managed until the end of the dry period and the fish are harvested before the next flood period Since the 1960rsquos various strategies to augment fish production from Dug-outs have been developed and tested These involve adding fingerlings of selected fish species to those which are lsquonaturally stockedrsquo in Dug-outs by floods Dug-outs are the major fish culture production approach in the savannah parts of the country which accounts for a little more than half the area of the country The Environment of fish culture Currently fish culture is taking place mainly in freshwater environments Brackish water fish culture and mari-culture activities which will bring lagoons estuaries and the sea into fish culture production have long term potential for development Fishes in culture Fishes being cultivated in Ghana In order of importance are Nile tilapia Oreochromis niloticus the African catfish Clarias gariepinus species of the catfish Heterobranchus and the Bony tongue Heterotis niloticus Scale of Culture Based on level of production fish culture operations can be categorized as follows
bull Large scale commercial where an enterprise produces up to 10000 tonnes per year
19
bull Medium scale commercial where a single enterprise produces between 50 and 500 tonnes bull Small scale commercial where an enterprise produces between one and 20 tonnes and bull Very small scale commercial with productions below 20 tonnes
Fish culture production Cultured fish contribution to national production was officially stated as 9000 tonnes for the year 2009 However informed opinion amongst fish farmers indicates that a figure of between 16000 and 20000 tonnes in 2010 would be closer to reality This statement is based on the facts that most producersrsquo published figures are underestimates several small to medium scale producers are not recorded in official lists and the recording of newly established fish farms has lagged actual establishment especially since 2009 Although cultured production up till 2009 may not have been significant considering a shortfall of about 460000 mt (as recorded in 2004) between captured fish production and national demand this reflected the fact that there were only two large scale commercial producers in the country each of which had had less than ten years of operation Anticipated growth in fish culture production within the next five years is expected to be dramatic as some of the critical challenges of the industry are resolved
CHALLENGES AND PROSPECTS Marine Fisheries The fishing sector is vital for food security and job creation to help alleviate rural poverty in Ghana However the levels of fisheries harvests are generally considered to be close to or to have exceeded the maximum sustained yield Future sustainability in the industry will depend upon the restriction of open access to fisheries and the introduction of management systems which allow fish stocks to recover and the establishment of consistent yields in both marine and inland waters Inland Fisheries Environmental conditions on the Volta Lake constitute the major environmental and social challenges for fisheries its sustainability and profitability In terms of future prospects success will depend heavily on implementation of the lsquoGhana Fisheries and Aquaculture Sector Development Planrsquo and the capacity of the system in Ghana to enforce the Fisheries Regulations passed by parliament in August 2010 Aspects of the Development plan that offers great prospects for the lakes fisheries include the provisions for eventually licensing boats (although the scale of this task should not be underestimated) and measures to involve communities in management of fisheries resources of the Lake
Aquaculture The main challenges facing aquaculture development in Ghana relate to bull The high cost of fish feed (significantly due to its importation from other countries) bull None availability of commercial fish hatcheries as enterprises bull Lack of a nation-wide distribution network for fish seed and cultured fish producers Most
sources of fingerlings are concentrated in one part of the country and since farms all over Ghana obtain their fingerlings individually transportation costs add significantly to overall production costs
bull Now emerging certification and monitoring to check the health and safety of aquaculture processes and products
bull The absence of adequate regulations regarding establishment of an aquaculture enterprise until August 2010 (In the absence of regulations only the large and medium scale commercial farms worked towards conforming to international performance Standards and operational regulations for certification of farms and their products still remain in a draft state)
bull Low national support for research to support expansion and systematic development of aquaculture
20
The prospects for development of aquaculture as an industry in Ghana are good since a number of practical policy and legal frameworks have been put in place to resolve the basic challenges to the industry listed above These include
bull Construction of the first local fish feed plant by an international fish feed company with the expectation of having initial products on the Ghanaian market during 2011
bull A lsquoLarge scale commercial fish farmrsquo with great capacity for fingerling production is shifting emphasis to fish seed production And several localized fish seed producers are expanding operations
bull Distribution strategies by cultured fish producers have started to emerge on a limited scale and are expected to evolve with increasing production as existing commercial farms expand and new ones join in
Now that regulations regarding establishment of aquaculture enterprises have been gazetted there is likely to be a positive response amongst fish farmers of all size categories New operational standards are being prepared which will introduce minimum standards for local certification This should set the stage for preparation of fish culture products and the broadening of choice for consumers while also qualifying Ghanaian producers to enter external markets
ENVIRONMENTAL CONDITIONS The coastal and marine environment a critical zone of influence for this study comprises a 550 km coastline a coastal belt ranging from 1 to 20 km in width and coastal waters extending to 200 nautical mile limit which was established in 1977(under the territorial waters and continental shelf act 1973 as amended by the territorial waters and continental shelf amendment decree 1977) The Coastal Belt The coastal belt accounts for only 65 of the land mass of Ghana but it is one of the most densely settled areas accounting for 25 of the population and80 of the industrial establishments in Ghana Historically the coastal zone was cultivated for coconut (copra) but this industry is in decline Vegetables and other agricultural produce are grown on better soils but the principal economic activities are fishing transportation salt production and sand and stone winning Tourism also offers great potential There is considerable expectation that the discovery of offshore oil and gas deposits will bring new wealth to parts of the coastal corridor However present plans to transfer crude products to tankers at sea and then export them directly will limit industrial activity to a support role A high percentage of industrial and municipal wastes is dumped at landfill sites within the coastal zone which creates pollution risks The coastal belt is generally a low-lying area less than 200 m above sea level Vegetation types reflect the rainfall gradient and consist of coastal shrub and Savannah to Winneba southern marginal forest to the east of Sekondi dry semi-deciduous and moist semi-deciduous forest to the east of Cape Three Points estuary and wet evergreen forest in the extreme south Soils are variable within this area ranging from fertile pockets river valleys to Sandy poorer quality soils close to the sea The Coast The coast line divides into three sections (Ly 1980)
bull West of Cape Three Points this area has a wide and flat beaches backed by coastal lagoons and
21
wave heights are generally low bull Between Cape three points and Tema the coast consists of a series of rock headlands enclosing
shallow bays together with sandbars or spits enclosing coastal lagoons The surf zone is a medium to high energy environment with wave heights often exceeding 1 m South-westerly prevailing winds give rise to longshore drift in an easterly direction
bull Between Tema and Aflao most of the shore is sandy although there are rocky outlets The coastal zone is important internationally in providing feeding roosting and nesting sites for thousands of migratory birds Environmental degradation is significant in Ghana and is recognized in the countryrsquos environmental action plan It contributes to rising poverty levels coupled with poor human health and inadequately planned urbanization which fuel a vicious cycle inhibiting human development The core issues include
bull Domestic sanitation bull Increased urbanization without appropriate infrastructure bull Wetlands and mangrove degradation bull Coastal erosion and bull General biodiversity loss
Briefly each of the above could directly or indirectly adversely influence fisheries and aquaculture separately or together For example in a recently completed study of water quality scenarios of the Volta Lake in relation to fish production as a component of a comprehensive study (The Challenge Program Project of Water amp Food) it was concluded among others that poor sanitation in highly populated fisheries communities adversely influenced water quality to the detriment of fish life and thus fish production With reference to aquaculture the same unsanitary conditions in highly populated shore communities adversely influenced water quality especially in terms of oxygen depletion when lake waters extend to the shore in high water periods This is a situation which has caused fish kills in cages because caged fish cannot escape lsquopollutedrsquo waters Degradation of wetlands and mangroves leads directly to a reduction in their capacities as spawning and nursery zones for both marine and inland water fishes which reduce fish production in both environments The situation outlined above is often contributed to by anthropogenic and industrial pollution due to urbanization without appropriate infrastructure Another issue linking human activity to a deteriorating environment is demonstrated by the encroachment of aquatic weeds on inland waters such as the Volta Lake Weed growth is accelerated by farming reservoir catchments which increases nutrient levels and the building of dams which reduce or cut off intrusion of sea water into rivers Currently as climatic change observable impacts such as floods seem to escape predictions The project could possibly contribute to mitigating against direct and indirect effects of climate change on fishing and aquaculture through investment into climate change orientation and education of fishers and fish farmers to mainly influence reasonable precautions they take Marine waters The continental shelf is relatively narrow projecting out to 25-35 km except in the area of Cape Coast to Salt Pond where it extends to almost 80 kms Sandy and rocky substrates which previously supported coral and seaweeds have been severely affected by former trawling activity which indiscriminately
22
dredges material from the seabed Coastal waters are enriched by freshwater discharges from the relatively small number of rivers and by two seasonal up-wellings which occur between late June and early October (the main upwelling) and January and March (the minor upwelling) The origin and driving mechanisms of these up-wellings are not fully understood and both their location and strength varies from year to year
Lake Volta and other inland water
Major environmental issues on the Volta Lake which might also be considered as challenges to sustainable fisheries on the major inland fisheries resource can be summarised as follows
bull The Volta Lake is known to be low in nutrients It therefore has low standing crops of phytoplankton and zoo plankton to support high fish production
bull The northern segment of the lake together with tributary rivers constitute the spawning and feeding grounds for majority of fish species in the lake during the wet season however these segments are intensely fished during the same period
bull The Volta Lake is divided into eight unequal strata with different distribution of boats per Km2 At the last estimation of carrying capacity in 2000 stratum V and II had the highest (527) and lowest(157) number of boatsKm2 respectively
bull The rate of siltation in the lake is considered to be increasing due to erosion associated with high rates of deforestation
bull A major challenge exists in getting fishers fishing communities and fishing entrepreneurs to understand and comply with fishing regulations aimed at conserving fish and fisheries resources
bull There is a lack of resources studies and research to support fisheries management of the Lake
bull High illiteracy exists amongst lake shore communities
bull Open access to the fish resources of the Lake has been in operation since its formation
bull Declining fish yields are occurring in the lake (468 Kgha in 1976 to 320 Kgha in 2003-MOFA) brought about by the constraints listed above
bull The commonly assumed estimate of potential fish production from the lake of around 75500 mtyr) is considered to be a serious underestimate since Stratum VII alone was estimated to produce 33800mtyr in 1996
bull The policy environment for aquaculture is currently strongly supportive of the industry and related enterprises
bull There is good quality and more than sufficient water to allow some kind of aquaculture to be developed in every region of the country with the Volta lake (about 8400 Km2) as the single most important water unit for fish culture Currently it appears that the free access to the fish resources of the lake has to some extent been applied to establishment of small scale caged fish culture enterprises a situation constituting environmental risk to investments of large scale commercial fish culture establishments in the lake
bull The Volta Lake is low in nutrients (Obeng 1964) resulting in a situation where higher fish yields could be sustained if greater quantities of fish feed were available
23
bull In Ghana the Nile tilapia O niloticus occurred naturally only in the Volta system Due to positive culture characteristics of the fish it has been moved into virtually all other river basins in the country The situation provides opportunities for hybridization of the Nile tilapia with other tilapia species native to the river basin into which the Nile tilapia has been moved
25
CHAPTER 4 POLICY AND LEGAL FRAMEWORK FOR ENVIRONMENTAL AND SOCIAL ISSUES
41 INTRODUCTION
Development and implementation of the Ghana Fisheries and Aquaculture Sector Development Plan and the World Bankrsquos supporting program need to be developed with full regard to existing international conventions national legislation policies and regulations This chapter highlights the main legislative and policy considerations for the protection of the environment natural resources fisheries and social and economic development It begins with reference to the World Bankrsquos safeguard framework and those of other donors This is followed by a section on the governance framework in Ghana
42 WORLD BANK AND OTHER DONORSrsquo SAFEGUARDS POLICIES
The World Bankrsquos safeguard policies exist to ensure that all projects which it finances are developed and implemented on environmentally and socially sound principles A range of different policies exist and these have been carefully considered to ensure that the Ghana Fisheries and Aquaculture Development Sector Development Plan complies with these safeguards All policies have been screened and those that have no bearing on the fisheries programme have been excluded from Table 41 below Table 41 lists policies which could have some applicability to the FASDP even if this interaction might be very slight It is important to stress that the comments in the third column of Table 41 relate to the entirety of the Fisheries and Aquaculture Sector Development Plan whose effects will continue to be experienced long after the World Bankrsquos financial support has been expended Most of the activities in the FASDP will have no effect in relation to safeguard objectives and where there are implications these are likely to occur at precise locations (for example at fish landing sites) rather than throughout the industry Where potential interactions have been noted the necessary mitigating measures are incorporated in the Draft Process Framework
Table 41 World Bank Safeguard Policies in Context
Safeguard Policy
Safeguard Policy Objective Brief Description and relevance to FASDP
OP 401 Environmental Assessment
This policy aims to ensure that Bank-financed projects are environmentally sound and sustainable and that the decision-making process is improved through appropriate analysis of actions and mitigation of their likely environmental impacts This policy is triggered if a project is likely to carry potentially adverse environmental risks and impacts on its area of influence OP 401 covers impacts on the natural environment (air water and land)
The majority of actions planned under FASDP will be beneficial to the marine environment and to inland waters However new construction activities could have impacts and depending on the project and the nature of impacts a range of instruments can be used to ameliorate and mitigate adverse effects while enhancing beneficial effects These include EIA environmental audit risk assessment and environmental management plans (EMP) The need for EIA and EMP is considered in this report
26
OP 404 Natural Habitats
This policy recognizes that conservation of natural habitats is essential to safeguard their unique biodiversity and to maintain environmental services and goods for human society and for long-term sustainable development The Bank therefore supports the protection management and restoration of natural habitats in its project financing as well as policy dialogue and economic and sectoral work Natural habitats comprise many types of terrestrial freshwater coastal and marine ecosystems They include areas lightly modified by human activities but retaining their ecological functions and most native species
This policy is triggered by any project (including any sub-project under a sector investment or financial intermediary) with the potential to cause significant conversion (loss) or degradation of natural habitats whether directly (through construction) or indirectly (through human activities induced by the project) This policy is applicable to the Ghana Fisheries Programme because the project focuses on the integrated management of natural habitats However by screening all proposals under the ESMF any sub-projects that might impact these habitats will not be funded
OP 409 Pest Management
The objective of this project is to (i) promote the use of biological or environmental control and reduce reliance on synthetic chemical pesticides and (ii) strengthen the capacity of the countryrsquos regulatory framework and institutions to promote and support safe effective and environmentally sound pest management
The policy is triggered if (i) procurement of pesticides or pesticide application equipment is envisaged either directly through the project or indirectly through on-lending co-financing or government counterpart funding (ii) the project supports an activity requiring the use of pesticides that may have negative effects on the environment The only instance in which this policy might be triggered by the Ghana Fisheries Programme is if aquatic herbicides or antibiotics were to be used in connection with aquaculture This is most unlikely but can be monitored through the implementation programme
OP 411 Physical Cultural Resources
The policy objective is to assist countries in avoiding or mitigating adverse impacts of development projects on physical cultural resources For the purposes of this policy ldquophysical cultural resourcesrdquo are defined as movable or immovable objects sites structures groups of structures natural features and landscapes that have
Under the Ghana Fisheries Programme construction and rehabilitation activities that could have negative impacts on cultural property will be avoided In the case of discovery of remains national procedures will be applied
27
archaeological paleontological historical architectural religious aesthetic or other cultural significance
OP 412 Involuntary Resettlement
The objective of this policy is to (i) avoid or minimize involuntary resettlement where feasible while exploring all viable alternative project designs (ii) to assist displaced persons in raising their former living standards income-earning capacity and production levels or at least in restoring them (iii) encourage community participation in planning and implementing resettlement and (iv) provide assistance to affected people regardless of the legality of land tenure
The policy covers not only physical relocation but any loss of land or other assets resulting in (i) relocation or loss of shelter (ii) loss of assets or access to assets (iii) loss of income sources or means of livelihood whether or not the affected people must move to another location The activities of the Ghana Fisheries Programme are likely to result in loss of assets or access to assets and loss of income sources or means of livelihood for some groups and individuals The potential for such losses will be carefully scrutinised and compensated for through the National Process Framework and Resettlement Policy Framework described in this report and appropriate procedures will be followed where necessary
Other donors and aid agencies including International and National NGOs play an active role within the fisheries sector in Ghana and their safeguards standards will be observed through operation of the Environmental and Social Safeguards Management Plan
28
43 THE GOVERNANCE FRAMEWORK IN GHANA
The Ministry of Food and Agriculture (MOFA) Preparation of Fisheries laws and policies fall under the responsibilities of the Minister of Food and Agriculture who in turn delegates functions including implementation to a semi-autonomous body the Fisheries Commission
The Fisheries Commission (FC) was established under the Fisheries Commission Act (625 2002) It oversees management regulation and utilisation of the fisheries resources of Ghana drawing on powers set out in the Fisheries Law (PNDC 256 1991) Fisheries Act 625 provided for the establishment of a more robust Fisheries Commission (FC) which is an amalgamation of the erstwhile FC and Department of Fisheries
Ten individuals constitute the Board which is led by a chairman (appointed by the President of Ghana in consultation with the Council of State) supported by three members drawn from the ministries of transport defence and environment There are three representatives from the following parastatal organizations - the Ghana Marine Fishing Officers Association Water Research Institute and Ghana Irrigation Development Authority- and two representatives (one from the artisanal and one from the industrial sections )of the National Fisheries Association of Ghana Finally the tenth member is a person with requisite knowledge of the fishing industry or natural resources renewal management
The day to day work of the Fisheries Commission is undertaken by the Department of Fisheries (DOF) which serves as the implementation secretariat of the Fisheries Commission as stipulated by the Fisheries Act 625 of 2002 Specific tasks that are undertaken by the Department of Fisheries include
bull preparing fishery resource management plans bull developing regulations for the fishing industry bull organizing monitoring surveillance and enforcement for the national fishery resources and
ensuring compliance with national fisheries law and institutionalizing co-management concepts
The MCS Division of the DoF (established under the Fisheries Sub sector Capacity Building project) works in conjunction with the Ghana Navy and undertakes sea patrols to exclude industrial fishing vessels from the 30-metre depth IEZ reserved for artisanal fisheries The MCS also conducts inspection of industrial vessels at the fishing ports of Tema and Takoradi for
bull valid fishing licences bull legality of fishing gear bull skipperrsquos certificate bull log book and crew composition
The MCS undertakes similar functions for inland fisheries on Lake Volta
The Ministry of Local Government and Rural Development (MLGRD) is responsible for managing fishers fish processors and fishery resources at district and sub-district levels which it undertakes through the District Assemblies In 2002 the District Assemblies in collaboration with DoF were mandated to facilitate fishery resource management by
bull helping to form and sustain Community Based Fisheries Management Committees (CBFMCs) bull cooperating with the DoF MCS units bull providing legal and financial support to the CBFMCs and bull approving levies proposed by the CBFMCs
29
Community-Based Fisheries Management Committees are charged with the responsibility of enforcing national fisheries laws at community level as well as initiating and enforcing their own by-laws
44 THE LEGAL FRAMEWORK
441 International Conventions
Ghana has ratified a number of international conventions and treaties which have an important bearing on the state of its marine and inland waters and the condition of the fisheries These are listed in Box 1 below
Box 1 International Conventions treaties and agreements to which Ghana is a signatory 1 International Convention for the Prevention of Pollution of the sea by Oil 21 October 1962 2 Convention on the Africa Migratory Locust 25 May 1962 3 Treaty Banning Nuclear Weapon Tests in the Atmosphere in Outer Space and Under Water 5th August 1963 4 International Convention for the Conservation of Atlantic Tunas 4 May 1966 5 Africa Convention on the Conservation of Nature and Natural Resources 15 September 1968 6 International Convention on Civil Liability for Oil Pollution Damage 29 November 1969 7 International Convention Relating to Intervention on the High Seas in Cases of Oil Pollution Causalities 8 Convention on Wetlands of International Importance Especially as Waterfowl Habitats 2 February 1971 9 Treaty and Prohibition of the Emplacement of Nuclear Weapons of Mass Destruction on the Seabed and the Ocean Floor and in the Subsoil Thereof 11 January 1971 10 International Convention on the Establishment of an International Fund for Compensation of Oil Pollution Damage 18th December 1971 11 Convention Concerning the Protection of World Cultural and Natural Heritage 16 November 1972 12 Convention on International Trade on Endangered Species of Wild Fauna and For a 3 March 1973 13 Convention on the Military or Any other Hostile Use of the Environmental Modification Techniques 10 December 1976 14 Convention on the Conservation of Migratory Species of Wild Animals 23 June 1979 15 Convention for the Cooperation in the Protection and Development of the Marine and Coastal Environment of the West and Central African Region1981(Abidjan Convention) 16 United Nation Convention on the Law of the Sea 10 December 1982 17 Montreal Protocol on Substances that Deplete the Ozone Layer 24 July 1989 18 Convention to Combat Drought and Desertification 19 Framework Convention on Climate Change June 1992 20 Convention on Biological Diversity1992 442 Environmental-Related Conventions Environmentally related conventions ratified by Ghana include
bull International Convention for the Prevention of Pollution of the sea by Oil 21 October 1962
bull Convention on the Africa Migratory Locust 25 May 1962 Treaty Banning Nuclear Weapon Tests in the Atmosphere in Outer Space and Under Water 5th August 1963
bull International Convention for the Conservation of Atlantic Tunas 4 May 1966 bull Africa Convention on the Conservation of Nature and Natural Resources 15 September 1968 bull 992256International Convention on Civil Liability for Oil Pollution Damage 29 November
1969 bull International Convention Relating to Intervention on the High Seas in Cases of Oil
30
Pollution Causalities bull Convention on Wetlands of International Importance Especially as Waterfowl Habitats
2 February 1971 bull Treaty and Prohibition of the Emplacement of Nuclear Weapons of Mass Destruction
on the Seabed and the Ocean Floor and in the Subsoil Thereof 11 January 1971 bull International Convention on the Establishment of an International Fund for
Compensation of Oil Pollution Damage 18th December 1971 bull Convention Concerning the Protection of World Cultural and Natural Heritage 16
November 1972 bull Convention on International Trade on Endangered Species of Wild Fauna and For a 3
March 1973 bull Convention on the Military or Any other Hostile Use of the Environmental
Modification Techniques 10 December 1976 bull Convention on the Conservation of Migratory Species of Wild Animals 23 June 1979 bull Convention for the Cooperation in the Protection and Development of the Marine and
Coastal Environment of the West and Central African Region1981(Abidjan Convention)
bull United Nation Convention on the Law of the Sea 10 December 1982 bull Montreal Protocol on Substances that Deplete the Ozone Layer 24 July 1989 bull Convention to Combat Drought and Desertification bull Framework Convention on Climate Change June 1992 bull Convention on Biological Diversity1992
443 National Legislation
The principal national legislation that affects fisheries in Ghana is listed below
1 Fisheries Regulation 1984 LI 1294 2 Fisheries (Amendment) Regulation 1977 3 Maritime Zones (Delimitation) Law 1986 4 PNDC Law 256 of 1991 5 Fisheries Commission Act of 1993 and 6 Fisheries Act 625 of 2002 7 Fisheries Regulations passed in 2010 LI 1968
Other laws that have relevance to the fisheries sector include
1 Wild Animals Preservation Act 1961 (Act 43) 2 Volta River Development Act 1961 (Act 46) 3 Ghana Water and Sewerage Corporation Act 1965 (Act 310) 4 Oil in Navigable Waters Act 1964 (Act 235) 5 Irrigation Development Authority Decree 1977 (SMCD 85) 6 Minerals and Mining Law 1986 (PNDCL 153) 7 Environmental Protection Agency Act 1994 (Act 490) 8 Ghana Highway Authority Act 1997 (Act 540) 9 Timber Resources Management Act 1998 (Act 547) and 10 Minerals and Mining Act 2006 (Act 703
31
434 Policies A number of Environmental related Policies exist in Ghana however there is no specific policy on the coastal zone These include
bull The National Environment Policy bull National Wetlands Policy bull Agricultural Policy bull Tourism Development Policy bull Land Management Policy bull National Health Policy bull Energy Policy bull Minerals Policy bull Wildlife Conservation Policy
The main thrust and orientation of national policies on the protection management and development of the marine and coastal environment focuses on the following three major areas
bull Integrated coastal zone management and sustainable development bull Marine environmental protection both from land-based activities and from sea-based
activities and bull Sustainable use and conservation of marine living resources (both of the high seas and
under national jurisdiction) Specific plans have been developed to ensure the realization of prudent management of the marine and coastal environment These include
bull Coastal Zone Management Indicative Plan 1990 bull National Environmental Action Plan 1994 bull Draft Integrated Coastal Zone Plan 1998 bull Coastal Zone Profile of Ghana 1998 bull National Oil Spill Contingency Plan with specific reference to the marine environment
2002 bull Environmental sensitivity map of the coastal areas of Ghana 1999 and 2004
Despite the existence of these plans active integration and coordination has been lacking in practice at local level 434 Regulations Though several legislations exist on coastal protection and sustainable development there is no omnibus legislation on the environment Legislation relating to the area include the following
bull Beaches Obstruction Ordinance 1897 (Cap 240) bull The Mineral and Mining Law 1986 (PNDC 153) bull Rivers Ordinance 1903 (Cap 226) bull Land Planning and Soil Conservation Ordinance No 32 of 1953 as Amended by the bull Land Planning and Soil Conservation (Amendment) Act 1957 (No 35 of 1957) bull Maritime Zones (Delimitation) Law 1986 (PNDCL 159) urban planning and
32
bull development bull Town and Country Planning Ordinance (Cap 84) bull Wild Animals Preservation Act Act 235 1964 bull The Towns Ordinance (Cap 86) bull National Building Regulations 1996 (LI 1630) bull Volta River Development Act 1961 bull Fisheries Act 2002 Act 625 bull Fisheries Law 1991 (PNDC 256) bull Fisheries (Amended) Regulations 1977 and 1984
The sustainable use and conservation of marine resources is encouraged through legislation regulations education and awareness creation programmes as well as the enforcement of existing regulations and legislation The legal framework for coastal zones issues and management in the country are contained in the following documents
bull The 1992 constitution bull EPA Act 1994 (Act 490) bull Environmental Assessment Regulations 1999 (LI 1652) bull Local Government Act 1993 (Act 462) bull Environmental Standards and Guidelines bull
In addition there are other specific legal frameworks which include a) The legal framework for Ecosystem Protection which are
bull Wild Animals Preservation Act 1961 (Act 43) bull Wildlife Conservation Regulations 1971 (LI685) bull Wild Reserves Regulations 1971 (LI 740) bull The Wetland Management (Ramsar sites) Regulation 1999 bull Oil in Navigable Waters Act 1964 (Act 235)
b) The legal framework for Fisheries Resources which are bull Fisheries Law 1971 (PNDCL 256) bull Fisheries Act 2000
c) The legal framework for Oil and Gas Industry bull Petroleum (Exploration and production) Law 1984 (PNDCL 84) bull Mineral (Offshore) Regulations 1963 (LI 257) bull Mineral (Oil and Gas) Regulations 1963 (LI 256) bull Oil and Mining Regulations 1957 (LI 221)
d) The legal framework for Tourism Promotion (including coastal tourism) bull Ghana investment Promotion Centre Act 1994 (Act 478) bull Companies Code 1963 (Act 179) bull Free Zone Act 1995 (Act 504) bull Ghana Tourism Board bull Ghana Commission on Culture
44 ACTIVITIES RELATING TO FISHERIES INTERESTS
33
Over the years several activities have been undertaken which are of relevance to protection of the marine environment and fisheries These include
bull Ghana Environmental Resource Management Project in Coastal Wetlands Management Component
bull Gulf of Guinea Large Marine Ecosystem Project bull Fisheries Sub-sector Capacity Building Project bull Establishment of a Protected Wetland Ecosystem on the coast bull Development and Implementation of Oil Spill Contingency Plan bull Monitoring of fish stock levels and associated oceanographic parameters bull Institution of a programme of Monitoring Compliance and Surveillance of the marine
environment bull Development of industrial pollution standards bull Development of University course on Coastal Zone Management bull Increased public education on sound coastal and marine environmental practices
45 RELEVANT INSTITUTIONS With regards to protection management and development of the marine and coastal environment a number of ministries and agencies have been identified as potential stakeholders Those shown with an asterisk are likely to have a particularly active role
bull Ministry of Environment and Science bull The Environmental Protection Agency bull Ministry of Tourism bull Ministry of Local Government and Rural Development bull Ministry of Ports bull District Assemblies bull Ghana Ports and Harbours Authority bull Hydrological Services Department bull Ministry of Food and Agriculture bull Ghana Tourist Board bull Ghana Investment Promotion Centre bull Fisheries Commission Ministry of trade Industries and PSI bull Ministry of Lands and Natural Resources Forestry and Mines bull Ministry of Energy bull Ministry of Health bull Ministry of Education Youth and Sports bull Ministry of Defence bull Ghana Navy bull Ministry of Works and Housing bull Ministry of Women and Childrenrsquos Affairs bull Ministry of Roads and Transport bull National Development Planning Commission bull Council for Scientific and Industrial Research bull Universities and Research Institutions bull Ghana Meteorological Agency bull Town and Country Planning Department bull Water Resources Commission
34
bull Ghana National Petroleum Corporation bull Volta River Authority bull Geological Survey Department bull Forestry Commission (Forestry and Wildlife Division) bull Traditional Rulers and their analogous ministry and laws
Non-Governmental Organisations including Resource Development amp Environmental Oriented Development Organisation
bull Friends of the Earth bull Green Earth bull Wildlife Society bull Recerca e Cooperazione bull Centre for African Wetlands bull And many others
46 PARTNERSHIPS Few formal partnerships exist However support for coastal conservation activities has been received from the private sector as well as from Government Regional and sub-regional collaboration efforts occur at various levels although the level of practical intervention is sometimes limited The science and technology unit of ECOWAS is engaged on issues relating to the management of the Gulf of Guinea In addition a bilateral arrangement exists between Ghana and Cote drsquoIvoire for the management of and datasharing on Sardinella stocks which migrate between the two countries The NEPAD framework among the coastal states of Africa is also developing an interest in marine and coastal management 461 Technical and financial support Ghana receives technical support in the form of training research and project implementation from national bilateral and multi-lateral sources Financing of activities in the sector is primarily supported from the national budget However donor support from both bilateral and multilateral sources has also been obtained for specific programmes such as the World Bank sponsored Fisheries Sub-sector Capacity Building Project UNOPS sponsored Environmental Sensitivity Map for Coastal Areas The Ghana Coastal Wetland Project of the World Bank UNEPrsquos WACAF Programmes and The Darwin Marine Biodiversity of West Africa Project by DFID implemented by the University of Ghana 47 ACTIVITIES Activities undertaken in the country with importance to the marine and coastal area are outlined in the following sections 471 Environment-related activities
bull Ecological Baseline studies of Korle Lagoon (1990-2000) This was carried out to satisfy EIA requirement and as a result pollution status of the lagoon was established
bull Lower Volta Mangrove Project (1996-1998) The objective is to ensure sustainable management of mangrove stands and as such baseline information was documented
bull Save the Seashore Birds Project (1985-1995) This was to protect the seashore birds and as a result conservation awareness of seashore birds was achieved
bull Ghana coastal wetlands management project (1996-1999) In this management of the five coastal wetlands designated as Ramsar Site was put in place
bull Darwin Marine Biodiversity of West Africa Project It is a training project in marine biodiversity assessment
35
472 Social-related activities bull A considerable amount of attention is currently being given to the potential impact of oil-related
development in coastal regions following the publication of Environmental and Social Impact Assessments and Management Plans relating to the Jubilee Oil Field discoveries
473 Coastal area management bull Climate and vulnerability and adaptation assessment on water resources agriculture and the
coastal zone Projects (1997-1999) The projects assessed the vulnerability of the coastal zone to climate change
bull Coastal area management plan for Princess Town (1998-2000) which aimed at providing a plan for the management of Princess Town
bull Keta Sea Defence Project Work (2000-2004) The project aimed at protecting the Keta and its environs from the episodes of erosion faced in the area and also to ensure improvement in environmental and socio-economic conditions at Keta and its immediate surroundings
474 Regional Programmes bull Gulf of Guinea Large Marine Ecosystems Project (1996-1999) The project developed an
effective approach to prevent and control pollution in the Gulf of Guinea and conserve its biodiversity As a result regional institutional capacities were strengthened and also a coastal zone management profile and plans produced
bull UNEP WACAF Projects 1 amp 2 This aims at institutionalising and coordination of national contingency plans monitoring of pollution in the marine environment and control of coastal erosion
475 Other major programmes Other recent programmes and activities in the marine and coastal environments have included
bull Ghana Environmental Resources Management Project in Coastal Wetlands bull Fisheries sub-sector Capacity Building Project bull Establishment of a Protected Wetland Ecosystem on the coast bull Development and Implementation of Oil Spill Contingency Plan bull
48 ONGOING PROJECTS Ghana is currently implementing several projects in the marine and coastal area Some of these projects are linked to developmental projects for which impact assessments are required under the Environmental Assessment Regulations of 1999 Some of the projects are large scale in nature with extensive baseline and monitoring studies like the Keta Sea Defence Project and the West Africa Gas Pipeline project Others are projects being implemented under the auspices of the United Nations agencies and non-governmental organisations include
bull Combating Living Resource Depletion and Coastal Area Degradation in the Guinea Current LME through Ecosystem-based Regional Actions
bull Amansuri Conservation and Integrated Development Project (ACID) bull Danida Water and Sanitation Sector Programme II Support to Integrated Water Resources
Management (IWRM) Component (2004-2008)The Densu Basin aspect of the IWRM component
bull Reduction of Environmental Impact from coastal tourism
bull Bui Hydro Power Project
bull Sea Defence Project at Atorkor
bull Sea Defence Projects in selected towns in the Western Region of Ghana
36
49 CONCLUDING REMARKS
This chapter has highlighted the wide range of conventions laws policies regulations and activities affecting the inland and coastal regions and inland freshwater and marine environment of Ghana It will be important to keep all of these processes and procedures under review as the Fisheries and Aquaculture Sector Development Plan is taken forward to the implementation stage
The main responsibility for ensuring delivery of the Fisheries and Aquaculture Sector Development Programme will rest with the Fisheries Department of the Ministry of Food and Agriculture and the Fisheries Commission supported by the MCS Division and Ghana Navy However a key part of the programme is the development of local co-management arrangements and the Ministry of Local Government and Rural Development and individual District Assemblies will play a key role in helping to form and sustain Community Based Fisheries Management Committees
Over time a significant number of fishermen and individual fish processors are likely to leave the sector as harvesting landing and processing of the catch becomes more efficient Management of these changes especially where disadvantaged and vulnerable sections of the community are affected will need substantial support and investment and a high degree of coordination amongst government ministries and agencies NGOs and international partners to ensure that development assistance is effectively targeted
37
CHAPTER 5 WORLD BANK SAFEGUARD ISSUES
51 INTRODUCTION
The World Bankrsquos proposed funding support to the Government of Ghana covers an initial five yearsrsquo period which could potentially be extended at a later date As the Government of the Republic of Ghana notes in the draft FASDP ldquoimproving the management of the countryrsquos fisheries and ensuring that the impacts on individuals and communities are properly addressed will take 20 or more years to effectrdquo It has therefore been judged important in this report to distinguish between changes that might occur as a direct result of the World Bankrsquos financial assistance thereby triggering the Bankrsquos environmental and social safeguards and changes that could result from longer term adjustments to fisheries and other sectors of Ghanarsquos economy as a result of wider influences by Government other donors and world-wide factors (for example international progress in world trade agreements)
The aim in this chapter is to identify changes which are likely to fall within the purview of the World Banks reputational risks and responsibilities under the first five years of the Fisheries and Aquaculture Sector Development Plan (FASDP) It should be clearly understood that the views expressed are those of the consultancy team and it will be for the World Bankrsquos internal advisors to decide what formal recommendations are made to the World Bank Board
Trends that may emerge in later stages of the implementation of FASDP ndash subsequent to the initial five year period - are discussed in chapter 6
52 THE CURRENT SITUATION
The general status of Ghanarsquos fisheries has been described in Chapters 3 while the legal and policy context has been set out in Chapter 4 The World Bankrsquos investment is being planned specifically to support government policy with the aim of providing a more efficient and better regulated fisheries sector Currently open access is leading to progressive deterioration in fish stocks and lower economic returns Based on many international examples of successful intervention the current proposals (see Chapter 2) are to provide support to introduce formal licensing of all vessels and proper monitoring and control over the seasonal timing and location of fishing activity use of gear and approved nets and self regulation through co-management structures under which the Government and fishing communities will work together to achieve recovery of fish stocks higher income levels for fishers and better returns on catches by reducing post harvest losses and improving processing and marketing operations
53 ANTICIPATED OUTCOMES
It is expected that the proposed reforms and changes will eventually lead to significant improvement in the marine environment restoration of fisheries and enhanced incomes In this respect the provision of grants and loans from the World Bank will bring about major benefits to the economy livelihoods and the environment in the longer term The question that has to be addressed however is - are there likely to be any short term adverse environmental or social consequences from the Bankrsquos own investment strategy Answers are considered in relation to each of the planned components sub-components and activities which are summarised in Table 51 A colour coding and numbering system has been adopted to distinguish those activities that are seen as particularly relevant from the standpoint of the environmental and social assessment Elements highlighted in green are those likely to have positive and beneficial effects on the environment and social conditions those highlighted in orange red have potentially negative or adverse consequences if not handled properly
38
Component 1 Good Governance and Sustainable Management of the Fisheries
Sub-Component 11 seeks to develop the capacity rules procedures and practices that will lead to better governance As such these procedural interventions will have no direct effect on the environment or social conditions of fishing communities However it will be important to ensure that the drafting agencies (government departments and consultants) give due attention to environmental and social objectives during this phase of work Three specific areas are highlighted including undertaking a socio-economic impact assessment with mitigation measures as part of the plan for fishing capacity reduction reviewing the economic and social implications of subsidies and fish import tariffs in the fisheries sector and developing the policy for the development and operation of community-based management networks built around defined fisheries management units
In developing regulations and guidelines it will be important to consider how less able individuals and vulnerable sectors are going to adapt to new systems For example the new regulations on licensing canoes including completion of registration forms the display of registration numbers on vessels and demonstration of basic competence in health and safety standards may prove taxing demands for owners and crew lacking any formal education Similarly legal instruments that are used to remove fuel subsidies or other benefits will need to be carefully explained A socio-economic impact assessment is proposed in the draft PAD to be accompanied by appropriate mitigation measures This assessment should consider amongst other things
bull whether support should be offered and if so under what conditions to any company community or individual who fails to secure a license for a particular class of vessel
bull how the transfer or sale of licenses will be regulated in the wider public interest to ensure transparent processes and avoid the creation of monopolistic and oligopolistic elites
bull who wins and who loses from any planned changes to subsidies and fish import tariff adjustments
bull how the performance of community-based management networks will be judged bull what action will be taken to mitigate the loss of any traditional fishing grounds that become the
subject of marine protected area development or are subject to exclusion zones to protect oil drilling and production platforms
Sub-Component 12 introduces the concept of fishing rights This is to be initiated through a series of four pilot stakeholder-based fishery initiatives and the rolling out of licensing procedures Discussions with stakeholders have made it very clear that the credibility of the entire fisheries policy and programme could be challenged if these pilots do not show positive and constructive ways of moving forward with fisheries reform There is a great deal of distrust for new procedures amongst the fishing communities based on the knowledge that many previous initiatives have failed It is therefore essential that the pilots are led by a strong implementation team are adequately financed and include a credible transparent and inclusive process for debate discussion and consultation Co-operation from the selected communities will be more likely to be achieved if they can see early results in terms of income generating activities
Sub-Component 13 is targeted at adjusting fishing effort and capacity to more sustainable levels and supporting alternative livelihood opportunities These activities are critical in giving effect to the policy decisions that have already been taken to reduce the size of the industrial and semi-industrial fishing fleet and to strengthen the role of the canoe sector Specific measures are proposed for compensating crew members who lose their jobs and for providing training to young men who are willing to transfer
39
out of the fishing sector The scale of this task should not be under-estimated however since there are currently few alternative employment opportunities in the coastal belt for manual workers with low education and skill levels which typify the status of many young fishermen The concept of creating some additional employment with conservation of the coastal littoral and marine ecosystems is strongly supported since this can be linked with development of tourism
Sub-Component 14 is another element that is strongly focused on delivering improved livelihoods with its emphasis on social marketing communication and transparency The focus on stakeholder participation is particularly welcome and should lead to positive response providing it is backed with direct financial support to participating communities
Component 2 - Reduction of Illegal Fishing
There is no Sub-Component 21 within the Ghana Fisheries Programme
Sub-Component 22 aims to develop monitoring control and surveillance (MCS) systems These measures are largely procedural and apart from the relatively small team that will be recruited to operationalise the systems it will have minimal effects on either the environment or social conditions One element that is highlighted in Table 51 relates to provision of facilities and training for participatory coastal surveillance of small-scale fisheries This should have direct and strongly positive benefits for participants and the communities who are enrolled in the training programmes
Component 3 increasing the contribution of the marine fish resources to the local economies
Sub-Component 31 will support the development of basic infrastructure at nine marine fish landing sites and two inland sites The scale of physical construction will be restricted to repair and minor extension of roads and jetties wharves and construction of net mending screens and storage sheds These activities are unlikely to have any significant adverse environmental impacts and should lead to positive social effects
Sub-Component 32 will underpin efforts to improve fish product trade infrastructure information and systems Introduction of new technology for smoking and curing fish and the extension of existing ice preparation plants will start to have positive beneficial effects within the selected communities
Sub-Component 33 provides a modest level of support to marine and inland aquaculture development Aquaculture development should include finalization establishment and enforcement of current draft operational standards to cater for environmental friendliness of fish culture industry for its own survival The main focus will be on developing policy and legal frameworks together with support for stock improvement These measures will have some impact on affected communities in the short term but are clearly aimed at longer term benefits
40
Component 4 Coordination Monitoring and Evaluation and Program Management
Sub-Components 41 and 42 are directed specifically at strengthening the capacity of the Governmentrsquos institutions for national implementation and regional co-ordination As such they will have no direct environmental or social impacts
54 SUMMARY AND CONCLUSIONS
This review of potential environmental and social safeguard issues under the World Bankrsquos targeted programme concludes that there are unlikely to be any significant adverse environmental or social effects as a result of the planned investments
The only possible exception relates to the effectiveness of measures that are put in place under Sub-Component 12 to support pilot stakeholder-based fishery initiatives It is of paramount importance that these pilots are successful and win the confidence of all participants since failure to achieve positive results could set back the entire fisheries programme For this reason it is essential that planning of the pilot initiatives is linked closely with measures for supporting alternative livelihoods and strengthening processing and marketing initiatives under Sub-Components 13 and 14
A number of the planned interventions may have longer term consequences as policies regulations and bye-laws are put into effect but these will be addressed in subsequent work by the Government of Ghana (see Chapter 6)
Table 51 Elements of the World Bank Programme and assessment of potential environmental and social risks
Description of Component Sub-Component and Activities
Measure of Likely Effects
Large (3)
Moderate (2)
Small (1)
None
Beneficial
3
2
1
Adverse
3
2
1
Component 1 Good Governance amp Sustainable Management of the Fisheries
Sub-Component 11 Developing the Capacity Rules Procedures amp Practices for Good Governance of the Fisheries
Reviewing developing programmes and projects designed to support the Fisheries and Aquaculture Development Sector Plan (FASDEP)
Developing an operational policy to enable implementation of the Aquaculture and Fisheries
Plan for fishing capacity reduction (including socio-economic impact assessment and mitigation) 3 2
Commercial vessel and fishing activity licensing plan including allocation criteria rules for transfer of licenses
41
Sector Development Plan and timetable and schedule of license fees
Compliance strategy and plan
Regulations for the management of fisheries including the identification and specification of fisheries management units (ie stocks species areas)
Recommendations for environmental and social safeguards arising from the review of the economic and social implications of subsidies and fish import tariffs in the fisheries sector
3
Policy for the development and operation of community-based management networks built around defined fisheries management units
3
Policy on adaptation strategies for climate change and marine protected area development
2 2
Review of the Ghana Tuna Industry to identify policy or infrastructure needs that threaten Ghanarsquos hub status
Strengthening capture fisheries management systems and capability
Development of fisheries and aquaculture management systems and processes and training
Strengthening fisheries information systems
Installation and operation of fisheries lsquodashboardrsquo database and information collection
Sub-Component 12 Introducing Fishing Rights ($15 M GEF)
Developing 4 pilot Stakeholder-Based Fisheries Management initiatives around defined fisheries units (ie local management initiatives tied to defined fisheries resources including demand-side governance initiatives)
3 2
Introducing and administering a licensing regime (registry establishment training stakeholder education) 2 2
Sub-Component 13 Adjusting Fishing Effort and Capacity to more Sustainable Levels and Supporting Alternative Livelihood Opportunities where Needed
Vessel decommissioning Decommissioning of 60 to 80 industrial trawlers in an environmentally friendly manner
2
Developing alternative livelihoods for crew of decommissioned industrialsemi-industrial
Skills training and small business development training and support for young (18-30 yrs) industrialsemi-industrial crew members willing to transition out of the sector
3
42
vessels
Alternative livelihood development to incentivize voluntary capacity reduction in canoe sector
Alternative livelihoods fund and CDD support to targeted fishing communities
3 2
Marine Resource Conservation
Would include confirming conservation priorities and management regimes and possible provision of support for alternative livelihood options (funded under 133) associated with conservation of coastal littoral and marine ecosystems as well as de facto protected areas associated with the development of oil and gas extraction
3
Sub-Component 14 Social Marketing Communication and Transparency)
Communications stakeholder consultations and awareness raising programs to support fisheries development
3
Component 2 Reduction of Illegal Fishing
Sub-Component 21 does not apply to Ghana
Sub-Component 22 Monitoring Control and Surveillance (MCS) Systems
Developing compliance systems and capability
Development of judicial and policy capacity (training)
Compliance risk assessmentstrategy systems and process development
Enforcement Unit establishment (dedicated facility)
Coastal surveillance stations 2
Facilities and training for participatory coastal surveillance of small-scale fisheries
3
Training for surveillance officers
Operation of aerial and water patrols (vessel leases aerial patrols operational costs patrol vehicles)
Observer program
Compliance education (stakeholder training signage) 1
Upgrademaintenance of the Vessel Monitoring System (VMS)
43
Component 3 Increasing the Contribution of the Marine Fish Resources to the Local Economies
Sub-Component 31 Fish Landing Site Clusters
Product diversificationvalue chain development
9 marine landing sites (basic infrastructure) at Axim Dixcove Fete Jamestown Moree Mumford Senya-Beraku Teshi and Winneba
3 1
2 inland fish landing sites (improved access and berthing infrastructure) at Abotoase and Dzemeni
3 1
2 ports developed (technical studies for 1 new port at Axim and additional berthing space in existing port of Elmina)
3 2
Sub-Component 32 Fish Product Trade Infrastructure Information and Systems
Export certification center development
Fish processing technology improvements 1 1
Technical assistance training and goods to support the National Fisheries Advisory Group
Sub-Component 33 Marine and Inland Aquaculture Development
Developing aquaculture policy and legal framework
Improving genetic quality of Tilapia fingerlings and breedstock
Catalyzing aquaculture development 2
Component 4 Coordination Monitoring and Evaluation and Program Management
Sub-Component 41 National Implementation
Technical assistance for Secretariat to the Fisheries Commission to implement the Project
Sub-Component 42 Regional Coordination
Technical assistance for Regional Coordination Unit at the CSRP support to Fisheries Information Systems (lsquoDashboardrsquo)
45
CHAPTER 6 ENVIRONMENTAL AND SOCIAL ASSESSMENT OF DRAFT FISHERIES AND AQUACULTURE SECTOR DEVELOPMENT PLAN (FASDP)
61 INTRODUCTION
This chapter examines environmental and social issues which need to be considered as part of the overall structural and economic adjustments in Ghanarsquos fisheries sector in the longer term (ie 1-15 years) The assessment deliberately focuses on the longer term because it will take a number of years before current plans start to have their full effect However the same temporal considerations apply to measures that are designed to avoid or mitigate potentially harmful effects so it will be important to start planning remedial actions as part of the joint Government of Ghana and World Bank fisheries programme
611 Key sectors and activities The fishing industry is divided first into marine capture and inland capture fisheries and then aquaculture For each of these three sectors activities are then broken down as follows Marine Capture Fisheries CATEGORY ACTIVITY Stock Management Research Surveillance reef building Harvesting Vessels Gear Skills capacity Marketing Sellers Buyers Processing Fresh fish Sun dried Smoking Freezing Consumers By market sector Support Sectors Boat Canoe Building fuel supply net making kiln construction
refrigeration transport cold store management Legal Enforcement Financing Investment in all elements Infrastructure Harbour wharf processing plant construction
Inland Capture Fisheries CATEGORY ACTIVITY Stock Management Research Surveillance Harvesting Vessels Gear Skills capacity Marketing Sellers Buyers Processing Fresh fish Sun dried Smoking Freezing Support Sectors Boat Canoe Building fuel supply net making kiln construction
refrigeration transport cold store management Legal Enforcement Financing Investment in all elements Infrastructure Harbour wharf processing plant construction
46
Aquaculture and Mariculture CATEGORY ACTIVITY Stock Management Research Surveillance Rearing Roe fingerling production cage -pond rearing Harvesting Vessels Gear Skills capacity Marketing Sellers Buyers Processing Fresh fish Sun dried Smoking Freezing Support Sectors Boat Canoe Building fuel supply cage construction kiln construction
refrigeration transport cold store management Legal Enforcement Financing Investment in all elements Infrastructure Harbour wharf processing plant construction
612 Evaluation Criteria The environmental and social assessment has been undertaken using a matrix (See Annex 114) which analyses the key sectors and activities of the fishing industry and the changes that are envisaged against a set of evaluation criteria Evaluation Criteria are broken down into environmental and social issues distinguishing between beneficial and adverse effects Table 61 below shows the relationship between the groups of criteria Table 61 List of Evaluation Criteria
Environment Social
Positive Adverse Positive Adverse
bull Sea bed rejuvenated
bull Fish stocks recovered
bull Biodiversity enhanced
bull Sea bed degraded
bull Fish stocks reduced
bull Biodiversity reduced
bull Increased harvest (catch volume)
bull Increased catch value
bull Reduced costs of inputs
bull Increased profit
bull Enhanced livelihoods
bull Increased job opportunities
bull Increased local economic multiplier
bull Reduced harvest (catch volume)
bull Reduced catch value
bull Increased costs of inputs
bull Reduced profit
bull Reduced livelihoods
bull Reduced job opportunities
bull Reduced local economic multiplier
The assessment process has involved systematically considering each sectoractivity against the evaluation criteria and recording either positive or negative results by drawing on the judgement of the consultancy specialists The findings are discussed in the paragraphs that follow and are reflected in Table 81 forming part of the Draft Environmental and Social Management Plan
62 DETAILED ASSESSMENT OF THE MARINE AND AQUACULTURE SECTORS
47
TunaIndustrial fleet streamlined and catch per vessel improved At present industrial trawlers have to travel increasing distances to fishing grounds and while the level of catch is remaining broadly static costs are increasing against available economic returns A major shortcoming is lack of investment in re-equipping the aging fishing fleet Many of the 90 vessels that make up this sector are increasingly unseaworthy and need to be replaced with modern trawlers and gear The plan is to buy out owners of substandard vessels by offering compensation at market value based on a full commercial survey Vessels remaining in the fleet will be required to meet exacting standards By reducing the number of old and inefficient boats this will allow each of the remaining vessels to catch a higher proportion of fish The aim is to ensure that Ghana is equipped with the latest vessels and technology in order to preserve the countryrsquos position as the hub of the West African tuna fishing and processing industry (see also the section on canneries below) The effect of these measures on the environment will remain broadly neutral since the same number of fish will be caught Providing other policies and increased surveillance are successful in preventing trawling in inland waters the smaller fleet will have to fish in deep oceanic waters This could potentially transfer some environmental effects on fish populations to other parts of the migratory cycle However this would become part of the international effort through fishing quotas to regulate overall catches Reduction in the size of the industrial fleet will mean that fewer men are needed to crew and service the vessels However in practice many men who work in this sector have only part time work and since a significant percentage of boats no longer put to sea the number of crewmen who will be displaced could be in the range of 1000-30003
It will be important to set up support services for those losing their jobs including retraining and welfare assistance where necessary
Decommissioning will necessitate the sale of seaworthy vessels and their removal from Ghanaian waters Other boats will need to be broken up and scrapped This process requires heavy duty specialized equipment and can release significant quantities of waste oil other toxic chemicals including refrigerants and asbestos used in pipe and engine room cladding Measures will need to be taken to ensure that proper environmental and health safety precautions are taken that decommissioning takes place in properly equipped boatyards and that all waste products are disposed of without environmental risk Cannery sector optimized The Fisheries and Aquaculture Sector Development Plan seeks to maintain the port of Tema as the centre of the Tuna canning industry in Ghana At present a proportion of Ghanarsquos tuna catch is diverted to neighbouring countries due to constraints on processing capacity These limitations include poor port infrastructure ageing equipment and delays in handling catch for some operators due to preferential treatment of vessels that are part-owned by the existing canneries Options for improvement include encouraging upgrading of the capacity of one or more existing canneries or promoting more competition in the processing sector and improving the infrastructure Providing modern building designs and construction techniques are employed and a full environmental assessment is undertaken in accordance with Ghanarsquos EIA regulations there should be no significant environmental or social risks associated with these development possibilities The potential economic benefit resulting from encouraging investment in this sector is very high
Industrial fishing excluded from inshore waters A major longer-term intention under the new fisheries plan (FASDP) is to ensure that existing regulations that restrict industrial and semi-industrial vessels from trawling in inshore waters are properly enforced This requires provision of surveillance
3 Based on an average crew of 20
48
equipment fast patrol vessels capacity building and training and increased staffing within Government agencies together with a full programme of awareness raising training and financial support to local bodies providing self-governance under new co-management services Restriction of industrial trawling in coastal waters will greatly ease pressures on fish stocks and reduce environmental damage to the sea bed In time this should lead to healthier fish population with more fish to be caught by the canoe industry as a result However the task of policing and enforcing regulations will not be easy and will take a number of years to bring into full effect Reduction in fishing activity by inshore trawlers will displace a number of crew members and have a short-term impact on dependent families until these individuals are either absorbed into the canoe fleet or find alternative employment There will therefore be a need to assist genuinely deserving cases where crew members (and their families dependents) need to transfer to other sectors of the economy These measures will only be required in the short term since the anticipated improvement in fish stocks will lead to improved economic performance in the canoe sector within which the bulk of employment exists
Expansion of deep water fisheries The fisheries plan notes that there may be a potential for exploitation or increased exploitation of some deep sea fish resources However the status and population dynamics of some affected species is not well known so any such activities should be scientifically monitored through research and enforced by MCS
Tema Secondi Port infrastructure improvements (equipmentbuildings) Under present conditions the transfer of fish from commercial and industrial vessels to canneries is often delayed by the time taken to offload crates and manouvre within the port area where there are conflicting activities There are also difficulties that arise when vessels owned by the canneries are given priority for landing leaving other boats waiting for many hours which can result in quality deterioration At this stage no details are available about the precise improvements that could be introduced and this will need to be investigated as the fisheries plan is advanced Any environmental effects from infrastructure improvements would be contained within the existing port areas and should be largely positive in reducing fuel (energy) costs and increasing overall efficiency It will however be important to carry out an environmental review of specific development proposals at the design stage especially if these involve plans for any dredging or for altering facilities for discharging waste and disposing of bilge water Both of these activities can have damaging effects on the sea bed (The first through dispersal of silt and sediment and the second through release of potential contaminants) Socio-economic effects from the infrastructure improvements should also be beneficial by removing delays increasing efficiency and reducing waste However there could be some slight reduction in manpower requirements leading to the need for skills retraining Regulating the catch (eg Fishing for selected species reducing juvenile catch to improve value of catch in inshore waters) The fundamental aim of the fisheries plan is to reduce the harmful effects on fish stocks and low economic returns from fish catches by phasing out open access for all and introducing regulation of fishing activity This is to be achieved through close cooperation between the Fisheries Commission Monitoring and Surveillance Unit as well as marine fisheries management division and individual fishing communities working together under a co-management framework The practical details will need to be worked out through each individual co-management group and initially the World Bank is offering to assist in the establishment of four pilots These bodies will test exactly what is required to increase fishersrsquo awareness to build capacity in self regulation and agree on appropriate measures
49
From discussion with stakeholders it is clear that while the broad principles are accepted the majority of the fishing community simply do not believe that the new regulations will be enforced because they have witnessed the failure of so many previous efforts to introduce firm management A major issue for the planned programme is therefore how to change this critical mindset without which very little progress is likely to be made in practice It will be necessary to demonstrate through the pilots that by regulating fishing activity direct benefits will accrue to those participating fishing communities Unfortunately efforts to eliminate harmful practices are unlikely to result in an immediate gain in fish stocks Instead catches are likely to fall in the short term It will therefore be essential to introduce other forms of incentive to cushion short term losses Such measures might include the purchase of new nets and gear for sale at subsidized price to local cooperatives the introduction of cash incentives for canoes demonstrating best practice in the use of gear and nets preservation of the catch using ice and landing and marketing fish of the required size and quality As restriction of open access starts to take effect there should be positive environmental gains in terms of improving fish stocks and less damage of the sea bed On the other hand both fishers and fish processors will feel the adverse temporary effect of reduced catches These social and local economic impacts will need to be monitored closely and assistance provided to help foster alternative livelihoods Cephalopus (Octopus) harvesting encouraged in inshore waters Although most fish species are currently exploited to unacceptably high levels within coastal waters there is a specific opportunity to increase the number of octopus caught by pot fishing This fishery could be developed by both the semi-industrial and canoe sectors Taking octopus in pots would have no adverse physical impacts on the sea bed and could allow very slight expansion in fish species that are preyed on by octopus At the same time it is important to note that there is only limited information on species composition and functioning of selected marine habitats including those of the octopus and more research should be undertaken on this and other species that could be selected for expanded fishing activity There would be clear socio-economic benefits arising from the creation of this new fishery Focusing fish landing at specific landing sites (to improve opportunities for subsequent marketing processing) Plans are already being developed for the enhancement of landing and processing facilities at a number of existing locations along the coast These locations include the construction of harbours at Jamestown and Elmina and development of landing sites at Teshie Ada Axim Dixcove Winneba Mumford SenyaBeraku Gomoa Fetteh Moree Keta Dzemeni and Tapa Abotoase Two sets of issues need to be considered in relation to these improvements all of which affect existing fish landing and processing sites The first is the nature of the physical works and infrastructure and it s potential effect on the marine and terrestrial environment The second is the socio-economic impact Both Elmina and Jamestown are long established fishing ports where the catch is landed either directly onto the beach or shallow wharves It is understood that the primary aim of the improvements will be to increase the area of permanent wharves to make it easier for fish to be offloaded to reduce the time taken in transferring stock to processing plants and to introduce modern technology In the case of other smaller landing sites the scale of improvements will be quite modest involving improvement to existing short stretches of access road the erection of stores for nets and other gear and provision of covered areas to provide shade for net-mending With all proposals for physical infrastructure development there will be a need to consider possible
50
environmental implications Due to the existing nature of these sites there are no major industrial or other commercial processes in the vicinity which could give rise to cumulative impacts including contamination of fish products The scale of plant needed for ice-making and storage and commercial smokeries is commensurate with the artisanal nature of the fishing activity itself and would not give rise to any significant environmental effects on air or water quality Harbour works could potentially involve some small scale dredging (for example the removal of accumulated silt) Where dredging is required it will be important to identify disposal areas (either at sea or on land) where silt can be deposited without damage to sensitive habitats In terms of economic and social impacts it is not clear at this stage who are likely to be the major investors from the private sector although it may be assumed that existing operators who have access to finance will be the main beneficiaries Over time as landing marketing and processing become more efficient it is possible that individuals in the traditional fish smoking sector will lose a significant proportion of their trade as the product switches to fresh or frozen fish sales for transfer to the major urban markets and the beach price for fish rises The draft Ghana fisheries and aquaculture sector development Plan notes in annex 2 that proposed facilities associated with the ports and landing sites may not have support from fish mammies or at least formidable commercial advocates able to resist any opposition from that quarter Inspection of major fish landing areas like Elmina and Sekondi indicates that the existing social and commercial structure of support activities to fish harvesting is very complex and involves almost every member of the community including children and the elderly Such activities include net mending boatbuilding metalworking (for cooking pots stoves and grills supplies (ropes weights tar paint wood) fuel supplies ice crates transport etc Leaders of the fishing community confirmed that in principle the improvements of facilities is welcomed provided that safeguards are in place for those who may lose part or all of their current trading activity through rationalisation Stabilise fleet capacity at a sustainable level Fishery experts consider that there would be significant benefits in reducing the number of canoes from the present 10000-12000 to around 8000-9000 which correlates with the number operating in the mid 1990rsquos when catches were at optimum levels At the same time the Fisheries and Aquaculture Plan stresses that the canoe sector will remain at the heart of the Ghana fishing industry and this has strong political enforcement Consequently there is unlikely to be any enforced reduction in the number of canoes holding licenses and owners of all existing canoes will be able to register their vessels The ability of canoe owners to pay annual licence fees should rise as the overall measures to increase efficiency and improve catches take effect However many people anticipate that over time as the annual cost of holding licenses rises less efficient fishers will sell their licenses (and hence their rights to fish) There may therefore be a de facto reduction in the size of the canoe fleet Even if numbers do not decrease the fleet could be stabilized at its present size by taking a decision not to grant new licences The draft plan discusses the fact that under existing law (section 53) there is a requirement for licenses to be issued on demand (presumably to ensure that Ghanaians are not barred from subsistence fishing) It is argued in the plan that this is a misconception since canoe fishing is largely a commercial activity and it is concluded that lsquoit is therefore essential that the number of canoe licenses can be controlled in future and the legal basis for these controls must be reviewed as a matter of priorityrsquo Decisions of this nature will require the full support of local co-management groups if they are to be effective but committees could easily come under pressure to make exceptions as the coastal population continues to rise and families without alternative livelihoods start lobbying for assistance
51
Accusations of preferential treatment of certain individuals by committees (or committee officials) - possibly linked with suggestions of bribery and corruption -could cause a lot of social tension and start to undermine community trust in the need to work together to improve fisheries management It is therefore most important that the detailed proposals for co-management address this risk and include proposals for mitigating individual hardship of the less advantaged ndash for example by offering voluntary retirement with some form of incentive Influencing marketing to maximise value and reduce post harvest losses (marketing cooperatives strong market structures etc) FAO has estimated that physical post harvest losses in Ghana amount to between 3 and 17 of smoked fish production and 16-20 of gillnet landings The plan notes that introduction of lsquonew generationrsquo small scale fish smokers should be introduced to replace the traditional Chorkor model This would improve fish product quality by eliminating charring of fish over open flames and also protecting operatorsrsquo eyes from the damaging effect of smoke and particles The other major improvement in post harvest value and profits would arise from greater use of ice throughout the supply chain Developing Aquaculture A distinction needs to be made between aquaculture development in ponds and dugouts which are self-contained and fish rearing in cages within open water In the case of farm ponds the commercial rearing of fish is little different to other forms of intensive livestock rearing Providing there is no direct connection to rivers and streams there is little likelihood of interaction between farmed and wild stocks which could spread fish infections and parasites In the case of fish farms in open water (rivers and lakes) there are well known risks of the spread of disease which can arise if overstocking occurs Intensive feeding of large numbers of fish in a confined area can lead to significant deterioration in water quality through the build up of nutrients from wood and waste It is also possible for antibiotics and growth hormones to be dispersed beyond the area of farm cages Genetic modification of farmed fish can also affect the local fish population through escapes All of these issues are capable of being managed and mitigated through good initial planning and design and subsequent maintenance and supervision It will therefore be necessary to develop additional regulations and guidelines specifically for the aquaculture sector 63 SUMMARY OF ENVIRONMENTAL RISKS AND OPPORTUNITIES Review of the full range of governance and development activities suggests that there are no high levels of risk to the marine or littoral environment Successful implementation of the Policy and plan should in fact result in very significant environmental gains Over a timespan of 5-20 years five activities in particular should result in significant improvements in the condition of the sea bed in coastal waters (to a depth of 30 metres) reestablishment of benthic flora and niche habitats increased fish stock and enriched biodiversity These interlinked activities are bull The exclusion of industrial vessels and trawling within coastal waters bull Regulation of fish catches through zonation seasonal control of fishing and standards for vessels
gear bull Stabilisation of the fishing fleet within sustainable harvesting yields bull The adoption of management plans formulated and agreed with full cooperation of local
communities bull The introduction of fishing rights through co-management agreements and bull Well planned consultation and information dissemination throughout the fisheries sector
52
Three components of the development plan have been identified where minor to moderate risk to the physical and biological environment could arise if proper design and implementation standards are not adhered to These relate to bull A potential risk of over-exploitation of new catch species in deep water off the continental shelf if
such development is not accompanied by through research to establish the sustainable yield of target species
bull Strictly localized effects on the physical environment from construction of landing wharves or jetties and other harbour facilities and
bull Infrastructure development at the existing ports of Tema and Takoradi All of these risks are capable of being fully managed by improved governance in the fishing sector and EIA procedures that are well-established in Ghana 64 SUMMARY OF SOCIO-ECONOMIC RISKS AND OPPORTUNITIES Implementation of the Plan Project will bring about substantial change in the fisheries sector and over time increased revenue reduction of post[harvest losses and added value to fish products will bring major economic returns At the same time there will be some individuals who do not participate in direct gains and whose livelihoods could be adversely affected if appropriate safeguarding measures are not put in place The level and extent of these socio-economic risks will be determined by 1 the level of commitment that is entered into by Government and its development partners to
deliver incentives to vulnerable and disadvantaged groups and 2 the speed with which the sector is transformed Rapid change could cause significant
displacement of less-efficient operators especially within the semi-industrial and canoe sector which would have serious ramifications for dependent communities However these effects can be marginalized if the development programme is carefully phased to ensure that alternative livelihood and employment incentives are available
The main risks to local livelihoods relate to the potential for bull loss of employment for crews of unseaworthy obsolete vessels ( from all sectors including
industrial semi-industrial and canoes) that are withdrawn from the fishing fleet because they no longer comply with license regulations
bull the inability of vulnerable and disadvantaged groups including artisanal fishers vendors and individual fish processors in small fishing villages to adjust to new market conditions at selected landing sites
53
CHAPTER 7 ASSESSMENT OF POLICY OPTIONS
71 INTRODUCTION
In order to place the significance of the environmental and social safeguards assessment in context this chapter examines the possible consequences of different policy responses to the existing challenges that face the fisheries sector in Ghana These different policy responses range from a continuation of the status ndashquo effectively a ldquodo-nothingrdquo option (A) to full-scale commitment by all stakeholders to achieving a sustainable fisheries future the ldquoOptimum Solutionrdquo option (C) Various less sustainable outcomes lie in between these two ends of a continuum of policy choices and these are represented by the ldquoWeak Solutionrdquo option (B) 72 OPTION A ndash DO NOTHING Background research and discussion with stakeholders indicates that practical capacity to deliver on clearly stated national goals for sustainable fisheries livelihoods and the reduction of poverty is weak This situation exists despite the fact that Ghana has a strong legal framework for management of its fisheries including the Law Policies and Regulations There is inertia and strong resistance on the part of the majority of players to accept that it is largely their own actions which are responsible for present conditions This in turn leads to the attitude that it is only the lsquoGovernmentrsquo that must act by providing increased subsidies and cushioning the industry against further deterioration in catches Unfortunately there is overwhelming evidence from around the world that where fish stocks are exploited beyond their natural capacity to regenerate this can lead to sudden and near-total collapse Ghana has historically been one of the strongest fisheries in West Africa but the signs are ominous that current levels of exploitation are leading to progressive decreases in annual catches for most species in both marine and inland waters As fishing effort intensifies with an increasing number of all types of vessel using illegal methods and inappropriate gear the distinction between the traditional lsquopeak season and lean season (linked to migration patterns breeding cycles and upwelling) is becoming blurred This is clearly illustrated by a statement from one of Elminarsquos fish mammies ldquowe use to smoke the herring in the peak but now the fishers bring them all the yearrdquo Use of monofilament nets light dynamite and chemicals to obtain fish in the lean season is aggravating a situation where too many boats are chasing too few fish Many fishers blame the reduction of catch on global warming for increasing water temperature the emergent oil and gas industry for restricting access to traditional fishing grounds and industry and urban development for increasing pollution leading to deterioration in water quality Each of these assertions warrants careful consideration but the industry is generally in denial when it comes to the primary fact ndash too many fish including juveniles are caught to allow regeneration of the stock In addition weak governance and lack of resources to ensure implementation of policy result in a situation where the law can be ignored with impunity If collective failure to recognize the seriousness of the current position and lack of commitment to taking hard decisions continues the omens for the future are not good Within a period of 10-15 years fish catches could fall by 50 or more from their present level Impacts on each species would vary and catches of some fish with regional or global migration patterns could remain viable (although this depends on the international conservation effort) On the other hand stocks of fish that provide the mainstay of local food resources herring and sardine could be decimated
54
Complete collapse of all fish species is unlikely but it is possible to envisage a situation where catches might fall below 300000 tonnes a year by 2025 (a reduction of more than 25 from present levels) The most serious consequences would be felt as a result of the social and local economic impact on fishing communities Perhaps 30000 men representing the crews of 3000 canoes and semi industrial boats and 15000 women engaged in marketing and processing would lose their present livelihoods Population migration away from the coast could follow and severe social pressures and local economic hardship This is clearly a ldquoworst caserdquo scenario and if conditions were to worsen gradually it might be possible to intervene but the fact has to be accepted that fish stocks are dynamic and subject to rapid decline (as in the case of the North Sea Herring and Atlantic Cod) 73 OPTION B THE lsquoWEAKrsquo SOLUTION The bleak future painted in Option A is unlikely to arise if the present policy and draft fisheries development plan is followed since these are specifically directed to addressing the major challenges However realization of the aims is dependent upon delivery across a wide range of initiatives by multiple stakeholders The following paragraphs illustrate some of the ways in which delivery of policy objectives might be thwarted These may be summarized as
bull Commitment to good governance and institutional reform bull Political resolve to implement unpopular measures bull Availability of adequate technical and financial resources bull Inertia to necessary changes in fishing practice
Good Governance and Institutional Reform Fundamental reforms are required to fully equip the national fisheries management effort at government level This includes introduction of change management clarification of responsibilities for senior staff rationalization of financial management systems provision of equipment expansion of staff numbers additional training and capacity building As an illustration of the extent of the effort required reference can be made to just one topic area the issue of monitoring control and surveillance At present the Fisheries Commissionrsquos MCS Unit has only 10 employees to oversee implementation of the fisheries regulations throughout Ghana This number will be increased as other institutions are engaged in joint monitoring initiatives but it is obvious that staff numbers and capacity will need to be expanded if regulations on fishing activities are to be affected Enforcement is only one part of the equation however Much greater emphasis will need to be placed on voluntary controls and self-policing at community level through Co-management schemes
Failure to press ahead with governance and institutional reform could delay the process of introducing and registering licenses which represents a crucial first step in moving from open access to managed access in the fisheries sector Given the urgency for action the five years allowed in the current plan for completing the registration process seems very generous Political resolve to implement unpopular measures Stakeholder meetings have confirmed the significance of party political influence as a constraint on achieving progress in the reform of the fisheries sector The offer of incentives like subsidies or the promise of new facilities and equipment are regularly employed by individual politicians to garner votes whether or not these form part of party manifestos Examples have been quoted to the consultants where enabling regulations that might restrict fishing access and prove unpopular amongst the fishing community are quietly ignored and officers may be discouraged from pursuing breaches of the law where the offender has political influence These issues arise with governments of all political
55
persuasions and can apply at all levels from District Assemblies through to regional and national committees
A serious issue with fisheries sector reform is that once actions have been taken to conserve fish stocks it may be years before the full benefits are felt and the results are evident in terms of increased catches This makes it harder for governments to institute unpopular reforms ndash even though these are in the best interests of the nation fishing communities and individuals Fishermen and their families are used to seeing an instant lsquosame day returnrsquo on their catch and are less willing or able than stakeholders in other economic sectors to wait for gradual improvements There is an urgent need to establish cross-party support for the fisheries sector in Ghana and to seek agreements between the main political parties to support established policy and regulations where these are in the interests of delivering sustainable fish stocks Availability of Technical and Financial Resources The process of moving from complete open access to restricted use rights for both marine and inland capture fisheries will take many years to complete Progress will be heavily influenced by the level of political will availability of technical assistance and financial support Existing subsidies (pre-mix fuel and import tariffs) are seen as a deterrent to the encouragement of more efficient business practices However in order to reduce dependencies on these forms of government aid there is also a need to underwrite new forms of economic enterprise by giving help to start-up businesses developing training centres and promoting alternative livelihoods for those individuals who are either displaced or voluntarily give up work in the fisheries sector Inertia to Change Traditional fishing practices are quite literally a way of life for many Ghanaians and have been handed down from generation to generation These traditions are closely interlinked with cultural practices and power and influence resides in specific families with hereditary authority In order to change attitudes and gain acceptance of new approaches to fishing there is a need for a major awareness building and communications strategy targeting in particular the traditional leaders of the fishing industry Without such a plan it will be difficult to break down the internal resistance and inertia towards change The constraints that have been outlined above in relation to the lsquoweakrsquo option are very real and in combination they present a serious barrier to progress It will require real political commitment on the part of Government and strong financial support from international partners to break down these barriers 74 OPTION C THE lsquoOPTIMUMrsquo SOLUTION
The new Draft Fisheries and Aquaculture Plan together with the Act and Policies provide a solid foundation for revitalising the fisheries sector in Ghana However for the reasons discussed in relation to options A and B above there are a number of impediments that need to be overcome In addition to the measures in Option B an ldquoOptimumrdquo solution would also include
A coherent mix of Incentives (carrots) and Regulation (sticks) A top priority in developing existing strategies and plans will be to ensure that measures are in place to offer encouragement and practical assistance to fishers to convert to more sustainable practices while at the same time introducing effective enforcement There are some real challenges with both of these goals
56
New forms of incentive need to be developed to convince boat owners and their crews that it is worth their while to drop illegal methods (dynamiting use of monofilament nets etc) and to reduce the level of fishing effort (through close seasons introduction of restricted zones etc) Without these incentives it is highly unlikely that there will be significant take-up of the fisheries stock management and conservation message Special attention needs to be given to the role of chief fishermen and local community councils in developing effective local policing since it is impractical to rely on a national MCS team to regulate canoe activity in either the marine or inland capture fisheries The national MCS team will have its own responsibilities for policing local and international waters in relation to industrial and semi-industrial sized vessels Integrated Coastal Development The long term success of the fisheries strategy depends upon reducing fishing effort to a level at which catches become both sustainable and profitable for those who remain in the business This in turn requires that those displaced from the industry are able to find gainful employment and livelihoods in other sectors of the economy The fisheries industry is often seen as a separate economic sector which attracts its own funding and support but in order for the necessary reforms to take place these attitudes will need to change A new approach is required to lsquointegrated coastal developmentrsquo following the lessons from integrated rural development Many fishing inland and marine fishing communities are almost wholly dependent on fishing with less than 10 of the local economy being devoted to other industries Reform of the fishing sector therefore requires that as much ndash if not more ndash effort is devoted by government and its international partners to building up complementary economic activities in construction transportation manufacturing food processing environmental conservation and tourism There is a need to explore new state industry partnerships to establish appropriate economic development agencies and to coordinate activities between relevant state institutions ministries and departments under the current decentralisation initiatives with district assemblies taking a prominent role If initiatives of this sort are taken forward it will make the task much easier in persuading conservatively ndashminded fishing communities that they need to simultaneously develop their own entrepreneurial flair and impose their own discipline
57
Chapter 8 DRAFT ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK (ESMF) 81 INTRODUCTION Previous chapters of this report have described the principal environmental and social impacts that are likely to arise from reform in the fisheries sector This chapter sets out the Framework (ESMF) for an Environmental and Social Management Plan (ESMP)The first step has been to outline specific objectives to be achieved through implementation of the ESMF These objectives relate specifically to the issues described in earlier chapters Subsequent sections of the chapter detail the measures which are required to respond to specific areas of environmental and social impact through mitigation and amelioration works They also describe the types and level of environmental monitoring required together with the institutional aspects which need to be improved in order to support the fisheries sector 82 STRATEGY AND OBJECTIVES The basic aim of the environmental and social management plan is to set out guidelines for participatory programs under which members of local fishing communities and civil society in general can become involved in the design and implementation of local fishery co-management maintaining sustainable local livelihoods and achieving local monitoring of fishery efforts The basic principle for future fisheries management is that both marine and inland waters will be demarcated as territories for use rights to fisheries (TURFs) The principal goal of government policy in the fisheries sector is to ensure that the fisheries industry plays an increasingly important role in supporting the growth of the economy as outlined in the Ghana poverty reduction strategy (GPRS II) and the Republic of Ghana fisheries and aquaculture policy This goal will be supported by implementation of the fisheries and aquaculture sector development plan over the next five years In this timescale the aim will be to bull improve management of fisheries the conservation of aquatic resources and protection of the
natural environment bull promote value addition in the fisheries sector and the improvement of livelihoods in fisheries
communities bull encourage sustainable development of aquaculture bull improve the services provided to the fisheries sector by the fisheries commission and supporting
institutions The overall consequences of this strategy and the investments that are being made by the government and its aid partners will be stabilisation of fish stocks and sustainable catch levels a strengthening of the national economy and creation of a more robust fisheries industry with consequent benefits for fishing communities Impact assessment confirms that the result will be significant benefits for the marine environment and local economy However depending on the rate of transition from an open access to a fully regulated market a number of adverse effects could arise unless appropriate mitigation measures are put in place Specific issues which require attention in this plan are listed below bull potential risks of environmental degradation through development of new fishing targets in
deep water
58
bull localised environmental impacts at construction sites bull loss of resources for individual operators due to restricted or controlled access to fishing
grounds bull displacement of labour from crews of vessels that are withdrawn from the industrial and semi-
industrial fleet bull Decommissioning of obsolete industrial vessels may not necessarily lead to recovery of fish
stocks Catch Per Unit Effort (CPUE) may increase This could lead to loss of livelihoods to crew members and the owners of the decommissioned vessels it could increase catch for the few vessels remaining in the system
bull increase production costs due to idling time in closed seasons for fishing bull exclusion of some groups and individuals seeking entrance to the industry following completion
of licensing bull concentration of processing and marketing at selected landing sites leaving Fish Mammies and
their dependents in other smaller fishing communities at an economic disadvantage bull displacement of traditional canoe building and other ancillary support industries by more
efficient and modern methods of construction and the inability of some workers in these trades to train and re-skill in the use of modern materials
bull lack of employment opportunities in alternative sectors The ESMF will set out specific actions to address these concerns through a coordinated set of interlinked proposals as follows 1) Preparation of local management plans and close surveillance of all new fishing enterprises in
deep waters
2) Preparation of environmental protection clauses to be included in all contracts and agreements for physical development work
3) Regular inspection by environmental protection officers of construction work at harbours and landing sites
4) Establishment of community management plans to provide support to those groups and individuals who are adversely affected by any of the measures listed above
5) Creation of community liaison groups to actively support community development alternative livelihoods and conversion to new areas of economic activity for those Fisher families or individual fishers who are adversely impacted
6) Introduction of skills training centres and business advice for small and medium enterprise development
7) Establishment of a coastal development agency drawing on the resources of the ministry of local government agriculture and tourism (others to be added) to coordinate integrated projects and initiatives for economic development linked with the existing coastal zone management plans
8) Creation of a liaison group between the government of Ghana and its international development partners to ensure that investment in the fisheries sector is targeted in the most effective way to deliver plan objectives and avoid duplication of effort
59
83 COMPONENTS OF THE ESMF The following paragraphs provide a summary of the draft ESMF 831 Local Management Plans these plans will be prepared for discrete zones of influence around specified fishing settlements Each plan will contain the same standard list of relevant activities that are to be monitored 832 Environmental Protection In relation to construction activity a checklist will be prepared identifying precisely what level of environmental scrutiny is required for specific types of development This checklist will be prepared by the Fisheries Commission with the support and advice of the Environmental Protection Agency 833 Small-Scale Project Development and Livelihood Restoration a list of potential micro-projects will be prepared by the Fisheries Commission which are regarded as suitable for support funding Demand for these micro-projects will be determined at the local level (ie in villages and fishing communities) Applications for funding of micro-projects will be submitted to the community liaison group for vetting and recommendation based on pre-established eligibility criteria Recommended projects will be referred for formal approval at national level (or through the Coastal Development Agency) 84 POTENTIAL PROJECT IMPACTS ON ASSETS AND LIVELIHOODS The project will have some adverse impacts on assets and livelihoods Therefore provisions will be made under the ESMF to minimize all such impacts including those of socio- economic significance and on any environmentally sensitive sites Provisions are also made in the RPF to accommodate all potential situations including cases that may entail actual displacement and livelihood restoration assistance in accordance with the Governmentrsquos policy and World Bank Policy on Involuntary Resettlement OP412 (see Chapters 9 and 10) The potential social and environmental impacts associated with the project (see Chapters 5 and 6) are summarised in Table 81 and the approach to related mitigation measures is defined in section 85 and Table 82 below
Table 81 Potential Environmental impacts and Social issues
Type of Activity Description Environmental Significance
Social Significance
Decommissioning of obsolete industrial vessels
Scrapping of vessels may release toxic waste (contaminated oils asbestos pipe wrapping and insulation etc)
Contamination of landfill dumps
Related health hazards
Laying off of work force Recovery of fish stocks in areas currently over-fished by trawling
Decommissioning of excessovercapacity would result in loss of livelihoods for crew members
60
Plan for fishing capacity reduction
introduction of licensing system for canoes and enforcement of licensing system for semi industrial vessels
Reduced catch from the decline in the use of prohibited fishing methods (activities) as stipulated in the Fisheries Regulation 2010 (LI1968) eg use of light dynamite etc
Reduction in fishing capacity should lead to significant recovery of fish stocks with long term benefits for all
Short term reduction in fishing effort and increased regulation may prejudice vulnerable sectors (illiterate elderly fishers) Capping on new entrants may remove the safety net opportunity offered by fisheries to would-be fishers who may be without alternative livelihoods
Harbour development and landing site improvements
Construction of access road improvements Erection of fish processing and ice making plant The Project could give rise to a small level of physical displacement for some sectors of individual communities
Removal of shelters homes Displacement of boat repair and trading sites for local community
Possible non-voluntary resettlement including vulnerable groups (women children and the elderly)
Adaptation Strategies to climate change
Introduction over time of regulations relating to fishing activity in rivers lakes estuaries lagoons and lsquoareas of upwelling affected by climate change
Measures to combat tackle rising temperature and other climate induced changes should ameliorate environmental impacts
Both beneficial and adverse effects may result from changes in climate (eg faster growth rates from higher water temperature spread of invasive species)
Establishment of exclusion zones ndash oil production and marine protection areas
Restrictions on fishing in oil production areas and marine protection areas
Positive ndash recovery of fish stocks but also potential risks of pollution from oil leaks and human waste
Temporary loss of livelihood for those fishers displaced from lsquotraditionalrsquo fishing grounds
Development of Co-Management System
Creation of 4 pilot Stakeholder ndashbased Fisheries Management Initiatives
Demonstration of practical benefits for the marine environment resulting from elimination of damaging practices
Greater social cohesion and sense of purpose established
61
Type of Activity Description Environmental Significance
Social Significance
Support for PAPs Establishment of enterprise training programmes
Development of criteria for defining Project Affected Persons (PAP) Development of skills training schemes enterprise allowances alternative livelihoods fund
Major benefits for PAPs ndash but scope for misinterpretation mismanagement of programme at local level Jobs created under social significance should be familiar to the fishers ie things they will be willing to do
Developing Compliance Systems
Establishment of enforcement unit and development of facilities and training for participatory coastal surveillance of small-scale fisheries
This component will greatly improve controls over environmentally unfriendly damaging activities
A number of new jobs should be created under this programme
Improvements in fish processing technology
Development of more efficient fish processing plant
This measure should reduce significantly the proportion of fish lost or degraded post harvest Improved fish processing technology will also reduce wood used from the forest as firewood for fish smoking
Potential displacement of vulnerable groups (women children and the elderly)who currently participate in fish drying curing using basic equipment
Construction of fish ponds
Expanding areas of dug-outs and other farm ponds
Small scale impacts on vegetation stream flow
Displacement of existing land users
Catalysing aquaculture development
Encouragement of larger fish farming enterprises Installation of fish cage aquaculture
Localised deterioration in water quality increased nutrients leading to eutrophication potential spread of fish parasites disease
Potential competition with free capture fisheries displacing vulnerable groups in existing fishing villages
62
85 PROPOSED MITIGATION MEASURES AND COST ESTIMATES Mitigation measures The potential environmental and social impacts to be addressed within the context of preparing this Environmental and Social Management Framework are generalized as shown in Table 82 below It is not possible at this time to prepare specific mitigation measures It is expected though that environmental and social assessment studies will be carried out within specific localities as and when required The framework for compensationresettlement (See Chapters 9 and 10) will then be applied incorporating (1) specific institutional arrangements (2) resettlementcompensation eligibility criteria (3) implementation procedures (4) financial responsibilities and (5) monitoring and evaluation plan Livelihood restoration measures Furthermore the livelihood restoration measures will consider issues such as
(1) income levels of affected persons
(2) other non-monetary sources of livelihood
(3) constraints and opportunities for income generation
(4) number of persons not able to revert to previous occupation and
(5) existing skills of affected persons
Table 82 Proposed mitigation measures for some potential impacts
Type of Impact Description of mitigation measures
1 Decommissioning of obsolete industrial vessels
a) A register will be prepared of all industrial vessels that are due to be decommissioned recording the owner and location of each vessel b) A system will be introduced for tracking progress on decommissioning including the means of disposal and measures taken to dispose of all potentially toxic or hazardous materials c) Persons who lose their job or livelihood as a result of a decision to decommission any particular vessel will be entitled to benefit from the skills training schemes enterprise allowances alternative livelihoods fund being developed
2 Plan for fishing capacity reduction
a) A full Social and Environmental Impact Assessment will be carried out on the Plan for fishing capacity reduction and appropriate measures for ameliorating and mitigating adverse effects on affected sectors of the community and PAPs will be incorporated in a revised edition of this Fisheries Environmental and Social Management Framework
63
3 Harbour development and landing site improvements
a) All harbour development proposals will be subject to Environmental and Social Impact Assessment (ESSA) in accordance with EPA Regulations b) Proposals for improvement of individual landing sites will be assessed in accordance with the checklist (832) and submitted to EPA for a ruling on the level of environmental assessment that is required which will depend on the nature of the intended works
4 Adaptation Strategies to climate change
a) An adaptation Strategy shall include proposals for mitigating any impacts on the environment or social welfare of local communities
b) Any strategy for responding to potential effects of climate change on the fisheries sector will be submitted to EPA for review to determine whether an SEA or EIA is required
5 Establishment of exclusion zones ndash oil production and marine protection areas
a) Proposals for restricting access of fishing vessels to oil production areas and marine production areas shall be subject to an Environmental and Social Assessment which shall be submitted for approval to EPA b) In the event that restrictions are likely to adversely affect fishersrsquo livelihoods the provisions set out in 7 below will apply
6 Development of Co-Management System
a) Development of co-management systems will require full cooperation and engagement of all stakeholders In the unlikely event that the provisions of any scheme are challenged by local communities there shall be a right of appeal to the Minister of Food and Agriculture and the Fisheries Commission acting jointly
7 Support for PAPs
Establishment of enterprise training programmes
a) Identification of vulnerable people including women children and the elderly and identification of the cause and impacts of their vulnerability shall be established through direct interviews and procedures to be developed as part of 6 above b) A high priority within the Fisheries and Aquaculture Sector Development Plansrsquo first five year programme will be the development of specific proposals for the establishment of skills training programmes and the establishment of enterprise allowances and an alternative livelihoods fund c) The measures outlined in 7b) above will be targeted specifically at PAPs and vulnerable sectors of the community
8 Developing Compliance Systems
a) All proposals for securing compliance with fisheries regulations shall be subject to review by a fisheries stakeholder committee to be established by the Fisheries Commission with the remit of ensuring that the measures themselves and penalties for failure to comply are commensurate with the ability of offenders to make restitution and do not unfairly penalize vulnerable sectors of the community
9 Improvements in fish processing technology
a) All plans and proposals for the introduction of new fish processing technology shall be published and shall include a statement on the likely impact of the project on existing processors within the local community
64
b) Any members of the public who consider they are unfairly disadvantaged by proposals for the introduction of new technology may apply to the local co-management committee to determine whether or not they fall within the category of PAP (see 6 and 7 above)
10 Construction of fish ponds Proposals for the construction of new fish ponds shall be assessed in accordance with the checklist (see section 832)
11 Catalysing aquaculture development
a) All proposals for aquaculture development shall be in accordance with the provisions laid down in Local Management Plans applying to specific TURFs
65
7
CHAPTER 1 INTRODUCTION
11 INTRODUCTION The government of Ghana is embarking on a Fisheries and Aquaculture Sector Development Plan (FASDP) for restructuring its coastal and inland fisheries The aim is to reverse the current trend whereby fish stocks are increasingly diminishing and the current rate of fishing is unsustainable resulting in less productive fisheries increased costs with declining profitability and the risk of exacerbating nutritional deficiencies and poverty within fishing communities To date the government has enacted legislation (Fisheries Act 2002) prepared policies (2008 updated in 2010) and published regulations (August 2010) but the Ministry of Food and Agriculture and the Fisheries Commission lack the capacity and financial resources to implement all of these initiatives The World Bank is therefore considering a supporting programme of technical assistance and finance which will assist with governance reforms the introduction of licensing for all vessels a reduction in the size of the industrial and semi-industrial fishing fleets and the progressive transfer of fishing activity to the canoe sector International support for Ghanas fishing industry is being coordinated under the West Africa Regional Fisheries Programme (WARFP) This initiative began with four countries Cape Verde Liberia Sierra Leone and Senegal It is now being extended to the following countries Ghana Guinea Guinea Bissau and Gambia A process framework has been developed by the Commission sous Regionale des Peche (Based in Dakar Senegal) to assist member countries of WARFP to prepare their own national process frameworks together with accompanying environmental and social safeguards assessment an environmental management plan and resettlement policy This report has been designed to provide the outline structure and contents for these documents on behalf of the Government of Ghana Another important function of the report is to review the application of the World Banks own Environmental and Social Safeguard policy to the planned investment Both the governments development plan (FASDP) and preparation of the World Banks financial assistance package are at an early stage Consequently this report covers (and can only cover) the broad principles and sets out initial conclusions It will be necessary for further reviews to be undertaken when the Government of Ghanarsquos programme has been developed in more detail Objectives of the Environmental and Social Assessment (ESA) The overall aims of planned interventions in the fisheries industry of Ghana are to improve fish stocks and increase the sustainability of fishing activity which will have long-term environmental and social benefits for the country However the process of introducing change is likely to have some short-term adverse effects on individuals and particularly those who are vulnerable or disadvantaged within poorer fishing communities unless appropriate mitigation measures are taken The purpose of the environmental and social assessment set out in chapter 6 is to identify potential environmental and social impacts both individually and cumulatively and to assess their relative magnitude duration reversibility and importance Based on these findings the draft management framework (see chapter 8) sets out proposals for avoiding or mitigating unacceptable change The process of reforming the fisheries sector will take a number of years and the existing FASDP covers only the first five years With the exception of proposals to scale down the size of the industrial and semi-industrial fishing fleets it is unlikely that major changes will take effect in terms of fishing activity during this five-year period Consequently from the standpoint of the World Banks investment there are likely to be relatively few issues in terms of potential conflict with safeguarding policies Later
8
however significant change is within the fishing industry and particularly onshore processing and marketing of fish products An important element in this report has therefore been the need to define the point at which the banksrsquo responsibilities are seen to terminate and all liabilities are transferred to other supporting donors and the government of Ghana In the short term a reduction in the industrial fleet may lead to the loss of 1000 to 3000 jobs for crew members although in practice most of this work is only part time and many of the vessels that are due to be withdrawn are no longer seaworthy In the longer term it is intended to encourage more selective fishing by limiting open and unfettered access to fish stocks eliminating illegal and damaging processes including dynamiting uncontrolled light fishing and the use of small size monofilament nets and introducing seasonal restrictions to protect breeding cycles The intention is that these measures will be managed jointly by the government and communities through co-management systems At the same time major efforts will be made to reduce the level of post-harvest losses and to increase the value of fish products The expectation is that the number of industrial semi-industrial vessels and canoes will be stabilised at a fixed lower level within five years Once this point is reached and no further licences are granted individual licences will acquire higher values especially as fish stocks recover and the size and value of fish catches starts to increase Subsequently licenses are likely to be sold and traded as less efficient owners drop out of the market and sell on to stronger individuals and companies In terms of onshore activities fish landing processing and marketing will become more efficient and losses will be reduced through use of better smokers freezing and drying equipment Previous studies in West Africa and elsewhere (Bennett et al 2001) have shown that the transition away from open access to a more regulated system of access management can give rise to social risks Specifically older men are likely to be displaced when they are no longer fit enough to withstand the rigours of fishing while a rising number of young men may find it harder to enter a career in fishing Women who currently manage or assist with all areas of buying processing and marketing using traditional clay ovens may also experience competition as new companies and enterprises are established to take advantage of higher profitability in the fishing sector perhaps using better equipment newer technologies and different logistics arrangements or their own transportation Methodology This study has followed the methodology developed within the process framework for the West Africa regional fisheries programme (WARFP) Figure 1 sets out both sequence and timescale for the work
The range of jobs at risk is based on assumptions about the number of vessels and average crew size and cannot be determined with any degree of accuracy until the necessary surveys are undertaken
9
The report is based on three major areas of activity 1 documentary analysis and utilisation of the studies already carried out by the fisheries commission 2 meetings with institutional stakeholders principally affected by the project and 3 Consultations and visits to some of the key fishing villages and communities The planned presentation of findings to Stakeholders has been postponed at the Clientrsquos request due to other pressing commitments in the agriculture and fisheries sectors This presentation will however need to be subsequently undertaken by the Ministry and the Fisheries Commission
11
CHAPTER 2 PLAN AND PROGRAMME DESCRIPTION
INTRODUCTION This chapter is divided into two parts Part 1 sets out the progress which the government Ghana is making in giving effect to the legislation policy and regulations Part 2 describes the proposed programme of assistance being offered by the World Bank with the specific aims of strengthening governance and enforcement systems (Components 1 and 2) and in promoting value addition and reduction of post-harvest losses
PART 1- THE DRAFT FISHERIES AND AQUACULTURE SECTOR DEVELOPMENT PLAN (FASDP) This plan (FASDP) covers the period 2010-2015 It recognises the importance of Ghanarsquos fisheries which generate in the order of US$ 1 billion a year contribute 45 to GDP and indirectly support the livelihoods of 22 million people However through over-fishing and lack of investment in management and value addition the average income per canoe has dropped by up to 40 over the last ten years to the point where it costs as much to fish as the catch is worth By comparison well managed fisheries in other parts of the world are capable of generating economic returns of 30-60 on investment (equivalent to a potential income of US$ 300 million a year for Ghanarsquos fisheries) The Draft FASDP acknowledges that the fishing sector is expected to make a substantial contribution towards doubling the size of the Ghanaian economy by 2015 (GPRS II) as part of the Republic of Ghana Fisheries and Aquaculture Policy Seven targets are set in the draft FASDP 1 Maintaining capture fisheries production at current levels 2amp3 Increasing revenue and profitability in capture fisheries by at least US$ 50 million a year after
five years 4 Increasing aquaculture production to 35000 tonnes a year after five years 5 Retaining Ghana as a landing and processing hub for the West Africa tuna industry 6 Developing fisheries management to allow effective control of all commercial fishing effort in
Ghanaian waters and 7 Ensuring fisheries management costs are sustainable and that the fisheries sector overall make a
fiscal contribution to Government revenues There is an underlying presumption that the canoe sector will remain at the heart of Ghanarsquos fishing industry but the plan is not prescriptive and leaves open the ways of achieving the overall goals At the same time there is an underlying assumption that the long term sustainability of Ghanarsquos fisheries will depend upon discouraging further entry by new operators
PART 2 THE WORLD BANKrsquos CONTRIBUTION TO GHANA FISHERIESPLAN (FASDP)
The essential aim of the World Bankrsquos contribution to FASDP is to provide investment which will build the necessary policy and capacity for effective fisheries management designed to reduce fishing effort while maintaining approximately the same catch levels and to address the impacts of change for fishers
12
and the communities in which they live Based on the currently available draft Project Appraisal Document (PAD) each of the components is now described in turn Component 1 - Good governance and sustainable management of the fisheries This component on good governance comprises four subcomponents which are broken down in turn into a number of separate activities Sub-component 11 developing the capacity rules procedures and practices for good governance of the fisheries Activity 111 reviewing the Fisheries Act and developing regulations to support the Sector Policy and the Fisheries and Aquaculture Sector Development Plan Activity 112 Developing an operational policy to enable implementation of the aquaculture and fisheries sector development plan Activity 11 3 strengthening fisheries management systems and capability (fisheries management plan development aquaculture implementation technical support and training) Activity 114 strengthening fisheries Information Systems (catch recording and monitoring systems statistical analysis and training)
Sub-component 12 introducing fishing rights
Activity 121 developing pilot stakeholder-based fisheries management initiatives around defined fisheries units (ie local management initiatives tighter defining fisheries resources in up to 6 selected Fisher communities) Activity 122 introducing and administering a licensing regime
Subcomponent 13 Adjusting fishing effort and capacity to more sustainable levels marine resource conservation and supporting alternative livelihood opportunities when needed Activity 131 vessel decommissioning Activity 132 compensation packages for crew of decommissioned industrialsemi-industrial vessels Activity 133 alternative livelihood development to incentivise voluntary capacity reduction in the canoe sector Activity 134 marine resources management and conservation
Subcomponent 14 social marketing communication and transparency Activity 141 communications stakeholder consultations and awareness raising programmes to support fishery development Component 2 reduction of illegal fishing Under the West Africa regional fisheries programme subcomponent 21 allows for enabling environment for reduction of illegal fishing These provisions already exist within Ghana and this subcomponent is therefore omitted Subcomponent 22 monitoring control and surveillance (MCS) systems Activity 221 developing compliant systems and capability
13
Component 3 increasing the contribution of the marine fish resources to the local economies Subcomponent 31 product diversificationvalue chain development (freshfrozen producttrade facilitation) Activity 311 landing site development Activity 312 Port development Subcomponent 32 fish product trade infrastructure information and systems - regional minimum integrated trade expansion platform (MITEP) Activity 321 export certification centre development Activity 322 fish processing technology improvements Activity 323 national fisheries advisory group Subcomponent 33 marine and inland aquaculture development Activity 331 space developing aquaculture policy and legal framework Activity 332 improving genetic policy of tilapia fingerlings and breedstock Activity 333 catalysing aquaculture development Component 4 Coordination monitoring and evaluation and program management Subcomponent 41 national implementation subcomponent 42 regional coordination Each of the components sub-components and activities are described in more detail in Chapter 5 which assesses the nature of environmental and social safeguards issues in terms of the World Bankrsquos planned investment
15
CHAPTER 3 BASELINE CONDITIONS
INTRODUCTION This chapter discusses the existing fishery resources of Ghana and describes recent environmental and social trends It identifies some of the pressures that led to the reduction in value of fishing activity and indicates the threats that could be posed if no action is taken in accordance with the planned fisheries and aquaculture program to deal with them FISHERY RESOURCES The continental and coastal waters of Ghana are potentially very rich due to a combination of warm waters and nutrients carried in ocean currents which up-well seasonally on the continental shelf The tonnage of fish caught in marine waters peaked in the mid-1990s around 500000 tonnes and currently averages around 400000 t(See Figure 1) Figure 1 Wild Capture Production in Ghana 1950-2005
2
Table31 Top 10 Species Exported (by value)
1 Canned tuna ($72000000) 2 Fresh tuna ($7200000) 3 Tilapia (no figure available) 4 Miscellaneous dried fish ($1000000) 5 Salmonids frozen ($900000) 6 Marine fish frozen ($600000) 7 Cuttlefish and squid ($600000) 8 Shrimps and prawns ($90000) 9 Sardines ($80000) 10 Crustaceans frozen ($50000) Source FAO Fishstat
The principal catch from deep waters is tuna Industrial vessels registered in Ghana target these species in international waters but also illegally in coastal waters Herring sardine and anchovies are fished in coastal waters by semi-industrial vessels and canoes Table 31 shows the top 10 species of fish exported from Ghana in 2005 PROFILE OF THE FISHING INDUSTRY Fishing is of vital importance in Ghana not only in terms of its contribution to gross domestic product (45 per annum) but because fish provides 65 of the countrys protein In recent years (between 2003-2008) and more specifically in 2004 the countryrsquos annual fish requirement has been estimated to be 882000 tonnes of which the country produces just about half (Tetteh 2007) Of the total population of 22 million people it has been estimated that between 15 and 22 million people are employed or gain their livelihoods from fishing (8-10) Of these there are 210000 men who are directly employed as
2 This figure is the Fisheries Departmentrsquos estimate for 2008
16
fishers The total export of seafood was valued US$824 billion in 2005 Ghanas fishing industry can be divided into three sections marine capture inland capture and aquaculture It can be further analysed by scale of operations distinguishing between industrial semi-industrial and artisanal sectors Marine fisheries Industrial sector Commercial fishing for tuna began in 1962 In the early 1980s Ghana sought to develop an industrial fishing fleet and there are currently 90 industrial trawlers and other vessels which are located in Tema and Takoradi Sekondi The port of Tema was expanded from 1962 to create four main areas the Inner Harbour Outer Harbour Canoe Basin and Commercial Area In 1999 fish landing facilities were improved at the Albert Bosumtwi Sam Fishing Harbour built in Sekondi This harbour is equipped with a cold store an ice-making plant offices a berthing bay for inshore vessels a jetty for canoes and a net drying area Under Ghanaian law more than 50 of the ownership of industrial vessels must be registered with a Ghanaian company or individuals However in practice many vessels are owned by foreign nationals with token Ghanaian ownership Relatively few of these large vessels regularly put to sea and a number are in poor condition or obsolete Nevertheless the impact of trawling activities by Ghanaian registered and foreign owned vessels has been very considerable in coastal waters in recent years Fish landed from industrial vessels is usually transferred directly to Canning factories in Tema and Takoradi Ghana has the largest canning industry in West Africa In the region of 30000 tonnes of tuna are landed In addition to trawling some industrial vessels are engaged in shrimping the use of tuna lines and polls purse seining and demersal trawling Semi-industrial sector in addition to deep sea trawlers there are around 230 large semi-industrial ships propelled by inboard motors which are used for trawling in shallow waters during the off-season and purse seining during upwelling seasons There are currently reported to be 48 bottom trawlers 14 pair trawlers 2 shrimpers 33 pole and line vessels and 10 tuna purse seiners operating from 2 of the 7 landing sites Canoe sector Ghanas artisanal fishing sector is based on between 10000 and 12000 wooden canoes Fifty seven per cent of the fleet is powered by outboard motors supported by paddle and occasionally sail Each Canoe carries a crew of between three and 20 men depending on size and length There are over 334 landing sites along the 550 km coast of Ghana and the majority of fish caught by canoe (180000 tonnes) is returned to these sites accounting for 70 of Ghanarsquos fish production The principal landing sites are at Teshie Jamestown Chorkor Shama Axim Elmina Winneba Mumford Akplabonya Adina Atiteti Abutiakope and more Fishing is undertaken by men but the majority of canoes are owned by women who pre-finance fishing trips (purchasing gear and premixed fuel) and purchase the catch Women also predominate in processing and marketing fish and fish products Only about 20 of fish sold fresh a further 20 is salted and the majority (60) is smoked It is estimated that up to 30 of the catch is spoilt through lack of ice for storage or alternative processing facilities
17
Inland fisheries Water Resources Ghanarsquos inland fishery resources consist of a natural lake( Lake Bosomtwe) and nine major river basins which from east to west of the country are
bull the Volta bull Densu bull Ayensu bull Ochi bull Kakum bull Pra bull Ankobra and bull the Tano
The River Tano forms the border between Ghana and Cote drsquo Ivoire The largest of the rivers is the Volta which drains more than two-thirds of the country through several large tributaries in virtually all regions of the country The Volta river system also incorporates the Volta reservoir generally known as the Volta Lake which has a surface area of around 8400 km2 The Volta lake discharges through the Akosombo dam before flowing through a delta into the Atlantic Ocean The eight other river systems are relatively smaller simpler and open more directly into the Atlantic There are also several reservoirs created on the smaller river systems mainly for potable water production irrigation and flood control These reservoirs irrespective of their primary purposes enhance availability of more permanent aquatic habitable space for fish and therefore support some fisheries Finally with all the river systems opening into the Atlantic there are a series of lagoons and estuaries which act as interfaces between the rivers and the sea These water areas constitute another type of inland water resource for salt and brackish water fishes Inland Fish resources Within the inland water resources of Ghana there are over 150 fish species more than 90 of which are fished for food
In commenting on inland fisheries in Ghana it must be noted that virtually all available information on inland fisheries is obtained from the Volta Lake No national fish production records have been kept on the fisheries of the eight smaller river systems and the lagoons and estuaries Thus the usual statement that inland fish production constitutes about 20 of what the country produces should refer to fish production from the Volta Lake In practice the total inland fish contribution could more realistically be estimated at about 30-35 of national fish production This is a very considerable but understated contribution to national food security and nutrition
Fishing vessels The dominant fishing vessel on the Volta Lake is the canoe the majority of which are built from wooden planks On some other river systems while plank canoes predominate a small number are carved as dug-outs from single tree trunks There is some variety in sizes of the canoes depending on how many planks are used to build the boat and the size of tree trunk used in building a canoe The total number of canoes estimated on the Volta Lake during a survey in 2000 was 24035 On the tributary rivers of the Volta Lake and other river systems in the country the planked canoe is the main vessel used in fishing
18
Fishing gear There are about eleven main kinds of gear used for fishing on the Volta Lake They are Gill Nets Cast Nets Hook and Line Basket and wire mesh traps Winch net Beach seine Bamboo Nifa-nifa Wangara Spears and Atidzas On other rivers in the country Gill nets Cast nets Hook and Line and traps are the fishing gear used On both the lake and rivers the Gill net is the main gear
People Involved In the 2000 frame survey of the Volta Lake conducted by the Fisheries Directorate of Ghana the estimate of fishers on the Volta Lake was put at 71861 Fishers on the lake work in collaboration with a host of fishmongers or handlers who also function as wholesalers for individual fishing groups Assuming that the fisher population on the lake has increased by a modest 3 in the ten years from 1998 to 2010 a fisher population of about 93500 could be considered to be on the Volta Lake now If again it is estimated that number of fishers on rivers in the country were to be a tenth of those on the lake this would put the fisher population on inland waters (apart from the Volta Lake) at about 9350 fishers A very conservative estimate therefore puts the total number of individuals who are directly engaged in inland fishing at over 100000 This excludes all directly associated groups such as fish handlers processors and traders An estimate of secondary fisheries operators such as boat builders out-board motor operators and mechanics as well as bulk salt and fuel wood sellers and those engaged in buying selling and distributing fish would have to be considered in developing estimates for both direct and indirect employment in inland fisheries but the number can be assumed to lie between 125000 and 150000 people
Aquaculture Under Ghanarsquos legal framework aquaculture is defined as ldquoany activity designed to cultivate or farm fish and other aquatic living resourcesrdquo Currently only fin fishes are involved in aquaculture in Ghana
Current culture media and environment Currently fish culture takes place almost exclusively in fresh water in Ghana either in cages brush parks or dugouts Dug-outs are excavations made in floodplains in the savannah parts of the country were water scarcity has been a major hindrance to development in general and food security in particular Dug-outs get filled with flood waters and whatever the water carries during major wet periods of a year in the savannah areas Waters that fill Dug-outs invariably contain fish which are trapped in the Dug-out after the wet period These water bodies are managed until the end of the dry period and the fish are harvested before the next flood period Since the 1960rsquos various strategies to augment fish production from Dug-outs have been developed and tested These involve adding fingerlings of selected fish species to those which are lsquonaturally stockedrsquo in Dug-outs by floods Dug-outs are the major fish culture production approach in the savannah parts of the country which accounts for a little more than half the area of the country The Environment of fish culture Currently fish culture is taking place mainly in freshwater environments Brackish water fish culture and mari-culture activities which will bring lagoons estuaries and the sea into fish culture production have long term potential for development Fishes in culture Fishes being cultivated in Ghana In order of importance are Nile tilapia Oreochromis niloticus the African catfish Clarias gariepinus species of the catfish Heterobranchus and the Bony tongue Heterotis niloticus Scale of Culture Based on level of production fish culture operations can be categorized as follows
bull Large scale commercial where an enterprise produces up to 10000 tonnes per year
19
bull Medium scale commercial where a single enterprise produces between 50 and 500 tonnes bull Small scale commercial where an enterprise produces between one and 20 tonnes and bull Very small scale commercial with productions below 20 tonnes
Fish culture production Cultured fish contribution to national production was officially stated as 9000 tonnes for the year 2009 However informed opinion amongst fish farmers indicates that a figure of between 16000 and 20000 tonnes in 2010 would be closer to reality This statement is based on the facts that most producersrsquo published figures are underestimates several small to medium scale producers are not recorded in official lists and the recording of newly established fish farms has lagged actual establishment especially since 2009 Although cultured production up till 2009 may not have been significant considering a shortfall of about 460000 mt (as recorded in 2004) between captured fish production and national demand this reflected the fact that there were only two large scale commercial producers in the country each of which had had less than ten years of operation Anticipated growth in fish culture production within the next five years is expected to be dramatic as some of the critical challenges of the industry are resolved
CHALLENGES AND PROSPECTS Marine Fisheries The fishing sector is vital for food security and job creation to help alleviate rural poverty in Ghana However the levels of fisheries harvests are generally considered to be close to or to have exceeded the maximum sustained yield Future sustainability in the industry will depend upon the restriction of open access to fisheries and the introduction of management systems which allow fish stocks to recover and the establishment of consistent yields in both marine and inland waters Inland Fisheries Environmental conditions on the Volta Lake constitute the major environmental and social challenges for fisheries its sustainability and profitability In terms of future prospects success will depend heavily on implementation of the lsquoGhana Fisheries and Aquaculture Sector Development Planrsquo and the capacity of the system in Ghana to enforce the Fisheries Regulations passed by parliament in August 2010 Aspects of the Development plan that offers great prospects for the lakes fisheries include the provisions for eventually licensing boats (although the scale of this task should not be underestimated) and measures to involve communities in management of fisheries resources of the Lake
Aquaculture The main challenges facing aquaculture development in Ghana relate to bull The high cost of fish feed (significantly due to its importation from other countries) bull None availability of commercial fish hatcheries as enterprises bull Lack of a nation-wide distribution network for fish seed and cultured fish producers Most
sources of fingerlings are concentrated in one part of the country and since farms all over Ghana obtain their fingerlings individually transportation costs add significantly to overall production costs
bull Now emerging certification and monitoring to check the health and safety of aquaculture processes and products
bull The absence of adequate regulations regarding establishment of an aquaculture enterprise until August 2010 (In the absence of regulations only the large and medium scale commercial farms worked towards conforming to international performance Standards and operational regulations for certification of farms and their products still remain in a draft state)
bull Low national support for research to support expansion and systematic development of aquaculture
20
The prospects for development of aquaculture as an industry in Ghana are good since a number of practical policy and legal frameworks have been put in place to resolve the basic challenges to the industry listed above These include
bull Construction of the first local fish feed plant by an international fish feed company with the expectation of having initial products on the Ghanaian market during 2011
bull A lsquoLarge scale commercial fish farmrsquo with great capacity for fingerling production is shifting emphasis to fish seed production And several localized fish seed producers are expanding operations
bull Distribution strategies by cultured fish producers have started to emerge on a limited scale and are expected to evolve with increasing production as existing commercial farms expand and new ones join in
Now that regulations regarding establishment of aquaculture enterprises have been gazetted there is likely to be a positive response amongst fish farmers of all size categories New operational standards are being prepared which will introduce minimum standards for local certification This should set the stage for preparation of fish culture products and the broadening of choice for consumers while also qualifying Ghanaian producers to enter external markets
ENVIRONMENTAL CONDITIONS The coastal and marine environment a critical zone of influence for this study comprises a 550 km coastline a coastal belt ranging from 1 to 20 km in width and coastal waters extending to 200 nautical mile limit which was established in 1977(under the territorial waters and continental shelf act 1973 as amended by the territorial waters and continental shelf amendment decree 1977) The Coastal Belt The coastal belt accounts for only 65 of the land mass of Ghana but it is one of the most densely settled areas accounting for 25 of the population and80 of the industrial establishments in Ghana Historically the coastal zone was cultivated for coconut (copra) but this industry is in decline Vegetables and other agricultural produce are grown on better soils but the principal economic activities are fishing transportation salt production and sand and stone winning Tourism also offers great potential There is considerable expectation that the discovery of offshore oil and gas deposits will bring new wealth to parts of the coastal corridor However present plans to transfer crude products to tankers at sea and then export them directly will limit industrial activity to a support role A high percentage of industrial and municipal wastes is dumped at landfill sites within the coastal zone which creates pollution risks The coastal belt is generally a low-lying area less than 200 m above sea level Vegetation types reflect the rainfall gradient and consist of coastal shrub and Savannah to Winneba southern marginal forest to the east of Sekondi dry semi-deciduous and moist semi-deciduous forest to the east of Cape Three Points estuary and wet evergreen forest in the extreme south Soils are variable within this area ranging from fertile pockets river valleys to Sandy poorer quality soils close to the sea The Coast The coast line divides into three sections (Ly 1980)
bull West of Cape Three Points this area has a wide and flat beaches backed by coastal lagoons and
21
wave heights are generally low bull Between Cape three points and Tema the coast consists of a series of rock headlands enclosing
shallow bays together with sandbars or spits enclosing coastal lagoons The surf zone is a medium to high energy environment with wave heights often exceeding 1 m South-westerly prevailing winds give rise to longshore drift in an easterly direction
bull Between Tema and Aflao most of the shore is sandy although there are rocky outlets The coastal zone is important internationally in providing feeding roosting and nesting sites for thousands of migratory birds Environmental degradation is significant in Ghana and is recognized in the countryrsquos environmental action plan It contributes to rising poverty levels coupled with poor human health and inadequately planned urbanization which fuel a vicious cycle inhibiting human development The core issues include
bull Domestic sanitation bull Increased urbanization without appropriate infrastructure bull Wetlands and mangrove degradation bull Coastal erosion and bull General biodiversity loss
Briefly each of the above could directly or indirectly adversely influence fisheries and aquaculture separately or together For example in a recently completed study of water quality scenarios of the Volta Lake in relation to fish production as a component of a comprehensive study (The Challenge Program Project of Water amp Food) it was concluded among others that poor sanitation in highly populated fisheries communities adversely influenced water quality to the detriment of fish life and thus fish production With reference to aquaculture the same unsanitary conditions in highly populated shore communities adversely influenced water quality especially in terms of oxygen depletion when lake waters extend to the shore in high water periods This is a situation which has caused fish kills in cages because caged fish cannot escape lsquopollutedrsquo waters Degradation of wetlands and mangroves leads directly to a reduction in their capacities as spawning and nursery zones for both marine and inland water fishes which reduce fish production in both environments The situation outlined above is often contributed to by anthropogenic and industrial pollution due to urbanization without appropriate infrastructure Another issue linking human activity to a deteriorating environment is demonstrated by the encroachment of aquatic weeds on inland waters such as the Volta Lake Weed growth is accelerated by farming reservoir catchments which increases nutrient levels and the building of dams which reduce or cut off intrusion of sea water into rivers Currently as climatic change observable impacts such as floods seem to escape predictions The project could possibly contribute to mitigating against direct and indirect effects of climate change on fishing and aquaculture through investment into climate change orientation and education of fishers and fish farmers to mainly influence reasonable precautions they take Marine waters The continental shelf is relatively narrow projecting out to 25-35 km except in the area of Cape Coast to Salt Pond where it extends to almost 80 kms Sandy and rocky substrates which previously supported coral and seaweeds have been severely affected by former trawling activity which indiscriminately
22
dredges material from the seabed Coastal waters are enriched by freshwater discharges from the relatively small number of rivers and by two seasonal up-wellings which occur between late June and early October (the main upwelling) and January and March (the minor upwelling) The origin and driving mechanisms of these up-wellings are not fully understood and both their location and strength varies from year to year
Lake Volta and other inland water
Major environmental issues on the Volta Lake which might also be considered as challenges to sustainable fisheries on the major inland fisheries resource can be summarised as follows
bull The Volta Lake is known to be low in nutrients It therefore has low standing crops of phytoplankton and zoo plankton to support high fish production
bull The northern segment of the lake together with tributary rivers constitute the spawning and feeding grounds for majority of fish species in the lake during the wet season however these segments are intensely fished during the same period
bull The Volta Lake is divided into eight unequal strata with different distribution of boats per Km2 At the last estimation of carrying capacity in 2000 stratum V and II had the highest (527) and lowest(157) number of boatsKm2 respectively
bull The rate of siltation in the lake is considered to be increasing due to erosion associated with high rates of deforestation
bull A major challenge exists in getting fishers fishing communities and fishing entrepreneurs to understand and comply with fishing regulations aimed at conserving fish and fisheries resources
bull There is a lack of resources studies and research to support fisheries management of the Lake
bull High illiteracy exists amongst lake shore communities
bull Open access to the fish resources of the Lake has been in operation since its formation
bull Declining fish yields are occurring in the lake (468 Kgha in 1976 to 320 Kgha in 2003-MOFA) brought about by the constraints listed above
bull The commonly assumed estimate of potential fish production from the lake of around 75500 mtyr) is considered to be a serious underestimate since Stratum VII alone was estimated to produce 33800mtyr in 1996
bull The policy environment for aquaculture is currently strongly supportive of the industry and related enterprises
bull There is good quality and more than sufficient water to allow some kind of aquaculture to be developed in every region of the country with the Volta lake (about 8400 Km2) as the single most important water unit for fish culture Currently it appears that the free access to the fish resources of the lake has to some extent been applied to establishment of small scale caged fish culture enterprises a situation constituting environmental risk to investments of large scale commercial fish culture establishments in the lake
bull The Volta Lake is low in nutrients (Obeng 1964) resulting in a situation where higher fish yields could be sustained if greater quantities of fish feed were available
23
bull In Ghana the Nile tilapia O niloticus occurred naturally only in the Volta system Due to positive culture characteristics of the fish it has been moved into virtually all other river basins in the country The situation provides opportunities for hybridization of the Nile tilapia with other tilapia species native to the river basin into which the Nile tilapia has been moved
25
CHAPTER 4 POLICY AND LEGAL FRAMEWORK FOR ENVIRONMENTAL AND SOCIAL ISSUES
41 INTRODUCTION
Development and implementation of the Ghana Fisheries and Aquaculture Sector Development Plan and the World Bankrsquos supporting program need to be developed with full regard to existing international conventions national legislation policies and regulations This chapter highlights the main legislative and policy considerations for the protection of the environment natural resources fisheries and social and economic development It begins with reference to the World Bankrsquos safeguard framework and those of other donors This is followed by a section on the governance framework in Ghana
42 WORLD BANK AND OTHER DONORSrsquo SAFEGUARDS POLICIES
The World Bankrsquos safeguard policies exist to ensure that all projects which it finances are developed and implemented on environmentally and socially sound principles A range of different policies exist and these have been carefully considered to ensure that the Ghana Fisheries and Aquaculture Development Sector Development Plan complies with these safeguards All policies have been screened and those that have no bearing on the fisheries programme have been excluded from Table 41 below Table 41 lists policies which could have some applicability to the FASDP even if this interaction might be very slight It is important to stress that the comments in the third column of Table 41 relate to the entirety of the Fisheries and Aquaculture Sector Development Plan whose effects will continue to be experienced long after the World Bankrsquos financial support has been expended Most of the activities in the FASDP will have no effect in relation to safeguard objectives and where there are implications these are likely to occur at precise locations (for example at fish landing sites) rather than throughout the industry Where potential interactions have been noted the necessary mitigating measures are incorporated in the Draft Process Framework
Table 41 World Bank Safeguard Policies in Context
Safeguard Policy
Safeguard Policy Objective Brief Description and relevance to FASDP
OP 401 Environmental Assessment
This policy aims to ensure that Bank-financed projects are environmentally sound and sustainable and that the decision-making process is improved through appropriate analysis of actions and mitigation of their likely environmental impacts This policy is triggered if a project is likely to carry potentially adverse environmental risks and impacts on its area of influence OP 401 covers impacts on the natural environment (air water and land)
The majority of actions planned under FASDP will be beneficial to the marine environment and to inland waters However new construction activities could have impacts and depending on the project and the nature of impacts a range of instruments can be used to ameliorate and mitigate adverse effects while enhancing beneficial effects These include EIA environmental audit risk assessment and environmental management plans (EMP) The need for EIA and EMP is considered in this report
26
OP 404 Natural Habitats
This policy recognizes that conservation of natural habitats is essential to safeguard their unique biodiversity and to maintain environmental services and goods for human society and for long-term sustainable development The Bank therefore supports the protection management and restoration of natural habitats in its project financing as well as policy dialogue and economic and sectoral work Natural habitats comprise many types of terrestrial freshwater coastal and marine ecosystems They include areas lightly modified by human activities but retaining their ecological functions and most native species
This policy is triggered by any project (including any sub-project under a sector investment or financial intermediary) with the potential to cause significant conversion (loss) or degradation of natural habitats whether directly (through construction) or indirectly (through human activities induced by the project) This policy is applicable to the Ghana Fisheries Programme because the project focuses on the integrated management of natural habitats However by screening all proposals under the ESMF any sub-projects that might impact these habitats will not be funded
OP 409 Pest Management
The objective of this project is to (i) promote the use of biological or environmental control and reduce reliance on synthetic chemical pesticides and (ii) strengthen the capacity of the countryrsquos regulatory framework and institutions to promote and support safe effective and environmentally sound pest management
The policy is triggered if (i) procurement of pesticides or pesticide application equipment is envisaged either directly through the project or indirectly through on-lending co-financing or government counterpart funding (ii) the project supports an activity requiring the use of pesticides that may have negative effects on the environment The only instance in which this policy might be triggered by the Ghana Fisheries Programme is if aquatic herbicides or antibiotics were to be used in connection with aquaculture This is most unlikely but can be monitored through the implementation programme
OP 411 Physical Cultural Resources
The policy objective is to assist countries in avoiding or mitigating adverse impacts of development projects on physical cultural resources For the purposes of this policy ldquophysical cultural resourcesrdquo are defined as movable or immovable objects sites structures groups of structures natural features and landscapes that have
Under the Ghana Fisheries Programme construction and rehabilitation activities that could have negative impacts on cultural property will be avoided In the case of discovery of remains national procedures will be applied
27
archaeological paleontological historical architectural religious aesthetic or other cultural significance
OP 412 Involuntary Resettlement
The objective of this policy is to (i) avoid or minimize involuntary resettlement where feasible while exploring all viable alternative project designs (ii) to assist displaced persons in raising their former living standards income-earning capacity and production levels or at least in restoring them (iii) encourage community participation in planning and implementing resettlement and (iv) provide assistance to affected people regardless of the legality of land tenure
The policy covers not only physical relocation but any loss of land or other assets resulting in (i) relocation or loss of shelter (ii) loss of assets or access to assets (iii) loss of income sources or means of livelihood whether or not the affected people must move to another location The activities of the Ghana Fisheries Programme are likely to result in loss of assets or access to assets and loss of income sources or means of livelihood for some groups and individuals The potential for such losses will be carefully scrutinised and compensated for through the National Process Framework and Resettlement Policy Framework described in this report and appropriate procedures will be followed where necessary
Other donors and aid agencies including International and National NGOs play an active role within the fisheries sector in Ghana and their safeguards standards will be observed through operation of the Environmental and Social Safeguards Management Plan
28
43 THE GOVERNANCE FRAMEWORK IN GHANA
The Ministry of Food and Agriculture (MOFA) Preparation of Fisheries laws and policies fall under the responsibilities of the Minister of Food and Agriculture who in turn delegates functions including implementation to a semi-autonomous body the Fisheries Commission
The Fisheries Commission (FC) was established under the Fisheries Commission Act (625 2002) It oversees management regulation and utilisation of the fisheries resources of Ghana drawing on powers set out in the Fisheries Law (PNDC 256 1991) Fisheries Act 625 provided for the establishment of a more robust Fisheries Commission (FC) which is an amalgamation of the erstwhile FC and Department of Fisheries
Ten individuals constitute the Board which is led by a chairman (appointed by the President of Ghana in consultation with the Council of State) supported by three members drawn from the ministries of transport defence and environment There are three representatives from the following parastatal organizations - the Ghana Marine Fishing Officers Association Water Research Institute and Ghana Irrigation Development Authority- and two representatives (one from the artisanal and one from the industrial sections )of the National Fisheries Association of Ghana Finally the tenth member is a person with requisite knowledge of the fishing industry or natural resources renewal management
The day to day work of the Fisheries Commission is undertaken by the Department of Fisheries (DOF) which serves as the implementation secretariat of the Fisheries Commission as stipulated by the Fisheries Act 625 of 2002 Specific tasks that are undertaken by the Department of Fisheries include
bull preparing fishery resource management plans bull developing regulations for the fishing industry bull organizing monitoring surveillance and enforcement for the national fishery resources and
ensuring compliance with national fisheries law and institutionalizing co-management concepts
The MCS Division of the DoF (established under the Fisheries Sub sector Capacity Building project) works in conjunction with the Ghana Navy and undertakes sea patrols to exclude industrial fishing vessels from the 30-metre depth IEZ reserved for artisanal fisheries The MCS also conducts inspection of industrial vessels at the fishing ports of Tema and Takoradi for
bull valid fishing licences bull legality of fishing gear bull skipperrsquos certificate bull log book and crew composition
The MCS undertakes similar functions for inland fisheries on Lake Volta
The Ministry of Local Government and Rural Development (MLGRD) is responsible for managing fishers fish processors and fishery resources at district and sub-district levels which it undertakes through the District Assemblies In 2002 the District Assemblies in collaboration with DoF were mandated to facilitate fishery resource management by
bull helping to form and sustain Community Based Fisheries Management Committees (CBFMCs) bull cooperating with the DoF MCS units bull providing legal and financial support to the CBFMCs and bull approving levies proposed by the CBFMCs
29
Community-Based Fisheries Management Committees are charged with the responsibility of enforcing national fisheries laws at community level as well as initiating and enforcing their own by-laws
44 THE LEGAL FRAMEWORK
441 International Conventions
Ghana has ratified a number of international conventions and treaties which have an important bearing on the state of its marine and inland waters and the condition of the fisheries These are listed in Box 1 below
Box 1 International Conventions treaties and agreements to which Ghana is a signatory 1 International Convention for the Prevention of Pollution of the sea by Oil 21 October 1962 2 Convention on the Africa Migratory Locust 25 May 1962 3 Treaty Banning Nuclear Weapon Tests in the Atmosphere in Outer Space and Under Water 5th August 1963 4 International Convention for the Conservation of Atlantic Tunas 4 May 1966 5 Africa Convention on the Conservation of Nature and Natural Resources 15 September 1968 6 International Convention on Civil Liability for Oil Pollution Damage 29 November 1969 7 International Convention Relating to Intervention on the High Seas in Cases of Oil Pollution Causalities 8 Convention on Wetlands of International Importance Especially as Waterfowl Habitats 2 February 1971 9 Treaty and Prohibition of the Emplacement of Nuclear Weapons of Mass Destruction on the Seabed and the Ocean Floor and in the Subsoil Thereof 11 January 1971 10 International Convention on the Establishment of an International Fund for Compensation of Oil Pollution Damage 18th December 1971 11 Convention Concerning the Protection of World Cultural and Natural Heritage 16 November 1972 12 Convention on International Trade on Endangered Species of Wild Fauna and For a 3 March 1973 13 Convention on the Military or Any other Hostile Use of the Environmental Modification Techniques 10 December 1976 14 Convention on the Conservation of Migratory Species of Wild Animals 23 June 1979 15 Convention for the Cooperation in the Protection and Development of the Marine and Coastal Environment of the West and Central African Region1981(Abidjan Convention) 16 United Nation Convention on the Law of the Sea 10 December 1982 17 Montreal Protocol on Substances that Deplete the Ozone Layer 24 July 1989 18 Convention to Combat Drought and Desertification 19 Framework Convention on Climate Change June 1992 20 Convention on Biological Diversity1992 442 Environmental-Related Conventions Environmentally related conventions ratified by Ghana include
bull International Convention for the Prevention of Pollution of the sea by Oil 21 October 1962
bull Convention on the Africa Migratory Locust 25 May 1962 Treaty Banning Nuclear Weapon Tests in the Atmosphere in Outer Space and Under Water 5th August 1963
bull International Convention for the Conservation of Atlantic Tunas 4 May 1966 bull Africa Convention on the Conservation of Nature and Natural Resources 15 September 1968 bull 992256International Convention on Civil Liability for Oil Pollution Damage 29 November
1969 bull International Convention Relating to Intervention on the High Seas in Cases of Oil
30
Pollution Causalities bull Convention on Wetlands of International Importance Especially as Waterfowl Habitats
2 February 1971 bull Treaty and Prohibition of the Emplacement of Nuclear Weapons of Mass Destruction
on the Seabed and the Ocean Floor and in the Subsoil Thereof 11 January 1971 bull International Convention on the Establishment of an International Fund for
Compensation of Oil Pollution Damage 18th December 1971 bull Convention Concerning the Protection of World Cultural and Natural Heritage 16
November 1972 bull Convention on International Trade on Endangered Species of Wild Fauna and For a 3
March 1973 bull Convention on the Military or Any other Hostile Use of the Environmental
Modification Techniques 10 December 1976 bull Convention on the Conservation of Migratory Species of Wild Animals 23 June 1979 bull Convention for the Cooperation in the Protection and Development of the Marine and
Coastal Environment of the West and Central African Region1981(Abidjan Convention)
bull United Nation Convention on the Law of the Sea 10 December 1982 bull Montreal Protocol on Substances that Deplete the Ozone Layer 24 July 1989 bull Convention to Combat Drought and Desertification bull Framework Convention on Climate Change June 1992 bull Convention on Biological Diversity1992
443 National Legislation
The principal national legislation that affects fisheries in Ghana is listed below
1 Fisheries Regulation 1984 LI 1294 2 Fisheries (Amendment) Regulation 1977 3 Maritime Zones (Delimitation) Law 1986 4 PNDC Law 256 of 1991 5 Fisheries Commission Act of 1993 and 6 Fisheries Act 625 of 2002 7 Fisheries Regulations passed in 2010 LI 1968
Other laws that have relevance to the fisheries sector include
1 Wild Animals Preservation Act 1961 (Act 43) 2 Volta River Development Act 1961 (Act 46) 3 Ghana Water and Sewerage Corporation Act 1965 (Act 310) 4 Oil in Navigable Waters Act 1964 (Act 235) 5 Irrigation Development Authority Decree 1977 (SMCD 85) 6 Minerals and Mining Law 1986 (PNDCL 153) 7 Environmental Protection Agency Act 1994 (Act 490) 8 Ghana Highway Authority Act 1997 (Act 540) 9 Timber Resources Management Act 1998 (Act 547) and 10 Minerals and Mining Act 2006 (Act 703
31
434 Policies A number of Environmental related Policies exist in Ghana however there is no specific policy on the coastal zone These include
bull The National Environment Policy bull National Wetlands Policy bull Agricultural Policy bull Tourism Development Policy bull Land Management Policy bull National Health Policy bull Energy Policy bull Minerals Policy bull Wildlife Conservation Policy
The main thrust and orientation of national policies on the protection management and development of the marine and coastal environment focuses on the following three major areas
bull Integrated coastal zone management and sustainable development bull Marine environmental protection both from land-based activities and from sea-based
activities and bull Sustainable use and conservation of marine living resources (both of the high seas and
under national jurisdiction) Specific plans have been developed to ensure the realization of prudent management of the marine and coastal environment These include
bull Coastal Zone Management Indicative Plan 1990 bull National Environmental Action Plan 1994 bull Draft Integrated Coastal Zone Plan 1998 bull Coastal Zone Profile of Ghana 1998 bull National Oil Spill Contingency Plan with specific reference to the marine environment
2002 bull Environmental sensitivity map of the coastal areas of Ghana 1999 and 2004
Despite the existence of these plans active integration and coordination has been lacking in practice at local level 434 Regulations Though several legislations exist on coastal protection and sustainable development there is no omnibus legislation on the environment Legislation relating to the area include the following
bull Beaches Obstruction Ordinance 1897 (Cap 240) bull The Mineral and Mining Law 1986 (PNDC 153) bull Rivers Ordinance 1903 (Cap 226) bull Land Planning and Soil Conservation Ordinance No 32 of 1953 as Amended by the bull Land Planning and Soil Conservation (Amendment) Act 1957 (No 35 of 1957) bull Maritime Zones (Delimitation) Law 1986 (PNDCL 159) urban planning and
32
bull development bull Town and Country Planning Ordinance (Cap 84) bull Wild Animals Preservation Act Act 235 1964 bull The Towns Ordinance (Cap 86) bull National Building Regulations 1996 (LI 1630) bull Volta River Development Act 1961 bull Fisheries Act 2002 Act 625 bull Fisheries Law 1991 (PNDC 256) bull Fisheries (Amended) Regulations 1977 and 1984
The sustainable use and conservation of marine resources is encouraged through legislation regulations education and awareness creation programmes as well as the enforcement of existing regulations and legislation The legal framework for coastal zones issues and management in the country are contained in the following documents
bull The 1992 constitution bull EPA Act 1994 (Act 490) bull Environmental Assessment Regulations 1999 (LI 1652) bull Local Government Act 1993 (Act 462) bull Environmental Standards and Guidelines bull
In addition there are other specific legal frameworks which include a) The legal framework for Ecosystem Protection which are
bull Wild Animals Preservation Act 1961 (Act 43) bull Wildlife Conservation Regulations 1971 (LI685) bull Wild Reserves Regulations 1971 (LI 740) bull The Wetland Management (Ramsar sites) Regulation 1999 bull Oil in Navigable Waters Act 1964 (Act 235)
b) The legal framework for Fisheries Resources which are bull Fisheries Law 1971 (PNDCL 256) bull Fisheries Act 2000
c) The legal framework for Oil and Gas Industry bull Petroleum (Exploration and production) Law 1984 (PNDCL 84) bull Mineral (Offshore) Regulations 1963 (LI 257) bull Mineral (Oil and Gas) Regulations 1963 (LI 256) bull Oil and Mining Regulations 1957 (LI 221)
d) The legal framework for Tourism Promotion (including coastal tourism) bull Ghana investment Promotion Centre Act 1994 (Act 478) bull Companies Code 1963 (Act 179) bull Free Zone Act 1995 (Act 504) bull Ghana Tourism Board bull Ghana Commission on Culture
44 ACTIVITIES RELATING TO FISHERIES INTERESTS
33
Over the years several activities have been undertaken which are of relevance to protection of the marine environment and fisheries These include
bull Ghana Environmental Resource Management Project in Coastal Wetlands Management Component
bull Gulf of Guinea Large Marine Ecosystem Project bull Fisheries Sub-sector Capacity Building Project bull Establishment of a Protected Wetland Ecosystem on the coast bull Development and Implementation of Oil Spill Contingency Plan bull Monitoring of fish stock levels and associated oceanographic parameters bull Institution of a programme of Monitoring Compliance and Surveillance of the marine
environment bull Development of industrial pollution standards bull Development of University course on Coastal Zone Management bull Increased public education on sound coastal and marine environmental practices
45 RELEVANT INSTITUTIONS With regards to protection management and development of the marine and coastal environment a number of ministries and agencies have been identified as potential stakeholders Those shown with an asterisk are likely to have a particularly active role
bull Ministry of Environment and Science bull The Environmental Protection Agency bull Ministry of Tourism bull Ministry of Local Government and Rural Development bull Ministry of Ports bull District Assemblies bull Ghana Ports and Harbours Authority bull Hydrological Services Department bull Ministry of Food and Agriculture bull Ghana Tourist Board bull Ghana Investment Promotion Centre bull Fisheries Commission Ministry of trade Industries and PSI bull Ministry of Lands and Natural Resources Forestry and Mines bull Ministry of Energy bull Ministry of Health bull Ministry of Education Youth and Sports bull Ministry of Defence bull Ghana Navy bull Ministry of Works and Housing bull Ministry of Women and Childrenrsquos Affairs bull Ministry of Roads and Transport bull National Development Planning Commission bull Council for Scientific and Industrial Research bull Universities and Research Institutions bull Ghana Meteorological Agency bull Town and Country Planning Department bull Water Resources Commission
34
bull Ghana National Petroleum Corporation bull Volta River Authority bull Geological Survey Department bull Forestry Commission (Forestry and Wildlife Division) bull Traditional Rulers and their analogous ministry and laws
Non-Governmental Organisations including Resource Development amp Environmental Oriented Development Organisation
bull Friends of the Earth bull Green Earth bull Wildlife Society bull Recerca e Cooperazione bull Centre for African Wetlands bull And many others
46 PARTNERSHIPS Few formal partnerships exist However support for coastal conservation activities has been received from the private sector as well as from Government Regional and sub-regional collaboration efforts occur at various levels although the level of practical intervention is sometimes limited The science and technology unit of ECOWAS is engaged on issues relating to the management of the Gulf of Guinea In addition a bilateral arrangement exists between Ghana and Cote drsquoIvoire for the management of and datasharing on Sardinella stocks which migrate between the two countries The NEPAD framework among the coastal states of Africa is also developing an interest in marine and coastal management 461 Technical and financial support Ghana receives technical support in the form of training research and project implementation from national bilateral and multi-lateral sources Financing of activities in the sector is primarily supported from the national budget However donor support from both bilateral and multilateral sources has also been obtained for specific programmes such as the World Bank sponsored Fisheries Sub-sector Capacity Building Project UNOPS sponsored Environmental Sensitivity Map for Coastal Areas The Ghana Coastal Wetland Project of the World Bank UNEPrsquos WACAF Programmes and The Darwin Marine Biodiversity of West Africa Project by DFID implemented by the University of Ghana 47 ACTIVITIES Activities undertaken in the country with importance to the marine and coastal area are outlined in the following sections 471 Environment-related activities
bull Ecological Baseline studies of Korle Lagoon (1990-2000) This was carried out to satisfy EIA requirement and as a result pollution status of the lagoon was established
bull Lower Volta Mangrove Project (1996-1998) The objective is to ensure sustainable management of mangrove stands and as such baseline information was documented
bull Save the Seashore Birds Project (1985-1995) This was to protect the seashore birds and as a result conservation awareness of seashore birds was achieved
bull Ghana coastal wetlands management project (1996-1999) In this management of the five coastal wetlands designated as Ramsar Site was put in place
bull Darwin Marine Biodiversity of West Africa Project It is a training project in marine biodiversity assessment
35
472 Social-related activities bull A considerable amount of attention is currently being given to the potential impact of oil-related
development in coastal regions following the publication of Environmental and Social Impact Assessments and Management Plans relating to the Jubilee Oil Field discoveries
473 Coastal area management bull Climate and vulnerability and adaptation assessment on water resources agriculture and the
coastal zone Projects (1997-1999) The projects assessed the vulnerability of the coastal zone to climate change
bull Coastal area management plan for Princess Town (1998-2000) which aimed at providing a plan for the management of Princess Town
bull Keta Sea Defence Project Work (2000-2004) The project aimed at protecting the Keta and its environs from the episodes of erosion faced in the area and also to ensure improvement in environmental and socio-economic conditions at Keta and its immediate surroundings
474 Regional Programmes bull Gulf of Guinea Large Marine Ecosystems Project (1996-1999) The project developed an
effective approach to prevent and control pollution in the Gulf of Guinea and conserve its biodiversity As a result regional institutional capacities were strengthened and also a coastal zone management profile and plans produced
bull UNEP WACAF Projects 1 amp 2 This aims at institutionalising and coordination of national contingency plans monitoring of pollution in the marine environment and control of coastal erosion
475 Other major programmes Other recent programmes and activities in the marine and coastal environments have included
bull Ghana Environmental Resources Management Project in Coastal Wetlands bull Fisheries sub-sector Capacity Building Project bull Establishment of a Protected Wetland Ecosystem on the coast bull Development and Implementation of Oil Spill Contingency Plan bull
48 ONGOING PROJECTS Ghana is currently implementing several projects in the marine and coastal area Some of these projects are linked to developmental projects for which impact assessments are required under the Environmental Assessment Regulations of 1999 Some of the projects are large scale in nature with extensive baseline and monitoring studies like the Keta Sea Defence Project and the West Africa Gas Pipeline project Others are projects being implemented under the auspices of the United Nations agencies and non-governmental organisations include
bull Combating Living Resource Depletion and Coastal Area Degradation in the Guinea Current LME through Ecosystem-based Regional Actions
bull Amansuri Conservation and Integrated Development Project (ACID) bull Danida Water and Sanitation Sector Programme II Support to Integrated Water Resources
Management (IWRM) Component (2004-2008)The Densu Basin aspect of the IWRM component
bull Reduction of Environmental Impact from coastal tourism
bull Bui Hydro Power Project
bull Sea Defence Project at Atorkor
bull Sea Defence Projects in selected towns in the Western Region of Ghana
36
49 CONCLUDING REMARKS
This chapter has highlighted the wide range of conventions laws policies regulations and activities affecting the inland and coastal regions and inland freshwater and marine environment of Ghana It will be important to keep all of these processes and procedures under review as the Fisheries and Aquaculture Sector Development Plan is taken forward to the implementation stage
The main responsibility for ensuring delivery of the Fisheries and Aquaculture Sector Development Programme will rest with the Fisheries Department of the Ministry of Food and Agriculture and the Fisheries Commission supported by the MCS Division and Ghana Navy However a key part of the programme is the development of local co-management arrangements and the Ministry of Local Government and Rural Development and individual District Assemblies will play a key role in helping to form and sustain Community Based Fisheries Management Committees
Over time a significant number of fishermen and individual fish processors are likely to leave the sector as harvesting landing and processing of the catch becomes more efficient Management of these changes especially where disadvantaged and vulnerable sections of the community are affected will need substantial support and investment and a high degree of coordination amongst government ministries and agencies NGOs and international partners to ensure that development assistance is effectively targeted
37
CHAPTER 5 WORLD BANK SAFEGUARD ISSUES
51 INTRODUCTION
The World Bankrsquos proposed funding support to the Government of Ghana covers an initial five yearsrsquo period which could potentially be extended at a later date As the Government of the Republic of Ghana notes in the draft FASDP ldquoimproving the management of the countryrsquos fisheries and ensuring that the impacts on individuals and communities are properly addressed will take 20 or more years to effectrdquo It has therefore been judged important in this report to distinguish between changes that might occur as a direct result of the World Bankrsquos financial assistance thereby triggering the Bankrsquos environmental and social safeguards and changes that could result from longer term adjustments to fisheries and other sectors of Ghanarsquos economy as a result of wider influences by Government other donors and world-wide factors (for example international progress in world trade agreements)
The aim in this chapter is to identify changes which are likely to fall within the purview of the World Banks reputational risks and responsibilities under the first five years of the Fisheries and Aquaculture Sector Development Plan (FASDP) It should be clearly understood that the views expressed are those of the consultancy team and it will be for the World Bankrsquos internal advisors to decide what formal recommendations are made to the World Bank Board
Trends that may emerge in later stages of the implementation of FASDP ndash subsequent to the initial five year period - are discussed in chapter 6
52 THE CURRENT SITUATION
The general status of Ghanarsquos fisheries has been described in Chapters 3 while the legal and policy context has been set out in Chapter 4 The World Bankrsquos investment is being planned specifically to support government policy with the aim of providing a more efficient and better regulated fisheries sector Currently open access is leading to progressive deterioration in fish stocks and lower economic returns Based on many international examples of successful intervention the current proposals (see Chapter 2) are to provide support to introduce formal licensing of all vessels and proper monitoring and control over the seasonal timing and location of fishing activity use of gear and approved nets and self regulation through co-management structures under which the Government and fishing communities will work together to achieve recovery of fish stocks higher income levels for fishers and better returns on catches by reducing post harvest losses and improving processing and marketing operations
53 ANTICIPATED OUTCOMES
It is expected that the proposed reforms and changes will eventually lead to significant improvement in the marine environment restoration of fisheries and enhanced incomes In this respect the provision of grants and loans from the World Bank will bring about major benefits to the economy livelihoods and the environment in the longer term The question that has to be addressed however is - are there likely to be any short term adverse environmental or social consequences from the Bankrsquos own investment strategy Answers are considered in relation to each of the planned components sub-components and activities which are summarised in Table 51 A colour coding and numbering system has been adopted to distinguish those activities that are seen as particularly relevant from the standpoint of the environmental and social assessment Elements highlighted in green are those likely to have positive and beneficial effects on the environment and social conditions those highlighted in orange red have potentially negative or adverse consequences if not handled properly
38
Component 1 Good Governance and Sustainable Management of the Fisheries
Sub-Component 11 seeks to develop the capacity rules procedures and practices that will lead to better governance As such these procedural interventions will have no direct effect on the environment or social conditions of fishing communities However it will be important to ensure that the drafting agencies (government departments and consultants) give due attention to environmental and social objectives during this phase of work Three specific areas are highlighted including undertaking a socio-economic impact assessment with mitigation measures as part of the plan for fishing capacity reduction reviewing the economic and social implications of subsidies and fish import tariffs in the fisheries sector and developing the policy for the development and operation of community-based management networks built around defined fisheries management units
In developing regulations and guidelines it will be important to consider how less able individuals and vulnerable sectors are going to adapt to new systems For example the new regulations on licensing canoes including completion of registration forms the display of registration numbers on vessels and demonstration of basic competence in health and safety standards may prove taxing demands for owners and crew lacking any formal education Similarly legal instruments that are used to remove fuel subsidies or other benefits will need to be carefully explained A socio-economic impact assessment is proposed in the draft PAD to be accompanied by appropriate mitigation measures This assessment should consider amongst other things
bull whether support should be offered and if so under what conditions to any company community or individual who fails to secure a license for a particular class of vessel
bull how the transfer or sale of licenses will be regulated in the wider public interest to ensure transparent processes and avoid the creation of monopolistic and oligopolistic elites
bull who wins and who loses from any planned changes to subsidies and fish import tariff adjustments
bull how the performance of community-based management networks will be judged bull what action will be taken to mitigate the loss of any traditional fishing grounds that become the
subject of marine protected area development or are subject to exclusion zones to protect oil drilling and production platforms
Sub-Component 12 introduces the concept of fishing rights This is to be initiated through a series of four pilot stakeholder-based fishery initiatives and the rolling out of licensing procedures Discussions with stakeholders have made it very clear that the credibility of the entire fisheries policy and programme could be challenged if these pilots do not show positive and constructive ways of moving forward with fisheries reform There is a great deal of distrust for new procedures amongst the fishing communities based on the knowledge that many previous initiatives have failed It is therefore essential that the pilots are led by a strong implementation team are adequately financed and include a credible transparent and inclusive process for debate discussion and consultation Co-operation from the selected communities will be more likely to be achieved if they can see early results in terms of income generating activities
Sub-Component 13 is targeted at adjusting fishing effort and capacity to more sustainable levels and supporting alternative livelihood opportunities These activities are critical in giving effect to the policy decisions that have already been taken to reduce the size of the industrial and semi-industrial fishing fleet and to strengthen the role of the canoe sector Specific measures are proposed for compensating crew members who lose their jobs and for providing training to young men who are willing to transfer
39
out of the fishing sector The scale of this task should not be under-estimated however since there are currently few alternative employment opportunities in the coastal belt for manual workers with low education and skill levels which typify the status of many young fishermen The concept of creating some additional employment with conservation of the coastal littoral and marine ecosystems is strongly supported since this can be linked with development of tourism
Sub-Component 14 is another element that is strongly focused on delivering improved livelihoods with its emphasis on social marketing communication and transparency The focus on stakeholder participation is particularly welcome and should lead to positive response providing it is backed with direct financial support to participating communities
Component 2 - Reduction of Illegal Fishing
There is no Sub-Component 21 within the Ghana Fisheries Programme
Sub-Component 22 aims to develop monitoring control and surveillance (MCS) systems These measures are largely procedural and apart from the relatively small team that will be recruited to operationalise the systems it will have minimal effects on either the environment or social conditions One element that is highlighted in Table 51 relates to provision of facilities and training for participatory coastal surveillance of small-scale fisheries This should have direct and strongly positive benefits for participants and the communities who are enrolled in the training programmes
Component 3 increasing the contribution of the marine fish resources to the local economies
Sub-Component 31 will support the development of basic infrastructure at nine marine fish landing sites and two inland sites The scale of physical construction will be restricted to repair and minor extension of roads and jetties wharves and construction of net mending screens and storage sheds These activities are unlikely to have any significant adverse environmental impacts and should lead to positive social effects
Sub-Component 32 will underpin efforts to improve fish product trade infrastructure information and systems Introduction of new technology for smoking and curing fish and the extension of existing ice preparation plants will start to have positive beneficial effects within the selected communities
Sub-Component 33 provides a modest level of support to marine and inland aquaculture development Aquaculture development should include finalization establishment and enforcement of current draft operational standards to cater for environmental friendliness of fish culture industry for its own survival The main focus will be on developing policy and legal frameworks together with support for stock improvement These measures will have some impact on affected communities in the short term but are clearly aimed at longer term benefits
40
Component 4 Coordination Monitoring and Evaluation and Program Management
Sub-Components 41 and 42 are directed specifically at strengthening the capacity of the Governmentrsquos institutions for national implementation and regional co-ordination As such they will have no direct environmental or social impacts
54 SUMMARY AND CONCLUSIONS
This review of potential environmental and social safeguard issues under the World Bankrsquos targeted programme concludes that there are unlikely to be any significant adverse environmental or social effects as a result of the planned investments
The only possible exception relates to the effectiveness of measures that are put in place under Sub-Component 12 to support pilot stakeholder-based fishery initiatives It is of paramount importance that these pilots are successful and win the confidence of all participants since failure to achieve positive results could set back the entire fisheries programme For this reason it is essential that planning of the pilot initiatives is linked closely with measures for supporting alternative livelihoods and strengthening processing and marketing initiatives under Sub-Components 13 and 14
A number of the planned interventions may have longer term consequences as policies regulations and bye-laws are put into effect but these will be addressed in subsequent work by the Government of Ghana (see Chapter 6)
Table 51 Elements of the World Bank Programme and assessment of potential environmental and social risks
Description of Component Sub-Component and Activities
Measure of Likely Effects
Large (3)
Moderate (2)
Small (1)
None
Beneficial
3
2
1
Adverse
3
2
1
Component 1 Good Governance amp Sustainable Management of the Fisheries
Sub-Component 11 Developing the Capacity Rules Procedures amp Practices for Good Governance of the Fisheries
Reviewing developing programmes and projects designed to support the Fisheries and Aquaculture Development Sector Plan (FASDEP)
Developing an operational policy to enable implementation of the Aquaculture and Fisheries
Plan for fishing capacity reduction (including socio-economic impact assessment and mitigation) 3 2
Commercial vessel and fishing activity licensing plan including allocation criteria rules for transfer of licenses
41
Sector Development Plan and timetable and schedule of license fees
Compliance strategy and plan
Regulations for the management of fisheries including the identification and specification of fisheries management units (ie stocks species areas)
Recommendations for environmental and social safeguards arising from the review of the economic and social implications of subsidies and fish import tariffs in the fisheries sector
3
Policy for the development and operation of community-based management networks built around defined fisheries management units
3
Policy on adaptation strategies for climate change and marine protected area development
2 2
Review of the Ghana Tuna Industry to identify policy or infrastructure needs that threaten Ghanarsquos hub status
Strengthening capture fisheries management systems and capability
Development of fisheries and aquaculture management systems and processes and training
Strengthening fisheries information systems
Installation and operation of fisheries lsquodashboardrsquo database and information collection
Sub-Component 12 Introducing Fishing Rights ($15 M GEF)
Developing 4 pilot Stakeholder-Based Fisheries Management initiatives around defined fisheries units (ie local management initiatives tied to defined fisheries resources including demand-side governance initiatives)
3 2
Introducing and administering a licensing regime (registry establishment training stakeholder education) 2 2
Sub-Component 13 Adjusting Fishing Effort and Capacity to more Sustainable Levels and Supporting Alternative Livelihood Opportunities where Needed
Vessel decommissioning Decommissioning of 60 to 80 industrial trawlers in an environmentally friendly manner
2
Developing alternative livelihoods for crew of decommissioned industrialsemi-industrial
Skills training and small business development training and support for young (18-30 yrs) industrialsemi-industrial crew members willing to transition out of the sector
3
42
vessels
Alternative livelihood development to incentivize voluntary capacity reduction in canoe sector
Alternative livelihoods fund and CDD support to targeted fishing communities
3 2
Marine Resource Conservation
Would include confirming conservation priorities and management regimes and possible provision of support for alternative livelihood options (funded under 133) associated with conservation of coastal littoral and marine ecosystems as well as de facto protected areas associated with the development of oil and gas extraction
3
Sub-Component 14 Social Marketing Communication and Transparency)
Communications stakeholder consultations and awareness raising programs to support fisheries development
3
Component 2 Reduction of Illegal Fishing
Sub-Component 21 does not apply to Ghana
Sub-Component 22 Monitoring Control and Surveillance (MCS) Systems
Developing compliance systems and capability
Development of judicial and policy capacity (training)
Compliance risk assessmentstrategy systems and process development
Enforcement Unit establishment (dedicated facility)
Coastal surveillance stations 2
Facilities and training for participatory coastal surveillance of small-scale fisheries
3
Training for surveillance officers
Operation of aerial and water patrols (vessel leases aerial patrols operational costs patrol vehicles)
Observer program
Compliance education (stakeholder training signage) 1
Upgrademaintenance of the Vessel Monitoring System (VMS)
43
Component 3 Increasing the Contribution of the Marine Fish Resources to the Local Economies
Sub-Component 31 Fish Landing Site Clusters
Product diversificationvalue chain development
9 marine landing sites (basic infrastructure) at Axim Dixcove Fete Jamestown Moree Mumford Senya-Beraku Teshi and Winneba
3 1
2 inland fish landing sites (improved access and berthing infrastructure) at Abotoase and Dzemeni
3 1
2 ports developed (technical studies for 1 new port at Axim and additional berthing space in existing port of Elmina)
3 2
Sub-Component 32 Fish Product Trade Infrastructure Information and Systems
Export certification center development
Fish processing technology improvements 1 1
Technical assistance training and goods to support the National Fisheries Advisory Group
Sub-Component 33 Marine and Inland Aquaculture Development
Developing aquaculture policy and legal framework
Improving genetic quality of Tilapia fingerlings and breedstock
Catalyzing aquaculture development 2
Component 4 Coordination Monitoring and Evaluation and Program Management
Sub-Component 41 National Implementation
Technical assistance for Secretariat to the Fisheries Commission to implement the Project
Sub-Component 42 Regional Coordination
Technical assistance for Regional Coordination Unit at the CSRP support to Fisheries Information Systems (lsquoDashboardrsquo)
45
CHAPTER 6 ENVIRONMENTAL AND SOCIAL ASSESSMENT OF DRAFT FISHERIES AND AQUACULTURE SECTOR DEVELOPMENT PLAN (FASDP)
61 INTRODUCTION
This chapter examines environmental and social issues which need to be considered as part of the overall structural and economic adjustments in Ghanarsquos fisheries sector in the longer term (ie 1-15 years) The assessment deliberately focuses on the longer term because it will take a number of years before current plans start to have their full effect However the same temporal considerations apply to measures that are designed to avoid or mitigate potentially harmful effects so it will be important to start planning remedial actions as part of the joint Government of Ghana and World Bank fisheries programme
611 Key sectors and activities The fishing industry is divided first into marine capture and inland capture fisheries and then aquaculture For each of these three sectors activities are then broken down as follows Marine Capture Fisheries CATEGORY ACTIVITY Stock Management Research Surveillance reef building Harvesting Vessels Gear Skills capacity Marketing Sellers Buyers Processing Fresh fish Sun dried Smoking Freezing Consumers By market sector Support Sectors Boat Canoe Building fuel supply net making kiln construction
refrigeration transport cold store management Legal Enforcement Financing Investment in all elements Infrastructure Harbour wharf processing plant construction
Inland Capture Fisheries CATEGORY ACTIVITY Stock Management Research Surveillance Harvesting Vessels Gear Skills capacity Marketing Sellers Buyers Processing Fresh fish Sun dried Smoking Freezing Support Sectors Boat Canoe Building fuel supply net making kiln construction
refrigeration transport cold store management Legal Enforcement Financing Investment in all elements Infrastructure Harbour wharf processing plant construction
46
Aquaculture and Mariculture CATEGORY ACTIVITY Stock Management Research Surveillance Rearing Roe fingerling production cage -pond rearing Harvesting Vessels Gear Skills capacity Marketing Sellers Buyers Processing Fresh fish Sun dried Smoking Freezing Support Sectors Boat Canoe Building fuel supply cage construction kiln construction
refrigeration transport cold store management Legal Enforcement Financing Investment in all elements Infrastructure Harbour wharf processing plant construction
612 Evaluation Criteria The environmental and social assessment has been undertaken using a matrix (See Annex 114) which analyses the key sectors and activities of the fishing industry and the changes that are envisaged against a set of evaluation criteria Evaluation Criteria are broken down into environmental and social issues distinguishing between beneficial and adverse effects Table 61 below shows the relationship between the groups of criteria Table 61 List of Evaluation Criteria
Environment Social
Positive Adverse Positive Adverse
bull Sea bed rejuvenated
bull Fish stocks recovered
bull Biodiversity enhanced
bull Sea bed degraded
bull Fish stocks reduced
bull Biodiversity reduced
bull Increased harvest (catch volume)
bull Increased catch value
bull Reduced costs of inputs
bull Increased profit
bull Enhanced livelihoods
bull Increased job opportunities
bull Increased local economic multiplier
bull Reduced harvest (catch volume)
bull Reduced catch value
bull Increased costs of inputs
bull Reduced profit
bull Reduced livelihoods
bull Reduced job opportunities
bull Reduced local economic multiplier
The assessment process has involved systematically considering each sectoractivity against the evaluation criteria and recording either positive or negative results by drawing on the judgement of the consultancy specialists The findings are discussed in the paragraphs that follow and are reflected in Table 81 forming part of the Draft Environmental and Social Management Plan
62 DETAILED ASSESSMENT OF THE MARINE AND AQUACULTURE SECTORS
47
TunaIndustrial fleet streamlined and catch per vessel improved At present industrial trawlers have to travel increasing distances to fishing grounds and while the level of catch is remaining broadly static costs are increasing against available economic returns A major shortcoming is lack of investment in re-equipping the aging fishing fleet Many of the 90 vessels that make up this sector are increasingly unseaworthy and need to be replaced with modern trawlers and gear The plan is to buy out owners of substandard vessels by offering compensation at market value based on a full commercial survey Vessels remaining in the fleet will be required to meet exacting standards By reducing the number of old and inefficient boats this will allow each of the remaining vessels to catch a higher proportion of fish The aim is to ensure that Ghana is equipped with the latest vessels and technology in order to preserve the countryrsquos position as the hub of the West African tuna fishing and processing industry (see also the section on canneries below) The effect of these measures on the environment will remain broadly neutral since the same number of fish will be caught Providing other policies and increased surveillance are successful in preventing trawling in inland waters the smaller fleet will have to fish in deep oceanic waters This could potentially transfer some environmental effects on fish populations to other parts of the migratory cycle However this would become part of the international effort through fishing quotas to regulate overall catches Reduction in the size of the industrial fleet will mean that fewer men are needed to crew and service the vessels However in practice many men who work in this sector have only part time work and since a significant percentage of boats no longer put to sea the number of crewmen who will be displaced could be in the range of 1000-30003
It will be important to set up support services for those losing their jobs including retraining and welfare assistance where necessary
Decommissioning will necessitate the sale of seaworthy vessels and their removal from Ghanaian waters Other boats will need to be broken up and scrapped This process requires heavy duty specialized equipment and can release significant quantities of waste oil other toxic chemicals including refrigerants and asbestos used in pipe and engine room cladding Measures will need to be taken to ensure that proper environmental and health safety precautions are taken that decommissioning takes place in properly equipped boatyards and that all waste products are disposed of without environmental risk Cannery sector optimized The Fisheries and Aquaculture Sector Development Plan seeks to maintain the port of Tema as the centre of the Tuna canning industry in Ghana At present a proportion of Ghanarsquos tuna catch is diverted to neighbouring countries due to constraints on processing capacity These limitations include poor port infrastructure ageing equipment and delays in handling catch for some operators due to preferential treatment of vessels that are part-owned by the existing canneries Options for improvement include encouraging upgrading of the capacity of one or more existing canneries or promoting more competition in the processing sector and improving the infrastructure Providing modern building designs and construction techniques are employed and a full environmental assessment is undertaken in accordance with Ghanarsquos EIA regulations there should be no significant environmental or social risks associated with these development possibilities The potential economic benefit resulting from encouraging investment in this sector is very high
Industrial fishing excluded from inshore waters A major longer-term intention under the new fisheries plan (FASDP) is to ensure that existing regulations that restrict industrial and semi-industrial vessels from trawling in inshore waters are properly enforced This requires provision of surveillance
3 Based on an average crew of 20
48
equipment fast patrol vessels capacity building and training and increased staffing within Government agencies together with a full programme of awareness raising training and financial support to local bodies providing self-governance under new co-management services Restriction of industrial trawling in coastal waters will greatly ease pressures on fish stocks and reduce environmental damage to the sea bed In time this should lead to healthier fish population with more fish to be caught by the canoe industry as a result However the task of policing and enforcing regulations will not be easy and will take a number of years to bring into full effect Reduction in fishing activity by inshore trawlers will displace a number of crew members and have a short-term impact on dependent families until these individuals are either absorbed into the canoe fleet or find alternative employment There will therefore be a need to assist genuinely deserving cases where crew members (and their families dependents) need to transfer to other sectors of the economy These measures will only be required in the short term since the anticipated improvement in fish stocks will lead to improved economic performance in the canoe sector within which the bulk of employment exists
Expansion of deep water fisheries The fisheries plan notes that there may be a potential for exploitation or increased exploitation of some deep sea fish resources However the status and population dynamics of some affected species is not well known so any such activities should be scientifically monitored through research and enforced by MCS
Tema Secondi Port infrastructure improvements (equipmentbuildings) Under present conditions the transfer of fish from commercial and industrial vessels to canneries is often delayed by the time taken to offload crates and manouvre within the port area where there are conflicting activities There are also difficulties that arise when vessels owned by the canneries are given priority for landing leaving other boats waiting for many hours which can result in quality deterioration At this stage no details are available about the precise improvements that could be introduced and this will need to be investigated as the fisheries plan is advanced Any environmental effects from infrastructure improvements would be contained within the existing port areas and should be largely positive in reducing fuel (energy) costs and increasing overall efficiency It will however be important to carry out an environmental review of specific development proposals at the design stage especially if these involve plans for any dredging or for altering facilities for discharging waste and disposing of bilge water Both of these activities can have damaging effects on the sea bed (The first through dispersal of silt and sediment and the second through release of potential contaminants) Socio-economic effects from the infrastructure improvements should also be beneficial by removing delays increasing efficiency and reducing waste However there could be some slight reduction in manpower requirements leading to the need for skills retraining Regulating the catch (eg Fishing for selected species reducing juvenile catch to improve value of catch in inshore waters) The fundamental aim of the fisheries plan is to reduce the harmful effects on fish stocks and low economic returns from fish catches by phasing out open access for all and introducing regulation of fishing activity This is to be achieved through close cooperation between the Fisheries Commission Monitoring and Surveillance Unit as well as marine fisheries management division and individual fishing communities working together under a co-management framework The practical details will need to be worked out through each individual co-management group and initially the World Bank is offering to assist in the establishment of four pilots These bodies will test exactly what is required to increase fishersrsquo awareness to build capacity in self regulation and agree on appropriate measures
49
From discussion with stakeholders it is clear that while the broad principles are accepted the majority of the fishing community simply do not believe that the new regulations will be enforced because they have witnessed the failure of so many previous efforts to introduce firm management A major issue for the planned programme is therefore how to change this critical mindset without which very little progress is likely to be made in practice It will be necessary to demonstrate through the pilots that by regulating fishing activity direct benefits will accrue to those participating fishing communities Unfortunately efforts to eliminate harmful practices are unlikely to result in an immediate gain in fish stocks Instead catches are likely to fall in the short term It will therefore be essential to introduce other forms of incentive to cushion short term losses Such measures might include the purchase of new nets and gear for sale at subsidized price to local cooperatives the introduction of cash incentives for canoes demonstrating best practice in the use of gear and nets preservation of the catch using ice and landing and marketing fish of the required size and quality As restriction of open access starts to take effect there should be positive environmental gains in terms of improving fish stocks and less damage of the sea bed On the other hand both fishers and fish processors will feel the adverse temporary effect of reduced catches These social and local economic impacts will need to be monitored closely and assistance provided to help foster alternative livelihoods Cephalopus (Octopus) harvesting encouraged in inshore waters Although most fish species are currently exploited to unacceptably high levels within coastal waters there is a specific opportunity to increase the number of octopus caught by pot fishing This fishery could be developed by both the semi-industrial and canoe sectors Taking octopus in pots would have no adverse physical impacts on the sea bed and could allow very slight expansion in fish species that are preyed on by octopus At the same time it is important to note that there is only limited information on species composition and functioning of selected marine habitats including those of the octopus and more research should be undertaken on this and other species that could be selected for expanded fishing activity There would be clear socio-economic benefits arising from the creation of this new fishery Focusing fish landing at specific landing sites (to improve opportunities for subsequent marketing processing) Plans are already being developed for the enhancement of landing and processing facilities at a number of existing locations along the coast These locations include the construction of harbours at Jamestown and Elmina and development of landing sites at Teshie Ada Axim Dixcove Winneba Mumford SenyaBeraku Gomoa Fetteh Moree Keta Dzemeni and Tapa Abotoase Two sets of issues need to be considered in relation to these improvements all of which affect existing fish landing and processing sites The first is the nature of the physical works and infrastructure and it s potential effect on the marine and terrestrial environment The second is the socio-economic impact Both Elmina and Jamestown are long established fishing ports where the catch is landed either directly onto the beach or shallow wharves It is understood that the primary aim of the improvements will be to increase the area of permanent wharves to make it easier for fish to be offloaded to reduce the time taken in transferring stock to processing plants and to introduce modern technology In the case of other smaller landing sites the scale of improvements will be quite modest involving improvement to existing short stretches of access road the erection of stores for nets and other gear and provision of covered areas to provide shade for net-mending With all proposals for physical infrastructure development there will be a need to consider possible
50
environmental implications Due to the existing nature of these sites there are no major industrial or other commercial processes in the vicinity which could give rise to cumulative impacts including contamination of fish products The scale of plant needed for ice-making and storage and commercial smokeries is commensurate with the artisanal nature of the fishing activity itself and would not give rise to any significant environmental effects on air or water quality Harbour works could potentially involve some small scale dredging (for example the removal of accumulated silt) Where dredging is required it will be important to identify disposal areas (either at sea or on land) where silt can be deposited without damage to sensitive habitats In terms of economic and social impacts it is not clear at this stage who are likely to be the major investors from the private sector although it may be assumed that existing operators who have access to finance will be the main beneficiaries Over time as landing marketing and processing become more efficient it is possible that individuals in the traditional fish smoking sector will lose a significant proportion of their trade as the product switches to fresh or frozen fish sales for transfer to the major urban markets and the beach price for fish rises The draft Ghana fisheries and aquaculture sector development Plan notes in annex 2 that proposed facilities associated with the ports and landing sites may not have support from fish mammies or at least formidable commercial advocates able to resist any opposition from that quarter Inspection of major fish landing areas like Elmina and Sekondi indicates that the existing social and commercial structure of support activities to fish harvesting is very complex and involves almost every member of the community including children and the elderly Such activities include net mending boatbuilding metalworking (for cooking pots stoves and grills supplies (ropes weights tar paint wood) fuel supplies ice crates transport etc Leaders of the fishing community confirmed that in principle the improvements of facilities is welcomed provided that safeguards are in place for those who may lose part or all of their current trading activity through rationalisation Stabilise fleet capacity at a sustainable level Fishery experts consider that there would be significant benefits in reducing the number of canoes from the present 10000-12000 to around 8000-9000 which correlates with the number operating in the mid 1990rsquos when catches were at optimum levels At the same time the Fisheries and Aquaculture Plan stresses that the canoe sector will remain at the heart of the Ghana fishing industry and this has strong political enforcement Consequently there is unlikely to be any enforced reduction in the number of canoes holding licenses and owners of all existing canoes will be able to register their vessels The ability of canoe owners to pay annual licence fees should rise as the overall measures to increase efficiency and improve catches take effect However many people anticipate that over time as the annual cost of holding licenses rises less efficient fishers will sell their licenses (and hence their rights to fish) There may therefore be a de facto reduction in the size of the canoe fleet Even if numbers do not decrease the fleet could be stabilized at its present size by taking a decision not to grant new licences The draft plan discusses the fact that under existing law (section 53) there is a requirement for licenses to be issued on demand (presumably to ensure that Ghanaians are not barred from subsistence fishing) It is argued in the plan that this is a misconception since canoe fishing is largely a commercial activity and it is concluded that lsquoit is therefore essential that the number of canoe licenses can be controlled in future and the legal basis for these controls must be reviewed as a matter of priorityrsquo Decisions of this nature will require the full support of local co-management groups if they are to be effective but committees could easily come under pressure to make exceptions as the coastal population continues to rise and families without alternative livelihoods start lobbying for assistance
51
Accusations of preferential treatment of certain individuals by committees (or committee officials) - possibly linked with suggestions of bribery and corruption -could cause a lot of social tension and start to undermine community trust in the need to work together to improve fisheries management It is therefore most important that the detailed proposals for co-management address this risk and include proposals for mitigating individual hardship of the less advantaged ndash for example by offering voluntary retirement with some form of incentive Influencing marketing to maximise value and reduce post harvest losses (marketing cooperatives strong market structures etc) FAO has estimated that physical post harvest losses in Ghana amount to between 3 and 17 of smoked fish production and 16-20 of gillnet landings The plan notes that introduction of lsquonew generationrsquo small scale fish smokers should be introduced to replace the traditional Chorkor model This would improve fish product quality by eliminating charring of fish over open flames and also protecting operatorsrsquo eyes from the damaging effect of smoke and particles The other major improvement in post harvest value and profits would arise from greater use of ice throughout the supply chain Developing Aquaculture A distinction needs to be made between aquaculture development in ponds and dugouts which are self-contained and fish rearing in cages within open water In the case of farm ponds the commercial rearing of fish is little different to other forms of intensive livestock rearing Providing there is no direct connection to rivers and streams there is little likelihood of interaction between farmed and wild stocks which could spread fish infections and parasites In the case of fish farms in open water (rivers and lakes) there are well known risks of the spread of disease which can arise if overstocking occurs Intensive feeding of large numbers of fish in a confined area can lead to significant deterioration in water quality through the build up of nutrients from wood and waste It is also possible for antibiotics and growth hormones to be dispersed beyond the area of farm cages Genetic modification of farmed fish can also affect the local fish population through escapes All of these issues are capable of being managed and mitigated through good initial planning and design and subsequent maintenance and supervision It will therefore be necessary to develop additional regulations and guidelines specifically for the aquaculture sector 63 SUMMARY OF ENVIRONMENTAL RISKS AND OPPORTUNITIES Review of the full range of governance and development activities suggests that there are no high levels of risk to the marine or littoral environment Successful implementation of the Policy and plan should in fact result in very significant environmental gains Over a timespan of 5-20 years five activities in particular should result in significant improvements in the condition of the sea bed in coastal waters (to a depth of 30 metres) reestablishment of benthic flora and niche habitats increased fish stock and enriched biodiversity These interlinked activities are bull The exclusion of industrial vessels and trawling within coastal waters bull Regulation of fish catches through zonation seasonal control of fishing and standards for vessels
gear bull Stabilisation of the fishing fleet within sustainable harvesting yields bull The adoption of management plans formulated and agreed with full cooperation of local
communities bull The introduction of fishing rights through co-management agreements and bull Well planned consultation and information dissemination throughout the fisheries sector
52
Three components of the development plan have been identified where minor to moderate risk to the physical and biological environment could arise if proper design and implementation standards are not adhered to These relate to bull A potential risk of over-exploitation of new catch species in deep water off the continental shelf if
such development is not accompanied by through research to establish the sustainable yield of target species
bull Strictly localized effects on the physical environment from construction of landing wharves or jetties and other harbour facilities and
bull Infrastructure development at the existing ports of Tema and Takoradi All of these risks are capable of being fully managed by improved governance in the fishing sector and EIA procedures that are well-established in Ghana 64 SUMMARY OF SOCIO-ECONOMIC RISKS AND OPPORTUNITIES Implementation of the Plan Project will bring about substantial change in the fisheries sector and over time increased revenue reduction of post[harvest losses and added value to fish products will bring major economic returns At the same time there will be some individuals who do not participate in direct gains and whose livelihoods could be adversely affected if appropriate safeguarding measures are not put in place The level and extent of these socio-economic risks will be determined by 1 the level of commitment that is entered into by Government and its development partners to
deliver incentives to vulnerable and disadvantaged groups and 2 the speed with which the sector is transformed Rapid change could cause significant
displacement of less-efficient operators especially within the semi-industrial and canoe sector which would have serious ramifications for dependent communities However these effects can be marginalized if the development programme is carefully phased to ensure that alternative livelihood and employment incentives are available
The main risks to local livelihoods relate to the potential for bull loss of employment for crews of unseaworthy obsolete vessels ( from all sectors including
industrial semi-industrial and canoes) that are withdrawn from the fishing fleet because they no longer comply with license regulations
bull the inability of vulnerable and disadvantaged groups including artisanal fishers vendors and individual fish processors in small fishing villages to adjust to new market conditions at selected landing sites
53
CHAPTER 7 ASSESSMENT OF POLICY OPTIONS
71 INTRODUCTION
In order to place the significance of the environmental and social safeguards assessment in context this chapter examines the possible consequences of different policy responses to the existing challenges that face the fisheries sector in Ghana These different policy responses range from a continuation of the status ndashquo effectively a ldquodo-nothingrdquo option (A) to full-scale commitment by all stakeholders to achieving a sustainable fisheries future the ldquoOptimum Solutionrdquo option (C) Various less sustainable outcomes lie in between these two ends of a continuum of policy choices and these are represented by the ldquoWeak Solutionrdquo option (B) 72 OPTION A ndash DO NOTHING Background research and discussion with stakeholders indicates that practical capacity to deliver on clearly stated national goals for sustainable fisheries livelihoods and the reduction of poverty is weak This situation exists despite the fact that Ghana has a strong legal framework for management of its fisheries including the Law Policies and Regulations There is inertia and strong resistance on the part of the majority of players to accept that it is largely their own actions which are responsible for present conditions This in turn leads to the attitude that it is only the lsquoGovernmentrsquo that must act by providing increased subsidies and cushioning the industry against further deterioration in catches Unfortunately there is overwhelming evidence from around the world that where fish stocks are exploited beyond their natural capacity to regenerate this can lead to sudden and near-total collapse Ghana has historically been one of the strongest fisheries in West Africa but the signs are ominous that current levels of exploitation are leading to progressive decreases in annual catches for most species in both marine and inland waters As fishing effort intensifies with an increasing number of all types of vessel using illegal methods and inappropriate gear the distinction between the traditional lsquopeak season and lean season (linked to migration patterns breeding cycles and upwelling) is becoming blurred This is clearly illustrated by a statement from one of Elminarsquos fish mammies ldquowe use to smoke the herring in the peak but now the fishers bring them all the yearrdquo Use of monofilament nets light dynamite and chemicals to obtain fish in the lean season is aggravating a situation where too many boats are chasing too few fish Many fishers blame the reduction of catch on global warming for increasing water temperature the emergent oil and gas industry for restricting access to traditional fishing grounds and industry and urban development for increasing pollution leading to deterioration in water quality Each of these assertions warrants careful consideration but the industry is generally in denial when it comes to the primary fact ndash too many fish including juveniles are caught to allow regeneration of the stock In addition weak governance and lack of resources to ensure implementation of policy result in a situation where the law can be ignored with impunity If collective failure to recognize the seriousness of the current position and lack of commitment to taking hard decisions continues the omens for the future are not good Within a period of 10-15 years fish catches could fall by 50 or more from their present level Impacts on each species would vary and catches of some fish with regional or global migration patterns could remain viable (although this depends on the international conservation effort) On the other hand stocks of fish that provide the mainstay of local food resources herring and sardine could be decimated
54
Complete collapse of all fish species is unlikely but it is possible to envisage a situation where catches might fall below 300000 tonnes a year by 2025 (a reduction of more than 25 from present levels) The most serious consequences would be felt as a result of the social and local economic impact on fishing communities Perhaps 30000 men representing the crews of 3000 canoes and semi industrial boats and 15000 women engaged in marketing and processing would lose their present livelihoods Population migration away from the coast could follow and severe social pressures and local economic hardship This is clearly a ldquoworst caserdquo scenario and if conditions were to worsen gradually it might be possible to intervene but the fact has to be accepted that fish stocks are dynamic and subject to rapid decline (as in the case of the North Sea Herring and Atlantic Cod) 73 OPTION B THE lsquoWEAKrsquo SOLUTION The bleak future painted in Option A is unlikely to arise if the present policy and draft fisheries development plan is followed since these are specifically directed to addressing the major challenges However realization of the aims is dependent upon delivery across a wide range of initiatives by multiple stakeholders The following paragraphs illustrate some of the ways in which delivery of policy objectives might be thwarted These may be summarized as
bull Commitment to good governance and institutional reform bull Political resolve to implement unpopular measures bull Availability of adequate technical and financial resources bull Inertia to necessary changes in fishing practice
Good Governance and Institutional Reform Fundamental reforms are required to fully equip the national fisheries management effort at government level This includes introduction of change management clarification of responsibilities for senior staff rationalization of financial management systems provision of equipment expansion of staff numbers additional training and capacity building As an illustration of the extent of the effort required reference can be made to just one topic area the issue of monitoring control and surveillance At present the Fisheries Commissionrsquos MCS Unit has only 10 employees to oversee implementation of the fisheries regulations throughout Ghana This number will be increased as other institutions are engaged in joint monitoring initiatives but it is obvious that staff numbers and capacity will need to be expanded if regulations on fishing activities are to be affected Enforcement is only one part of the equation however Much greater emphasis will need to be placed on voluntary controls and self-policing at community level through Co-management schemes
Failure to press ahead with governance and institutional reform could delay the process of introducing and registering licenses which represents a crucial first step in moving from open access to managed access in the fisheries sector Given the urgency for action the five years allowed in the current plan for completing the registration process seems very generous Political resolve to implement unpopular measures Stakeholder meetings have confirmed the significance of party political influence as a constraint on achieving progress in the reform of the fisheries sector The offer of incentives like subsidies or the promise of new facilities and equipment are regularly employed by individual politicians to garner votes whether or not these form part of party manifestos Examples have been quoted to the consultants where enabling regulations that might restrict fishing access and prove unpopular amongst the fishing community are quietly ignored and officers may be discouraged from pursuing breaches of the law where the offender has political influence These issues arise with governments of all political
55
persuasions and can apply at all levels from District Assemblies through to regional and national committees
A serious issue with fisheries sector reform is that once actions have been taken to conserve fish stocks it may be years before the full benefits are felt and the results are evident in terms of increased catches This makes it harder for governments to institute unpopular reforms ndash even though these are in the best interests of the nation fishing communities and individuals Fishermen and their families are used to seeing an instant lsquosame day returnrsquo on their catch and are less willing or able than stakeholders in other economic sectors to wait for gradual improvements There is an urgent need to establish cross-party support for the fisheries sector in Ghana and to seek agreements between the main political parties to support established policy and regulations where these are in the interests of delivering sustainable fish stocks Availability of Technical and Financial Resources The process of moving from complete open access to restricted use rights for both marine and inland capture fisheries will take many years to complete Progress will be heavily influenced by the level of political will availability of technical assistance and financial support Existing subsidies (pre-mix fuel and import tariffs) are seen as a deterrent to the encouragement of more efficient business practices However in order to reduce dependencies on these forms of government aid there is also a need to underwrite new forms of economic enterprise by giving help to start-up businesses developing training centres and promoting alternative livelihoods for those individuals who are either displaced or voluntarily give up work in the fisheries sector Inertia to Change Traditional fishing practices are quite literally a way of life for many Ghanaians and have been handed down from generation to generation These traditions are closely interlinked with cultural practices and power and influence resides in specific families with hereditary authority In order to change attitudes and gain acceptance of new approaches to fishing there is a need for a major awareness building and communications strategy targeting in particular the traditional leaders of the fishing industry Without such a plan it will be difficult to break down the internal resistance and inertia towards change The constraints that have been outlined above in relation to the lsquoweakrsquo option are very real and in combination they present a serious barrier to progress It will require real political commitment on the part of Government and strong financial support from international partners to break down these barriers 74 OPTION C THE lsquoOPTIMUMrsquo SOLUTION
The new Draft Fisheries and Aquaculture Plan together with the Act and Policies provide a solid foundation for revitalising the fisheries sector in Ghana However for the reasons discussed in relation to options A and B above there are a number of impediments that need to be overcome In addition to the measures in Option B an ldquoOptimumrdquo solution would also include
A coherent mix of Incentives (carrots) and Regulation (sticks) A top priority in developing existing strategies and plans will be to ensure that measures are in place to offer encouragement and practical assistance to fishers to convert to more sustainable practices while at the same time introducing effective enforcement There are some real challenges with both of these goals
56
New forms of incentive need to be developed to convince boat owners and their crews that it is worth their while to drop illegal methods (dynamiting use of monofilament nets etc) and to reduce the level of fishing effort (through close seasons introduction of restricted zones etc) Without these incentives it is highly unlikely that there will be significant take-up of the fisheries stock management and conservation message Special attention needs to be given to the role of chief fishermen and local community councils in developing effective local policing since it is impractical to rely on a national MCS team to regulate canoe activity in either the marine or inland capture fisheries The national MCS team will have its own responsibilities for policing local and international waters in relation to industrial and semi-industrial sized vessels Integrated Coastal Development The long term success of the fisheries strategy depends upon reducing fishing effort to a level at which catches become both sustainable and profitable for those who remain in the business This in turn requires that those displaced from the industry are able to find gainful employment and livelihoods in other sectors of the economy The fisheries industry is often seen as a separate economic sector which attracts its own funding and support but in order for the necessary reforms to take place these attitudes will need to change A new approach is required to lsquointegrated coastal developmentrsquo following the lessons from integrated rural development Many fishing inland and marine fishing communities are almost wholly dependent on fishing with less than 10 of the local economy being devoted to other industries Reform of the fishing sector therefore requires that as much ndash if not more ndash effort is devoted by government and its international partners to building up complementary economic activities in construction transportation manufacturing food processing environmental conservation and tourism There is a need to explore new state industry partnerships to establish appropriate economic development agencies and to coordinate activities between relevant state institutions ministries and departments under the current decentralisation initiatives with district assemblies taking a prominent role If initiatives of this sort are taken forward it will make the task much easier in persuading conservatively ndashminded fishing communities that they need to simultaneously develop their own entrepreneurial flair and impose their own discipline
57
Chapter 8 DRAFT ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK (ESMF) 81 INTRODUCTION Previous chapters of this report have described the principal environmental and social impacts that are likely to arise from reform in the fisheries sector This chapter sets out the Framework (ESMF) for an Environmental and Social Management Plan (ESMP)The first step has been to outline specific objectives to be achieved through implementation of the ESMF These objectives relate specifically to the issues described in earlier chapters Subsequent sections of the chapter detail the measures which are required to respond to specific areas of environmental and social impact through mitigation and amelioration works They also describe the types and level of environmental monitoring required together with the institutional aspects which need to be improved in order to support the fisheries sector 82 STRATEGY AND OBJECTIVES The basic aim of the environmental and social management plan is to set out guidelines for participatory programs under which members of local fishing communities and civil society in general can become involved in the design and implementation of local fishery co-management maintaining sustainable local livelihoods and achieving local monitoring of fishery efforts The basic principle for future fisheries management is that both marine and inland waters will be demarcated as territories for use rights to fisheries (TURFs) The principal goal of government policy in the fisheries sector is to ensure that the fisheries industry plays an increasingly important role in supporting the growth of the economy as outlined in the Ghana poverty reduction strategy (GPRS II) and the Republic of Ghana fisheries and aquaculture policy This goal will be supported by implementation of the fisheries and aquaculture sector development plan over the next five years In this timescale the aim will be to bull improve management of fisheries the conservation of aquatic resources and protection of the
natural environment bull promote value addition in the fisheries sector and the improvement of livelihoods in fisheries
communities bull encourage sustainable development of aquaculture bull improve the services provided to the fisheries sector by the fisheries commission and supporting
institutions The overall consequences of this strategy and the investments that are being made by the government and its aid partners will be stabilisation of fish stocks and sustainable catch levels a strengthening of the national economy and creation of a more robust fisheries industry with consequent benefits for fishing communities Impact assessment confirms that the result will be significant benefits for the marine environment and local economy However depending on the rate of transition from an open access to a fully regulated market a number of adverse effects could arise unless appropriate mitigation measures are put in place Specific issues which require attention in this plan are listed below bull potential risks of environmental degradation through development of new fishing targets in
deep water
58
bull localised environmental impacts at construction sites bull loss of resources for individual operators due to restricted or controlled access to fishing
grounds bull displacement of labour from crews of vessels that are withdrawn from the industrial and semi-
industrial fleet bull Decommissioning of obsolete industrial vessels may not necessarily lead to recovery of fish
stocks Catch Per Unit Effort (CPUE) may increase This could lead to loss of livelihoods to crew members and the owners of the decommissioned vessels it could increase catch for the few vessels remaining in the system
bull increase production costs due to idling time in closed seasons for fishing bull exclusion of some groups and individuals seeking entrance to the industry following completion
of licensing bull concentration of processing and marketing at selected landing sites leaving Fish Mammies and
their dependents in other smaller fishing communities at an economic disadvantage bull displacement of traditional canoe building and other ancillary support industries by more
efficient and modern methods of construction and the inability of some workers in these trades to train and re-skill in the use of modern materials
bull lack of employment opportunities in alternative sectors The ESMF will set out specific actions to address these concerns through a coordinated set of interlinked proposals as follows 1) Preparation of local management plans and close surveillance of all new fishing enterprises in
deep waters
2) Preparation of environmental protection clauses to be included in all contracts and agreements for physical development work
3) Regular inspection by environmental protection officers of construction work at harbours and landing sites
4) Establishment of community management plans to provide support to those groups and individuals who are adversely affected by any of the measures listed above
5) Creation of community liaison groups to actively support community development alternative livelihoods and conversion to new areas of economic activity for those Fisher families or individual fishers who are adversely impacted
6) Introduction of skills training centres and business advice for small and medium enterprise development
7) Establishment of a coastal development agency drawing on the resources of the ministry of local government agriculture and tourism (others to be added) to coordinate integrated projects and initiatives for economic development linked with the existing coastal zone management plans
8) Creation of a liaison group between the government of Ghana and its international development partners to ensure that investment in the fisheries sector is targeted in the most effective way to deliver plan objectives and avoid duplication of effort
59
83 COMPONENTS OF THE ESMF The following paragraphs provide a summary of the draft ESMF 831 Local Management Plans these plans will be prepared for discrete zones of influence around specified fishing settlements Each plan will contain the same standard list of relevant activities that are to be monitored 832 Environmental Protection In relation to construction activity a checklist will be prepared identifying precisely what level of environmental scrutiny is required for specific types of development This checklist will be prepared by the Fisheries Commission with the support and advice of the Environmental Protection Agency 833 Small-Scale Project Development and Livelihood Restoration a list of potential micro-projects will be prepared by the Fisheries Commission which are regarded as suitable for support funding Demand for these micro-projects will be determined at the local level (ie in villages and fishing communities) Applications for funding of micro-projects will be submitted to the community liaison group for vetting and recommendation based on pre-established eligibility criteria Recommended projects will be referred for formal approval at national level (or through the Coastal Development Agency) 84 POTENTIAL PROJECT IMPACTS ON ASSETS AND LIVELIHOODS The project will have some adverse impacts on assets and livelihoods Therefore provisions will be made under the ESMF to minimize all such impacts including those of socio- economic significance and on any environmentally sensitive sites Provisions are also made in the RPF to accommodate all potential situations including cases that may entail actual displacement and livelihood restoration assistance in accordance with the Governmentrsquos policy and World Bank Policy on Involuntary Resettlement OP412 (see Chapters 9 and 10) The potential social and environmental impacts associated with the project (see Chapters 5 and 6) are summarised in Table 81 and the approach to related mitigation measures is defined in section 85 and Table 82 below
Table 81 Potential Environmental impacts and Social issues
Type of Activity Description Environmental Significance
Social Significance
Decommissioning of obsolete industrial vessels
Scrapping of vessels may release toxic waste (contaminated oils asbestos pipe wrapping and insulation etc)
Contamination of landfill dumps
Related health hazards
Laying off of work force Recovery of fish stocks in areas currently over-fished by trawling
Decommissioning of excessovercapacity would result in loss of livelihoods for crew members
60
Plan for fishing capacity reduction
introduction of licensing system for canoes and enforcement of licensing system for semi industrial vessels
Reduced catch from the decline in the use of prohibited fishing methods (activities) as stipulated in the Fisheries Regulation 2010 (LI1968) eg use of light dynamite etc
Reduction in fishing capacity should lead to significant recovery of fish stocks with long term benefits for all
Short term reduction in fishing effort and increased regulation may prejudice vulnerable sectors (illiterate elderly fishers) Capping on new entrants may remove the safety net opportunity offered by fisheries to would-be fishers who may be without alternative livelihoods
Harbour development and landing site improvements
Construction of access road improvements Erection of fish processing and ice making plant The Project could give rise to a small level of physical displacement for some sectors of individual communities
Removal of shelters homes Displacement of boat repair and trading sites for local community
Possible non-voluntary resettlement including vulnerable groups (women children and the elderly)
Adaptation Strategies to climate change
Introduction over time of regulations relating to fishing activity in rivers lakes estuaries lagoons and lsquoareas of upwelling affected by climate change
Measures to combat tackle rising temperature and other climate induced changes should ameliorate environmental impacts
Both beneficial and adverse effects may result from changes in climate (eg faster growth rates from higher water temperature spread of invasive species)
Establishment of exclusion zones ndash oil production and marine protection areas
Restrictions on fishing in oil production areas and marine protection areas
Positive ndash recovery of fish stocks but also potential risks of pollution from oil leaks and human waste
Temporary loss of livelihood for those fishers displaced from lsquotraditionalrsquo fishing grounds
Development of Co-Management System
Creation of 4 pilot Stakeholder ndashbased Fisheries Management Initiatives
Demonstration of practical benefits for the marine environment resulting from elimination of damaging practices
Greater social cohesion and sense of purpose established
61
Type of Activity Description Environmental Significance
Social Significance
Support for PAPs Establishment of enterprise training programmes
Development of criteria for defining Project Affected Persons (PAP) Development of skills training schemes enterprise allowances alternative livelihoods fund
Major benefits for PAPs ndash but scope for misinterpretation mismanagement of programme at local level Jobs created under social significance should be familiar to the fishers ie things they will be willing to do
Developing Compliance Systems
Establishment of enforcement unit and development of facilities and training for participatory coastal surveillance of small-scale fisheries
This component will greatly improve controls over environmentally unfriendly damaging activities
A number of new jobs should be created under this programme
Improvements in fish processing technology
Development of more efficient fish processing plant
This measure should reduce significantly the proportion of fish lost or degraded post harvest Improved fish processing technology will also reduce wood used from the forest as firewood for fish smoking
Potential displacement of vulnerable groups (women children and the elderly)who currently participate in fish drying curing using basic equipment
Construction of fish ponds
Expanding areas of dug-outs and other farm ponds
Small scale impacts on vegetation stream flow
Displacement of existing land users
Catalysing aquaculture development
Encouragement of larger fish farming enterprises Installation of fish cage aquaculture
Localised deterioration in water quality increased nutrients leading to eutrophication potential spread of fish parasites disease
Potential competition with free capture fisheries displacing vulnerable groups in existing fishing villages
62
85 PROPOSED MITIGATION MEASURES AND COST ESTIMATES Mitigation measures The potential environmental and social impacts to be addressed within the context of preparing this Environmental and Social Management Framework are generalized as shown in Table 82 below It is not possible at this time to prepare specific mitigation measures It is expected though that environmental and social assessment studies will be carried out within specific localities as and when required The framework for compensationresettlement (See Chapters 9 and 10) will then be applied incorporating (1) specific institutional arrangements (2) resettlementcompensation eligibility criteria (3) implementation procedures (4) financial responsibilities and (5) monitoring and evaluation plan Livelihood restoration measures Furthermore the livelihood restoration measures will consider issues such as
(1) income levels of affected persons
(2) other non-monetary sources of livelihood
(3) constraints and opportunities for income generation
(4) number of persons not able to revert to previous occupation and
(5) existing skills of affected persons
Table 82 Proposed mitigation measures for some potential impacts
Type of Impact Description of mitigation measures
1 Decommissioning of obsolete industrial vessels
a) A register will be prepared of all industrial vessels that are due to be decommissioned recording the owner and location of each vessel b) A system will be introduced for tracking progress on decommissioning including the means of disposal and measures taken to dispose of all potentially toxic or hazardous materials c) Persons who lose their job or livelihood as a result of a decision to decommission any particular vessel will be entitled to benefit from the skills training schemes enterprise allowances alternative livelihoods fund being developed
2 Plan for fishing capacity reduction
a) A full Social and Environmental Impact Assessment will be carried out on the Plan for fishing capacity reduction and appropriate measures for ameliorating and mitigating adverse effects on affected sectors of the community and PAPs will be incorporated in a revised edition of this Fisheries Environmental and Social Management Framework
63
3 Harbour development and landing site improvements
a) All harbour development proposals will be subject to Environmental and Social Impact Assessment (ESSA) in accordance with EPA Regulations b) Proposals for improvement of individual landing sites will be assessed in accordance with the checklist (832) and submitted to EPA for a ruling on the level of environmental assessment that is required which will depend on the nature of the intended works
4 Adaptation Strategies to climate change
a) An adaptation Strategy shall include proposals for mitigating any impacts on the environment or social welfare of local communities
b) Any strategy for responding to potential effects of climate change on the fisheries sector will be submitted to EPA for review to determine whether an SEA or EIA is required
5 Establishment of exclusion zones ndash oil production and marine protection areas
a) Proposals for restricting access of fishing vessels to oil production areas and marine production areas shall be subject to an Environmental and Social Assessment which shall be submitted for approval to EPA b) In the event that restrictions are likely to adversely affect fishersrsquo livelihoods the provisions set out in 7 below will apply
6 Development of Co-Management System
a) Development of co-management systems will require full cooperation and engagement of all stakeholders In the unlikely event that the provisions of any scheme are challenged by local communities there shall be a right of appeal to the Minister of Food and Agriculture and the Fisheries Commission acting jointly
7 Support for PAPs
Establishment of enterprise training programmes
a) Identification of vulnerable people including women children and the elderly and identification of the cause and impacts of their vulnerability shall be established through direct interviews and procedures to be developed as part of 6 above b) A high priority within the Fisheries and Aquaculture Sector Development Plansrsquo first five year programme will be the development of specific proposals for the establishment of skills training programmes and the establishment of enterprise allowances and an alternative livelihoods fund c) The measures outlined in 7b) above will be targeted specifically at PAPs and vulnerable sectors of the community
8 Developing Compliance Systems
a) All proposals for securing compliance with fisheries regulations shall be subject to review by a fisheries stakeholder committee to be established by the Fisheries Commission with the remit of ensuring that the measures themselves and penalties for failure to comply are commensurate with the ability of offenders to make restitution and do not unfairly penalize vulnerable sectors of the community
9 Improvements in fish processing technology
a) All plans and proposals for the introduction of new fish processing technology shall be published and shall include a statement on the likely impact of the project on existing processors within the local community
64
b) Any members of the public who consider they are unfairly disadvantaged by proposals for the introduction of new technology may apply to the local co-management committee to determine whether or not they fall within the category of PAP (see 6 and 7 above)
10 Construction of fish ponds Proposals for the construction of new fish ponds shall be assessed in accordance with the checklist (see section 832)
11 Catalysing aquaculture development
a) All proposals for aquaculture development shall be in accordance with the provisions laid down in Local Management Plans applying to specific TURFs
65
8
however significant change is within the fishing industry and particularly onshore processing and marketing of fish products An important element in this report has therefore been the need to define the point at which the banksrsquo responsibilities are seen to terminate and all liabilities are transferred to other supporting donors and the government of Ghana In the short term a reduction in the industrial fleet may lead to the loss of 1000 to 3000 jobs for crew members although in practice most of this work is only part time and many of the vessels that are due to be withdrawn are no longer seaworthy In the longer term it is intended to encourage more selective fishing by limiting open and unfettered access to fish stocks eliminating illegal and damaging processes including dynamiting uncontrolled light fishing and the use of small size monofilament nets and introducing seasonal restrictions to protect breeding cycles The intention is that these measures will be managed jointly by the government and communities through co-management systems At the same time major efforts will be made to reduce the level of post-harvest losses and to increase the value of fish products The expectation is that the number of industrial semi-industrial vessels and canoes will be stabilised at a fixed lower level within five years Once this point is reached and no further licences are granted individual licences will acquire higher values especially as fish stocks recover and the size and value of fish catches starts to increase Subsequently licenses are likely to be sold and traded as less efficient owners drop out of the market and sell on to stronger individuals and companies In terms of onshore activities fish landing processing and marketing will become more efficient and losses will be reduced through use of better smokers freezing and drying equipment Previous studies in West Africa and elsewhere (Bennett et al 2001) have shown that the transition away from open access to a more regulated system of access management can give rise to social risks Specifically older men are likely to be displaced when they are no longer fit enough to withstand the rigours of fishing while a rising number of young men may find it harder to enter a career in fishing Women who currently manage or assist with all areas of buying processing and marketing using traditional clay ovens may also experience competition as new companies and enterprises are established to take advantage of higher profitability in the fishing sector perhaps using better equipment newer technologies and different logistics arrangements or their own transportation Methodology This study has followed the methodology developed within the process framework for the West Africa regional fisheries programme (WARFP) Figure 1 sets out both sequence and timescale for the work
The range of jobs at risk is based on assumptions about the number of vessels and average crew size and cannot be determined with any degree of accuracy until the necessary surveys are undertaken
9
The report is based on three major areas of activity 1 documentary analysis and utilisation of the studies already carried out by the fisheries commission 2 meetings with institutional stakeholders principally affected by the project and 3 Consultations and visits to some of the key fishing villages and communities The planned presentation of findings to Stakeholders has been postponed at the Clientrsquos request due to other pressing commitments in the agriculture and fisheries sectors This presentation will however need to be subsequently undertaken by the Ministry and the Fisheries Commission
11
CHAPTER 2 PLAN AND PROGRAMME DESCRIPTION
INTRODUCTION This chapter is divided into two parts Part 1 sets out the progress which the government Ghana is making in giving effect to the legislation policy and regulations Part 2 describes the proposed programme of assistance being offered by the World Bank with the specific aims of strengthening governance and enforcement systems (Components 1 and 2) and in promoting value addition and reduction of post-harvest losses
PART 1- THE DRAFT FISHERIES AND AQUACULTURE SECTOR DEVELOPMENT PLAN (FASDP) This plan (FASDP) covers the period 2010-2015 It recognises the importance of Ghanarsquos fisheries which generate in the order of US$ 1 billion a year contribute 45 to GDP and indirectly support the livelihoods of 22 million people However through over-fishing and lack of investment in management and value addition the average income per canoe has dropped by up to 40 over the last ten years to the point where it costs as much to fish as the catch is worth By comparison well managed fisheries in other parts of the world are capable of generating economic returns of 30-60 on investment (equivalent to a potential income of US$ 300 million a year for Ghanarsquos fisheries) The Draft FASDP acknowledges that the fishing sector is expected to make a substantial contribution towards doubling the size of the Ghanaian economy by 2015 (GPRS II) as part of the Republic of Ghana Fisheries and Aquaculture Policy Seven targets are set in the draft FASDP 1 Maintaining capture fisheries production at current levels 2amp3 Increasing revenue and profitability in capture fisheries by at least US$ 50 million a year after
five years 4 Increasing aquaculture production to 35000 tonnes a year after five years 5 Retaining Ghana as a landing and processing hub for the West Africa tuna industry 6 Developing fisheries management to allow effective control of all commercial fishing effort in
Ghanaian waters and 7 Ensuring fisheries management costs are sustainable and that the fisheries sector overall make a
fiscal contribution to Government revenues There is an underlying presumption that the canoe sector will remain at the heart of Ghanarsquos fishing industry but the plan is not prescriptive and leaves open the ways of achieving the overall goals At the same time there is an underlying assumption that the long term sustainability of Ghanarsquos fisheries will depend upon discouraging further entry by new operators
PART 2 THE WORLD BANKrsquos CONTRIBUTION TO GHANA FISHERIESPLAN (FASDP)
The essential aim of the World Bankrsquos contribution to FASDP is to provide investment which will build the necessary policy and capacity for effective fisheries management designed to reduce fishing effort while maintaining approximately the same catch levels and to address the impacts of change for fishers
12
and the communities in which they live Based on the currently available draft Project Appraisal Document (PAD) each of the components is now described in turn Component 1 - Good governance and sustainable management of the fisheries This component on good governance comprises four subcomponents which are broken down in turn into a number of separate activities Sub-component 11 developing the capacity rules procedures and practices for good governance of the fisheries Activity 111 reviewing the Fisheries Act and developing regulations to support the Sector Policy and the Fisheries and Aquaculture Sector Development Plan Activity 112 Developing an operational policy to enable implementation of the aquaculture and fisheries sector development plan Activity 11 3 strengthening fisheries management systems and capability (fisheries management plan development aquaculture implementation technical support and training) Activity 114 strengthening fisheries Information Systems (catch recording and monitoring systems statistical analysis and training)
Sub-component 12 introducing fishing rights
Activity 121 developing pilot stakeholder-based fisheries management initiatives around defined fisheries units (ie local management initiatives tighter defining fisheries resources in up to 6 selected Fisher communities) Activity 122 introducing and administering a licensing regime
Subcomponent 13 Adjusting fishing effort and capacity to more sustainable levels marine resource conservation and supporting alternative livelihood opportunities when needed Activity 131 vessel decommissioning Activity 132 compensation packages for crew of decommissioned industrialsemi-industrial vessels Activity 133 alternative livelihood development to incentivise voluntary capacity reduction in the canoe sector Activity 134 marine resources management and conservation
Subcomponent 14 social marketing communication and transparency Activity 141 communications stakeholder consultations and awareness raising programmes to support fishery development Component 2 reduction of illegal fishing Under the West Africa regional fisheries programme subcomponent 21 allows for enabling environment for reduction of illegal fishing These provisions already exist within Ghana and this subcomponent is therefore omitted Subcomponent 22 monitoring control and surveillance (MCS) systems Activity 221 developing compliant systems and capability
13
Component 3 increasing the contribution of the marine fish resources to the local economies Subcomponent 31 product diversificationvalue chain development (freshfrozen producttrade facilitation) Activity 311 landing site development Activity 312 Port development Subcomponent 32 fish product trade infrastructure information and systems - regional minimum integrated trade expansion platform (MITEP) Activity 321 export certification centre development Activity 322 fish processing technology improvements Activity 323 national fisheries advisory group Subcomponent 33 marine and inland aquaculture development Activity 331 space developing aquaculture policy and legal framework Activity 332 improving genetic policy of tilapia fingerlings and breedstock Activity 333 catalysing aquaculture development Component 4 Coordination monitoring and evaluation and program management Subcomponent 41 national implementation subcomponent 42 regional coordination Each of the components sub-components and activities are described in more detail in Chapter 5 which assesses the nature of environmental and social safeguards issues in terms of the World Bankrsquos planned investment
15
CHAPTER 3 BASELINE CONDITIONS
INTRODUCTION This chapter discusses the existing fishery resources of Ghana and describes recent environmental and social trends It identifies some of the pressures that led to the reduction in value of fishing activity and indicates the threats that could be posed if no action is taken in accordance with the planned fisheries and aquaculture program to deal with them FISHERY RESOURCES The continental and coastal waters of Ghana are potentially very rich due to a combination of warm waters and nutrients carried in ocean currents which up-well seasonally on the continental shelf The tonnage of fish caught in marine waters peaked in the mid-1990s around 500000 tonnes and currently averages around 400000 t(See Figure 1) Figure 1 Wild Capture Production in Ghana 1950-2005
2
Table31 Top 10 Species Exported (by value)
1 Canned tuna ($72000000) 2 Fresh tuna ($7200000) 3 Tilapia (no figure available) 4 Miscellaneous dried fish ($1000000) 5 Salmonids frozen ($900000) 6 Marine fish frozen ($600000) 7 Cuttlefish and squid ($600000) 8 Shrimps and prawns ($90000) 9 Sardines ($80000) 10 Crustaceans frozen ($50000) Source FAO Fishstat
The principal catch from deep waters is tuna Industrial vessels registered in Ghana target these species in international waters but also illegally in coastal waters Herring sardine and anchovies are fished in coastal waters by semi-industrial vessels and canoes Table 31 shows the top 10 species of fish exported from Ghana in 2005 PROFILE OF THE FISHING INDUSTRY Fishing is of vital importance in Ghana not only in terms of its contribution to gross domestic product (45 per annum) but because fish provides 65 of the countrys protein In recent years (between 2003-2008) and more specifically in 2004 the countryrsquos annual fish requirement has been estimated to be 882000 tonnes of which the country produces just about half (Tetteh 2007) Of the total population of 22 million people it has been estimated that between 15 and 22 million people are employed or gain their livelihoods from fishing (8-10) Of these there are 210000 men who are directly employed as
2 This figure is the Fisheries Departmentrsquos estimate for 2008
16
fishers The total export of seafood was valued US$824 billion in 2005 Ghanas fishing industry can be divided into three sections marine capture inland capture and aquaculture It can be further analysed by scale of operations distinguishing between industrial semi-industrial and artisanal sectors Marine fisheries Industrial sector Commercial fishing for tuna began in 1962 In the early 1980s Ghana sought to develop an industrial fishing fleet and there are currently 90 industrial trawlers and other vessels which are located in Tema and Takoradi Sekondi The port of Tema was expanded from 1962 to create four main areas the Inner Harbour Outer Harbour Canoe Basin and Commercial Area In 1999 fish landing facilities were improved at the Albert Bosumtwi Sam Fishing Harbour built in Sekondi This harbour is equipped with a cold store an ice-making plant offices a berthing bay for inshore vessels a jetty for canoes and a net drying area Under Ghanaian law more than 50 of the ownership of industrial vessels must be registered with a Ghanaian company or individuals However in practice many vessels are owned by foreign nationals with token Ghanaian ownership Relatively few of these large vessels regularly put to sea and a number are in poor condition or obsolete Nevertheless the impact of trawling activities by Ghanaian registered and foreign owned vessels has been very considerable in coastal waters in recent years Fish landed from industrial vessels is usually transferred directly to Canning factories in Tema and Takoradi Ghana has the largest canning industry in West Africa In the region of 30000 tonnes of tuna are landed In addition to trawling some industrial vessels are engaged in shrimping the use of tuna lines and polls purse seining and demersal trawling Semi-industrial sector in addition to deep sea trawlers there are around 230 large semi-industrial ships propelled by inboard motors which are used for trawling in shallow waters during the off-season and purse seining during upwelling seasons There are currently reported to be 48 bottom trawlers 14 pair trawlers 2 shrimpers 33 pole and line vessels and 10 tuna purse seiners operating from 2 of the 7 landing sites Canoe sector Ghanas artisanal fishing sector is based on between 10000 and 12000 wooden canoes Fifty seven per cent of the fleet is powered by outboard motors supported by paddle and occasionally sail Each Canoe carries a crew of between three and 20 men depending on size and length There are over 334 landing sites along the 550 km coast of Ghana and the majority of fish caught by canoe (180000 tonnes) is returned to these sites accounting for 70 of Ghanarsquos fish production The principal landing sites are at Teshie Jamestown Chorkor Shama Axim Elmina Winneba Mumford Akplabonya Adina Atiteti Abutiakope and more Fishing is undertaken by men but the majority of canoes are owned by women who pre-finance fishing trips (purchasing gear and premixed fuel) and purchase the catch Women also predominate in processing and marketing fish and fish products Only about 20 of fish sold fresh a further 20 is salted and the majority (60) is smoked It is estimated that up to 30 of the catch is spoilt through lack of ice for storage or alternative processing facilities
17
Inland fisheries Water Resources Ghanarsquos inland fishery resources consist of a natural lake( Lake Bosomtwe) and nine major river basins which from east to west of the country are
bull the Volta bull Densu bull Ayensu bull Ochi bull Kakum bull Pra bull Ankobra and bull the Tano
The River Tano forms the border between Ghana and Cote drsquo Ivoire The largest of the rivers is the Volta which drains more than two-thirds of the country through several large tributaries in virtually all regions of the country The Volta river system also incorporates the Volta reservoir generally known as the Volta Lake which has a surface area of around 8400 km2 The Volta lake discharges through the Akosombo dam before flowing through a delta into the Atlantic Ocean The eight other river systems are relatively smaller simpler and open more directly into the Atlantic There are also several reservoirs created on the smaller river systems mainly for potable water production irrigation and flood control These reservoirs irrespective of their primary purposes enhance availability of more permanent aquatic habitable space for fish and therefore support some fisheries Finally with all the river systems opening into the Atlantic there are a series of lagoons and estuaries which act as interfaces between the rivers and the sea These water areas constitute another type of inland water resource for salt and brackish water fishes Inland Fish resources Within the inland water resources of Ghana there are over 150 fish species more than 90 of which are fished for food
In commenting on inland fisheries in Ghana it must be noted that virtually all available information on inland fisheries is obtained from the Volta Lake No national fish production records have been kept on the fisheries of the eight smaller river systems and the lagoons and estuaries Thus the usual statement that inland fish production constitutes about 20 of what the country produces should refer to fish production from the Volta Lake In practice the total inland fish contribution could more realistically be estimated at about 30-35 of national fish production This is a very considerable but understated contribution to national food security and nutrition
Fishing vessels The dominant fishing vessel on the Volta Lake is the canoe the majority of which are built from wooden planks On some other river systems while plank canoes predominate a small number are carved as dug-outs from single tree trunks There is some variety in sizes of the canoes depending on how many planks are used to build the boat and the size of tree trunk used in building a canoe The total number of canoes estimated on the Volta Lake during a survey in 2000 was 24035 On the tributary rivers of the Volta Lake and other river systems in the country the planked canoe is the main vessel used in fishing
18
Fishing gear There are about eleven main kinds of gear used for fishing on the Volta Lake They are Gill Nets Cast Nets Hook and Line Basket and wire mesh traps Winch net Beach seine Bamboo Nifa-nifa Wangara Spears and Atidzas On other rivers in the country Gill nets Cast nets Hook and Line and traps are the fishing gear used On both the lake and rivers the Gill net is the main gear
People Involved In the 2000 frame survey of the Volta Lake conducted by the Fisheries Directorate of Ghana the estimate of fishers on the Volta Lake was put at 71861 Fishers on the lake work in collaboration with a host of fishmongers or handlers who also function as wholesalers for individual fishing groups Assuming that the fisher population on the lake has increased by a modest 3 in the ten years from 1998 to 2010 a fisher population of about 93500 could be considered to be on the Volta Lake now If again it is estimated that number of fishers on rivers in the country were to be a tenth of those on the lake this would put the fisher population on inland waters (apart from the Volta Lake) at about 9350 fishers A very conservative estimate therefore puts the total number of individuals who are directly engaged in inland fishing at over 100000 This excludes all directly associated groups such as fish handlers processors and traders An estimate of secondary fisheries operators such as boat builders out-board motor operators and mechanics as well as bulk salt and fuel wood sellers and those engaged in buying selling and distributing fish would have to be considered in developing estimates for both direct and indirect employment in inland fisheries but the number can be assumed to lie between 125000 and 150000 people
Aquaculture Under Ghanarsquos legal framework aquaculture is defined as ldquoany activity designed to cultivate or farm fish and other aquatic living resourcesrdquo Currently only fin fishes are involved in aquaculture in Ghana
Current culture media and environment Currently fish culture takes place almost exclusively in fresh water in Ghana either in cages brush parks or dugouts Dug-outs are excavations made in floodplains in the savannah parts of the country were water scarcity has been a major hindrance to development in general and food security in particular Dug-outs get filled with flood waters and whatever the water carries during major wet periods of a year in the savannah areas Waters that fill Dug-outs invariably contain fish which are trapped in the Dug-out after the wet period These water bodies are managed until the end of the dry period and the fish are harvested before the next flood period Since the 1960rsquos various strategies to augment fish production from Dug-outs have been developed and tested These involve adding fingerlings of selected fish species to those which are lsquonaturally stockedrsquo in Dug-outs by floods Dug-outs are the major fish culture production approach in the savannah parts of the country which accounts for a little more than half the area of the country The Environment of fish culture Currently fish culture is taking place mainly in freshwater environments Brackish water fish culture and mari-culture activities which will bring lagoons estuaries and the sea into fish culture production have long term potential for development Fishes in culture Fishes being cultivated in Ghana In order of importance are Nile tilapia Oreochromis niloticus the African catfish Clarias gariepinus species of the catfish Heterobranchus and the Bony tongue Heterotis niloticus Scale of Culture Based on level of production fish culture operations can be categorized as follows
bull Large scale commercial where an enterprise produces up to 10000 tonnes per year
19
bull Medium scale commercial where a single enterprise produces between 50 and 500 tonnes bull Small scale commercial where an enterprise produces between one and 20 tonnes and bull Very small scale commercial with productions below 20 tonnes
Fish culture production Cultured fish contribution to national production was officially stated as 9000 tonnes for the year 2009 However informed opinion amongst fish farmers indicates that a figure of between 16000 and 20000 tonnes in 2010 would be closer to reality This statement is based on the facts that most producersrsquo published figures are underestimates several small to medium scale producers are not recorded in official lists and the recording of newly established fish farms has lagged actual establishment especially since 2009 Although cultured production up till 2009 may not have been significant considering a shortfall of about 460000 mt (as recorded in 2004) between captured fish production and national demand this reflected the fact that there were only two large scale commercial producers in the country each of which had had less than ten years of operation Anticipated growth in fish culture production within the next five years is expected to be dramatic as some of the critical challenges of the industry are resolved
CHALLENGES AND PROSPECTS Marine Fisheries The fishing sector is vital for food security and job creation to help alleviate rural poverty in Ghana However the levels of fisheries harvests are generally considered to be close to or to have exceeded the maximum sustained yield Future sustainability in the industry will depend upon the restriction of open access to fisheries and the introduction of management systems which allow fish stocks to recover and the establishment of consistent yields in both marine and inland waters Inland Fisheries Environmental conditions on the Volta Lake constitute the major environmental and social challenges for fisheries its sustainability and profitability In terms of future prospects success will depend heavily on implementation of the lsquoGhana Fisheries and Aquaculture Sector Development Planrsquo and the capacity of the system in Ghana to enforce the Fisheries Regulations passed by parliament in August 2010 Aspects of the Development plan that offers great prospects for the lakes fisheries include the provisions for eventually licensing boats (although the scale of this task should not be underestimated) and measures to involve communities in management of fisheries resources of the Lake
Aquaculture The main challenges facing aquaculture development in Ghana relate to bull The high cost of fish feed (significantly due to its importation from other countries) bull None availability of commercial fish hatcheries as enterprises bull Lack of a nation-wide distribution network for fish seed and cultured fish producers Most
sources of fingerlings are concentrated in one part of the country and since farms all over Ghana obtain their fingerlings individually transportation costs add significantly to overall production costs
bull Now emerging certification and monitoring to check the health and safety of aquaculture processes and products
bull The absence of adequate regulations regarding establishment of an aquaculture enterprise until August 2010 (In the absence of regulations only the large and medium scale commercial farms worked towards conforming to international performance Standards and operational regulations for certification of farms and their products still remain in a draft state)
bull Low national support for research to support expansion and systematic development of aquaculture
20
The prospects for development of aquaculture as an industry in Ghana are good since a number of practical policy and legal frameworks have been put in place to resolve the basic challenges to the industry listed above These include
bull Construction of the first local fish feed plant by an international fish feed company with the expectation of having initial products on the Ghanaian market during 2011
bull A lsquoLarge scale commercial fish farmrsquo with great capacity for fingerling production is shifting emphasis to fish seed production And several localized fish seed producers are expanding operations
bull Distribution strategies by cultured fish producers have started to emerge on a limited scale and are expected to evolve with increasing production as existing commercial farms expand and new ones join in
Now that regulations regarding establishment of aquaculture enterprises have been gazetted there is likely to be a positive response amongst fish farmers of all size categories New operational standards are being prepared which will introduce minimum standards for local certification This should set the stage for preparation of fish culture products and the broadening of choice for consumers while also qualifying Ghanaian producers to enter external markets
ENVIRONMENTAL CONDITIONS The coastal and marine environment a critical zone of influence for this study comprises a 550 km coastline a coastal belt ranging from 1 to 20 km in width and coastal waters extending to 200 nautical mile limit which was established in 1977(under the territorial waters and continental shelf act 1973 as amended by the territorial waters and continental shelf amendment decree 1977) The Coastal Belt The coastal belt accounts for only 65 of the land mass of Ghana but it is one of the most densely settled areas accounting for 25 of the population and80 of the industrial establishments in Ghana Historically the coastal zone was cultivated for coconut (copra) but this industry is in decline Vegetables and other agricultural produce are grown on better soils but the principal economic activities are fishing transportation salt production and sand and stone winning Tourism also offers great potential There is considerable expectation that the discovery of offshore oil and gas deposits will bring new wealth to parts of the coastal corridor However present plans to transfer crude products to tankers at sea and then export them directly will limit industrial activity to a support role A high percentage of industrial and municipal wastes is dumped at landfill sites within the coastal zone which creates pollution risks The coastal belt is generally a low-lying area less than 200 m above sea level Vegetation types reflect the rainfall gradient and consist of coastal shrub and Savannah to Winneba southern marginal forest to the east of Sekondi dry semi-deciduous and moist semi-deciduous forest to the east of Cape Three Points estuary and wet evergreen forest in the extreme south Soils are variable within this area ranging from fertile pockets river valleys to Sandy poorer quality soils close to the sea The Coast The coast line divides into three sections (Ly 1980)
bull West of Cape Three Points this area has a wide and flat beaches backed by coastal lagoons and
21
wave heights are generally low bull Between Cape three points and Tema the coast consists of a series of rock headlands enclosing
shallow bays together with sandbars or spits enclosing coastal lagoons The surf zone is a medium to high energy environment with wave heights often exceeding 1 m South-westerly prevailing winds give rise to longshore drift in an easterly direction
bull Between Tema and Aflao most of the shore is sandy although there are rocky outlets The coastal zone is important internationally in providing feeding roosting and nesting sites for thousands of migratory birds Environmental degradation is significant in Ghana and is recognized in the countryrsquos environmental action plan It contributes to rising poverty levels coupled with poor human health and inadequately planned urbanization which fuel a vicious cycle inhibiting human development The core issues include
bull Domestic sanitation bull Increased urbanization without appropriate infrastructure bull Wetlands and mangrove degradation bull Coastal erosion and bull General biodiversity loss
Briefly each of the above could directly or indirectly adversely influence fisheries and aquaculture separately or together For example in a recently completed study of water quality scenarios of the Volta Lake in relation to fish production as a component of a comprehensive study (The Challenge Program Project of Water amp Food) it was concluded among others that poor sanitation in highly populated fisheries communities adversely influenced water quality to the detriment of fish life and thus fish production With reference to aquaculture the same unsanitary conditions in highly populated shore communities adversely influenced water quality especially in terms of oxygen depletion when lake waters extend to the shore in high water periods This is a situation which has caused fish kills in cages because caged fish cannot escape lsquopollutedrsquo waters Degradation of wetlands and mangroves leads directly to a reduction in their capacities as spawning and nursery zones for both marine and inland water fishes which reduce fish production in both environments The situation outlined above is often contributed to by anthropogenic and industrial pollution due to urbanization without appropriate infrastructure Another issue linking human activity to a deteriorating environment is demonstrated by the encroachment of aquatic weeds on inland waters such as the Volta Lake Weed growth is accelerated by farming reservoir catchments which increases nutrient levels and the building of dams which reduce or cut off intrusion of sea water into rivers Currently as climatic change observable impacts such as floods seem to escape predictions The project could possibly contribute to mitigating against direct and indirect effects of climate change on fishing and aquaculture through investment into climate change orientation and education of fishers and fish farmers to mainly influence reasonable precautions they take Marine waters The continental shelf is relatively narrow projecting out to 25-35 km except in the area of Cape Coast to Salt Pond where it extends to almost 80 kms Sandy and rocky substrates which previously supported coral and seaweeds have been severely affected by former trawling activity which indiscriminately
22
dredges material from the seabed Coastal waters are enriched by freshwater discharges from the relatively small number of rivers and by two seasonal up-wellings which occur between late June and early October (the main upwelling) and January and March (the minor upwelling) The origin and driving mechanisms of these up-wellings are not fully understood and both their location and strength varies from year to year
Lake Volta and other inland water
Major environmental issues on the Volta Lake which might also be considered as challenges to sustainable fisheries on the major inland fisheries resource can be summarised as follows
bull The Volta Lake is known to be low in nutrients It therefore has low standing crops of phytoplankton and zoo plankton to support high fish production
bull The northern segment of the lake together with tributary rivers constitute the spawning and feeding grounds for majority of fish species in the lake during the wet season however these segments are intensely fished during the same period
bull The Volta Lake is divided into eight unequal strata with different distribution of boats per Km2 At the last estimation of carrying capacity in 2000 stratum V and II had the highest (527) and lowest(157) number of boatsKm2 respectively
bull The rate of siltation in the lake is considered to be increasing due to erosion associated with high rates of deforestation
bull A major challenge exists in getting fishers fishing communities and fishing entrepreneurs to understand and comply with fishing regulations aimed at conserving fish and fisheries resources
bull There is a lack of resources studies and research to support fisheries management of the Lake
bull High illiteracy exists amongst lake shore communities
bull Open access to the fish resources of the Lake has been in operation since its formation
bull Declining fish yields are occurring in the lake (468 Kgha in 1976 to 320 Kgha in 2003-MOFA) brought about by the constraints listed above
bull The commonly assumed estimate of potential fish production from the lake of around 75500 mtyr) is considered to be a serious underestimate since Stratum VII alone was estimated to produce 33800mtyr in 1996
bull The policy environment for aquaculture is currently strongly supportive of the industry and related enterprises
bull There is good quality and more than sufficient water to allow some kind of aquaculture to be developed in every region of the country with the Volta lake (about 8400 Km2) as the single most important water unit for fish culture Currently it appears that the free access to the fish resources of the lake has to some extent been applied to establishment of small scale caged fish culture enterprises a situation constituting environmental risk to investments of large scale commercial fish culture establishments in the lake
bull The Volta Lake is low in nutrients (Obeng 1964) resulting in a situation where higher fish yields could be sustained if greater quantities of fish feed were available
23
bull In Ghana the Nile tilapia O niloticus occurred naturally only in the Volta system Due to positive culture characteristics of the fish it has been moved into virtually all other river basins in the country The situation provides opportunities for hybridization of the Nile tilapia with other tilapia species native to the river basin into which the Nile tilapia has been moved
25
CHAPTER 4 POLICY AND LEGAL FRAMEWORK FOR ENVIRONMENTAL AND SOCIAL ISSUES
41 INTRODUCTION
Development and implementation of the Ghana Fisheries and Aquaculture Sector Development Plan and the World Bankrsquos supporting program need to be developed with full regard to existing international conventions national legislation policies and regulations This chapter highlights the main legislative and policy considerations for the protection of the environment natural resources fisheries and social and economic development It begins with reference to the World Bankrsquos safeguard framework and those of other donors This is followed by a section on the governance framework in Ghana
42 WORLD BANK AND OTHER DONORSrsquo SAFEGUARDS POLICIES
The World Bankrsquos safeguard policies exist to ensure that all projects which it finances are developed and implemented on environmentally and socially sound principles A range of different policies exist and these have been carefully considered to ensure that the Ghana Fisheries and Aquaculture Development Sector Development Plan complies with these safeguards All policies have been screened and those that have no bearing on the fisheries programme have been excluded from Table 41 below Table 41 lists policies which could have some applicability to the FASDP even if this interaction might be very slight It is important to stress that the comments in the third column of Table 41 relate to the entirety of the Fisheries and Aquaculture Sector Development Plan whose effects will continue to be experienced long after the World Bankrsquos financial support has been expended Most of the activities in the FASDP will have no effect in relation to safeguard objectives and where there are implications these are likely to occur at precise locations (for example at fish landing sites) rather than throughout the industry Where potential interactions have been noted the necessary mitigating measures are incorporated in the Draft Process Framework
Table 41 World Bank Safeguard Policies in Context
Safeguard Policy
Safeguard Policy Objective Brief Description and relevance to FASDP
OP 401 Environmental Assessment
This policy aims to ensure that Bank-financed projects are environmentally sound and sustainable and that the decision-making process is improved through appropriate analysis of actions and mitigation of their likely environmental impacts This policy is triggered if a project is likely to carry potentially adverse environmental risks and impacts on its area of influence OP 401 covers impacts on the natural environment (air water and land)
The majority of actions planned under FASDP will be beneficial to the marine environment and to inland waters However new construction activities could have impacts and depending on the project and the nature of impacts a range of instruments can be used to ameliorate and mitigate adverse effects while enhancing beneficial effects These include EIA environmental audit risk assessment and environmental management plans (EMP) The need for EIA and EMP is considered in this report
26
OP 404 Natural Habitats
This policy recognizes that conservation of natural habitats is essential to safeguard their unique biodiversity and to maintain environmental services and goods for human society and for long-term sustainable development The Bank therefore supports the protection management and restoration of natural habitats in its project financing as well as policy dialogue and economic and sectoral work Natural habitats comprise many types of terrestrial freshwater coastal and marine ecosystems They include areas lightly modified by human activities but retaining their ecological functions and most native species
This policy is triggered by any project (including any sub-project under a sector investment or financial intermediary) with the potential to cause significant conversion (loss) or degradation of natural habitats whether directly (through construction) or indirectly (through human activities induced by the project) This policy is applicable to the Ghana Fisheries Programme because the project focuses on the integrated management of natural habitats However by screening all proposals under the ESMF any sub-projects that might impact these habitats will not be funded
OP 409 Pest Management
The objective of this project is to (i) promote the use of biological or environmental control and reduce reliance on synthetic chemical pesticides and (ii) strengthen the capacity of the countryrsquos regulatory framework and institutions to promote and support safe effective and environmentally sound pest management
The policy is triggered if (i) procurement of pesticides or pesticide application equipment is envisaged either directly through the project or indirectly through on-lending co-financing or government counterpart funding (ii) the project supports an activity requiring the use of pesticides that may have negative effects on the environment The only instance in which this policy might be triggered by the Ghana Fisheries Programme is if aquatic herbicides or antibiotics were to be used in connection with aquaculture This is most unlikely but can be monitored through the implementation programme
OP 411 Physical Cultural Resources
The policy objective is to assist countries in avoiding or mitigating adverse impacts of development projects on physical cultural resources For the purposes of this policy ldquophysical cultural resourcesrdquo are defined as movable or immovable objects sites structures groups of structures natural features and landscapes that have
Under the Ghana Fisheries Programme construction and rehabilitation activities that could have negative impacts on cultural property will be avoided In the case of discovery of remains national procedures will be applied
27
archaeological paleontological historical architectural religious aesthetic or other cultural significance
OP 412 Involuntary Resettlement
The objective of this policy is to (i) avoid or minimize involuntary resettlement where feasible while exploring all viable alternative project designs (ii) to assist displaced persons in raising their former living standards income-earning capacity and production levels or at least in restoring them (iii) encourage community participation in planning and implementing resettlement and (iv) provide assistance to affected people regardless of the legality of land tenure
The policy covers not only physical relocation but any loss of land or other assets resulting in (i) relocation or loss of shelter (ii) loss of assets or access to assets (iii) loss of income sources or means of livelihood whether or not the affected people must move to another location The activities of the Ghana Fisheries Programme are likely to result in loss of assets or access to assets and loss of income sources or means of livelihood for some groups and individuals The potential for such losses will be carefully scrutinised and compensated for through the National Process Framework and Resettlement Policy Framework described in this report and appropriate procedures will be followed where necessary
Other donors and aid agencies including International and National NGOs play an active role within the fisheries sector in Ghana and their safeguards standards will be observed through operation of the Environmental and Social Safeguards Management Plan
28
43 THE GOVERNANCE FRAMEWORK IN GHANA
The Ministry of Food and Agriculture (MOFA) Preparation of Fisheries laws and policies fall under the responsibilities of the Minister of Food and Agriculture who in turn delegates functions including implementation to a semi-autonomous body the Fisheries Commission
The Fisheries Commission (FC) was established under the Fisheries Commission Act (625 2002) It oversees management regulation and utilisation of the fisheries resources of Ghana drawing on powers set out in the Fisheries Law (PNDC 256 1991) Fisheries Act 625 provided for the establishment of a more robust Fisheries Commission (FC) which is an amalgamation of the erstwhile FC and Department of Fisheries
Ten individuals constitute the Board which is led by a chairman (appointed by the President of Ghana in consultation with the Council of State) supported by three members drawn from the ministries of transport defence and environment There are three representatives from the following parastatal organizations - the Ghana Marine Fishing Officers Association Water Research Institute and Ghana Irrigation Development Authority- and two representatives (one from the artisanal and one from the industrial sections )of the National Fisheries Association of Ghana Finally the tenth member is a person with requisite knowledge of the fishing industry or natural resources renewal management
The day to day work of the Fisheries Commission is undertaken by the Department of Fisheries (DOF) which serves as the implementation secretariat of the Fisheries Commission as stipulated by the Fisheries Act 625 of 2002 Specific tasks that are undertaken by the Department of Fisheries include
bull preparing fishery resource management plans bull developing regulations for the fishing industry bull organizing monitoring surveillance and enforcement for the national fishery resources and
ensuring compliance with national fisheries law and institutionalizing co-management concepts
The MCS Division of the DoF (established under the Fisheries Sub sector Capacity Building project) works in conjunction with the Ghana Navy and undertakes sea patrols to exclude industrial fishing vessels from the 30-metre depth IEZ reserved for artisanal fisheries The MCS also conducts inspection of industrial vessels at the fishing ports of Tema and Takoradi for
bull valid fishing licences bull legality of fishing gear bull skipperrsquos certificate bull log book and crew composition
The MCS undertakes similar functions for inland fisheries on Lake Volta
The Ministry of Local Government and Rural Development (MLGRD) is responsible for managing fishers fish processors and fishery resources at district and sub-district levels which it undertakes through the District Assemblies In 2002 the District Assemblies in collaboration with DoF were mandated to facilitate fishery resource management by
bull helping to form and sustain Community Based Fisheries Management Committees (CBFMCs) bull cooperating with the DoF MCS units bull providing legal and financial support to the CBFMCs and bull approving levies proposed by the CBFMCs
29
Community-Based Fisheries Management Committees are charged with the responsibility of enforcing national fisheries laws at community level as well as initiating and enforcing their own by-laws
44 THE LEGAL FRAMEWORK
441 International Conventions
Ghana has ratified a number of international conventions and treaties which have an important bearing on the state of its marine and inland waters and the condition of the fisheries These are listed in Box 1 below
Box 1 International Conventions treaties and agreements to which Ghana is a signatory 1 International Convention for the Prevention of Pollution of the sea by Oil 21 October 1962 2 Convention on the Africa Migratory Locust 25 May 1962 3 Treaty Banning Nuclear Weapon Tests in the Atmosphere in Outer Space and Under Water 5th August 1963 4 International Convention for the Conservation of Atlantic Tunas 4 May 1966 5 Africa Convention on the Conservation of Nature and Natural Resources 15 September 1968 6 International Convention on Civil Liability for Oil Pollution Damage 29 November 1969 7 International Convention Relating to Intervention on the High Seas in Cases of Oil Pollution Causalities 8 Convention on Wetlands of International Importance Especially as Waterfowl Habitats 2 February 1971 9 Treaty and Prohibition of the Emplacement of Nuclear Weapons of Mass Destruction on the Seabed and the Ocean Floor and in the Subsoil Thereof 11 January 1971 10 International Convention on the Establishment of an International Fund for Compensation of Oil Pollution Damage 18th December 1971 11 Convention Concerning the Protection of World Cultural and Natural Heritage 16 November 1972 12 Convention on International Trade on Endangered Species of Wild Fauna and For a 3 March 1973 13 Convention on the Military or Any other Hostile Use of the Environmental Modification Techniques 10 December 1976 14 Convention on the Conservation of Migratory Species of Wild Animals 23 June 1979 15 Convention for the Cooperation in the Protection and Development of the Marine and Coastal Environment of the West and Central African Region1981(Abidjan Convention) 16 United Nation Convention on the Law of the Sea 10 December 1982 17 Montreal Protocol on Substances that Deplete the Ozone Layer 24 July 1989 18 Convention to Combat Drought and Desertification 19 Framework Convention on Climate Change June 1992 20 Convention on Biological Diversity1992 442 Environmental-Related Conventions Environmentally related conventions ratified by Ghana include
bull International Convention for the Prevention of Pollution of the sea by Oil 21 October 1962
bull Convention on the Africa Migratory Locust 25 May 1962 Treaty Banning Nuclear Weapon Tests in the Atmosphere in Outer Space and Under Water 5th August 1963
bull International Convention for the Conservation of Atlantic Tunas 4 May 1966 bull Africa Convention on the Conservation of Nature and Natural Resources 15 September 1968 bull 992256International Convention on Civil Liability for Oil Pollution Damage 29 November
1969 bull International Convention Relating to Intervention on the High Seas in Cases of Oil
30
Pollution Causalities bull Convention on Wetlands of International Importance Especially as Waterfowl Habitats
2 February 1971 bull Treaty and Prohibition of the Emplacement of Nuclear Weapons of Mass Destruction
on the Seabed and the Ocean Floor and in the Subsoil Thereof 11 January 1971 bull International Convention on the Establishment of an International Fund for
Compensation of Oil Pollution Damage 18th December 1971 bull Convention Concerning the Protection of World Cultural and Natural Heritage 16
November 1972 bull Convention on International Trade on Endangered Species of Wild Fauna and For a 3
March 1973 bull Convention on the Military or Any other Hostile Use of the Environmental
Modification Techniques 10 December 1976 bull Convention on the Conservation of Migratory Species of Wild Animals 23 June 1979 bull Convention for the Cooperation in the Protection and Development of the Marine and
Coastal Environment of the West and Central African Region1981(Abidjan Convention)
bull United Nation Convention on the Law of the Sea 10 December 1982 bull Montreal Protocol on Substances that Deplete the Ozone Layer 24 July 1989 bull Convention to Combat Drought and Desertification bull Framework Convention on Climate Change June 1992 bull Convention on Biological Diversity1992
443 National Legislation
The principal national legislation that affects fisheries in Ghana is listed below
1 Fisheries Regulation 1984 LI 1294 2 Fisheries (Amendment) Regulation 1977 3 Maritime Zones (Delimitation) Law 1986 4 PNDC Law 256 of 1991 5 Fisheries Commission Act of 1993 and 6 Fisheries Act 625 of 2002 7 Fisheries Regulations passed in 2010 LI 1968
Other laws that have relevance to the fisheries sector include
1 Wild Animals Preservation Act 1961 (Act 43) 2 Volta River Development Act 1961 (Act 46) 3 Ghana Water and Sewerage Corporation Act 1965 (Act 310) 4 Oil in Navigable Waters Act 1964 (Act 235) 5 Irrigation Development Authority Decree 1977 (SMCD 85) 6 Minerals and Mining Law 1986 (PNDCL 153) 7 Environmental Protection Agency Act 1994 (Act 490) 8 Ghana Highway Authority Act 1997 (Act 540) 9 Timber Resources Management Act 1998 (Act 547) and 10 Minerals and Mining Act 2006 (Act 703
31
434 Policies A number of Environmental related Policies exist in Ghana however there is no specific policy on the coastal zone These include
bull The National Environment Policy bull National Wetlands Policy bull Agricultural Policy bull Tourism Development Policy bull Land Management Policy bull National Health Policy bull Energy Policy bull Minerals Policy bull Wildlife Conservation Policy
The main thrust and orientation of national policies on the protection management and development of the marine and coastal environment focuses on the following three major areas
bull Integrated coastal zone management and sustainable development bull Marine environmental protection both from land-based activities and from sea-based
activities and bull Sustainable use and conservation of marine living resources (both of the high seas and
under national jurisdiction) Specific plans have been developed to ensure the realization of prudent management of the marine and coastal environment These include
bull Coastal Zone Management Indicative Plan 1990 bull National Environmental Action Plan 1994 bull Draft Integrated Coastal Zone Plan 1998 bull Coastal Zone Profile of Ghana 1998 bull National Oil Spill Contingency Plan with specific reference to the marine environment
2002 bull Environmental sensitivity map of the coastal areas of Ghana 1999 and 2004
Despite the existence of these plans active integration and coordination has been lacking in practice at local level 434 Regulations Though several legislations exist on coastal protection and sustainable development there is no omnibus legislation on the environment Legislation relating to the area include the following
bull Beaches Obstruction Ordinance 1897 (Cap 240) bull The Mineral and Mining Law 1986 (PNDC 153) bull Rivers Ordinance 1903 (Cap 226) bull Land Planning and Soil Conservation Ordinance No 32 of 1953 as Amended by the bull Land Planning and Soil Conservation (Amendment) Act 1957 (No 35 of 1957) bull Maritime Zones (Delimitation) Law 1986 (PNDCL 159) urban planning and
32
bull development bull Town and Country Planning Ordinance (Cap 84) bull Wild Animals Preservation Act Act 235 1964 bull The Towns Ordinance (Cap 86) bull National Building Regulations 1996 (LI 1630) bull Volta River Development Act 1961 bull Fisheries Act 2002 Act 625 bull Fisheries Law 1991 (PNDC 256) bull Fisheries (Amended) Regulations 1977 and 1984
The sustainable use and conservation of marine resources is encouraged through legislation regulations education and awareness creation programmes as well as the enforcement of existing regulations and legislation The legal framework for coastal zones issues and management in the country are contained in the following documents
bull The 1992 constitution bull EPA Act 1994 (Act 490) bull Environmental Assessment Regulations 1999 (LI 1652) bull Local Government Act 1993 (Act 462) bull Environmental Standards and Guidelines bull
In addition there are other specific legal frameworks which include a) The legal framework for Ecosystem Protection which are
bull Wild Animals Preservation Act 1961 (Act 43) bull Wildlife Conservation Regulations 1971 (LI685) bull Wild Reserves Regulations 1971 (LI 740) bull The Wetland Management (Ramsar sites) Regulation 1999 bull Oil in Navigable Waters Act 1964 (Act 235)
b) The legal framework for Fisheries Resources which are bull Fisheries Law 1971 (PNDCL 256) bull Fisheries Act 2000
c) The legal framework for Oil and Gas Industry bull Petroleum (Exploration and production) Law 1984 (PNDCL 84) bull Mineral (Offshore) Regulations 1963 (LI 257) bull Mineral (Oil and Gas) Regulations 1963 (LI 256) bull Oil and Mining Regulations 1957 (LI 221)
d) The legal framework for Tourism Promotion (including coastal tourism) bull Ghana investment Promotion Centre Act 1994 (Act 478) bull Companies Code 1963 (Act 179) bull Free Zone Act 1995 (Act 504) bull Ghana Tourism Board bull Ghana Commission on Culture
44 ACTIVITIES RELATING TO FISHERIES INTERESTS
33
Over the years several activities have been undertaken which are of relevance to protection of the marine environment and fisheries These include
bull Ghana Environmental Resource Management Project in Coastal Wetlands Management Component
bull Gulf of Guinea Large Marine Ecosystem Project bull Fisheries Sub-sector Capacity Building Project bull Establishment of a Protected Wetland Ecosystem on the coast bull Development and Implementation of Oil Spill Contingency Plan bull Monitoring of fish stock levels and associated oceanographic parameters bull Institution of a programme of Monitoring Compliance and Surveillance of the marine
environment bull Development of industrial pollution standards bull Development of University course on Coastal Zone Management bull Increased public education on sound coastal and marine environmental practices
45 RELEVANT INSTITUTIONS With regards to protection management and development of the marine and coastal environment a number of ministries and agencies have been identified as potential stakeholders Those shown with an asterisk are likely to have a particularly active role
bull Ministry of Environment and Science bull The Environmental Protection Agency bull Ministry of Tourism bull Ministry of Local Government and Rural Development bull Ministry of Ports bull District Assemblies bull Ghana Ports and Harbours Authority bull Hydrological Services Department bull Ministry of Food and Agriculture bull Ghana Tourist Board bull Ghana Investment Promotion Centre bull Fisheries Commission Ministry of trade Industries and PSI bull Ministry of Lands and Natural Resources Forestry and Mines bull Ministry of Energy bull Ministry of Health bull Ministry of Education Youth and Sports bull Ministry of Defence bull Ghana Navy bull Ministry of Works and Housing bull Ministry of Women and Childrenrsquos Affairs bull Ministry of Roads and Transport bull National Development Planning Commission bull Council for Scientific and Industrial Research bull Universities and Research Institutions bull Ghana Meteorological Agency bull Town and Country Planning Department bull Water Resources Commission
34
bull Ghana National Petroleum Corporation bull Volta River Authority bull Geological Survey Department bull Forestry Commission (Forestry and Wildlife Division) bull Traditional Rulers and their analogous ministry and laws
Non-Governmental Organisations including Resource Development amp Environmental Oriented Development Organisation
bull Friends of the Earth bull Green Earth bull Wildlife Society bull Recerca e Cooperazione bull Centre for African Wetlands bull And many others
46 PARTNERSHIPS Few formal partnerships exist However support for coastal conservation activities has been received from the private sector as well as from Government Regional and sub-regional collaboration efforts occur at various levels although the level of practical intervention is sometimes limited The science and technology unit of ECOWAS is engaged on issues relating to the management of the Gulf of Guinea In addition a bilateral arrangement exists between Ghana and Cote drsquoIvoire for the management of and datasharing on Sardinella stocks which migrate between the two countries The NEPAD framework among the coastal states of Africa is also developing an interest in marine and coastal management 461 Technical and financial support Ghana receives technical support in the form of training research and project implementation from national bilateral and multi-lateral sources Financing of activities in the sector is primarily supported from the national budget However donor support from both bilateral and multilateral sources has also been obtained for specific programmes such as the World Bank sponsored Fisheries Sub-sector Capacity Building Project UNOPS sponsored Environmental Sensitivity Map for Coastal Areas The Ghana Coastal Wetland Project of the World Bank UNEPrsquos WACAF Programmes and The Darwin Marine Biodiversity of West Africa Project by DFID implemented by the University of Ghana 47 ACTIVITIES Activities undertaken in the country with importance to the marine and coastal area are outlined in the following sections 471 Environment-related activities
bull Ecological Baseline studies of Korle Lagoon (1990-2000) This was carried out to satisfy EIA requirement and as a result pollution status of the lagoon was established
bull Lower Volta Mangrove Project (1996-1998) The objective is to ensure sustainable management of mangrove stands and as such baseline information was documented
bull Save the Seashore Birds Project (1985-1995) This was to protect the seashore birds and as a result conservation awareness of seashore birds was achieved
bull Ghana coastal wetlands management project (1996-1999) In this management of the five coastal wetlands designated as Ramsar Site was put in place
bull Darwin Marine Biodiversity of West Africa Project It is a training project in marine biodiversity assessment
35
472 Social-related activities bull A considerable amount of attention is currently being given to the potential impact of oil-related
development in coastal regions following the publication of Environmental and Social Impact Assessments and Management Plans relating to the Jubilee Oil Field discoveries
473 Coastal area management bull Climate and vulnerability and adaptation assessment on water resources agriculture and the
coastal zone Projects (1997-1999) The projects assessed the vulnerability of the coastal zone to climate change
bull Coastal area management plan for Princess Town (1998-2000) which aimed at providing a plan for the management of Princess Town
bull Keta Sea Defence Project Work (2000-2004) The project aimed at protecting the Keta and its environs from the episodes of erosion faced in the area and also to ensure improvement in environmental and socio-economic conditions at Keta and its immediate surroundings
474 Regional Programmes bull Gulf of Guinea Large Marine Ecosystems Project (1996-1999) The project developed an
effective approach to prevent and control pollution in the Gulf of Guinea and conserve its biodiversity As a result regional institutional capacities were strengthened and also a coastal zone management profile and plans produced
bull UNEP WACAF Projects 1 amp 2 This aims at institutionalising and coordination of national contingency plans monitoring of pollution in the marine environment and control of coastal erosion
475 Other major programmes Other recent programmes and activities in the marine and coastal environments have included
bull Ghana Environmental Resources Management Project in Coastal Wetlands bull Fisheries sub-sector Capacity Building Project bull Establishment of a Protected Wetland Ecosystem on the coast bull Development and Implementation of Oil Spill Contingency Plan bull
48 ONGOING PROJECTS Ghana is currently implementing several projects in the marine and coastal area Some of these projects are linked to developmental projects for which impact assessments are required under the Environmental Assessment Regulations of 1999 Some of the projects are large scale in nature with extensive baseline and monitoring studies like the Keta Sea Defence Project and the West Africa Gas Pipeline project Others are projects being implemented under the auspices of the United Nations agencies and non-governmental organisations include
bull Combating Living Resource Depletion and Coastal Area Degradation in the Guinea Current LME through Ecosystem-based Regional Actions
bull Amansuri Conservation and Integrated Development Project (ACID) bull Danida Water and Sanitation Sector Programme II Support to Integrated Water Resources
Management (IWRM) Component (2004-2008)The Densu Basin aspect of the IWRM component
bull Reduction of Environmental Impact from coastal tourism
bull Bui Hydro Power Project
bull Sea Defence Project at Atorkor
bull Sea Defence Projects in selected towns in the Western Region of Ghana
36
49 CONCLUDING REMARKS
This chapter has highlighted the wide range of conventions laws policies regulations and activities affecting the inland and coastal regions and inland freshwater and marine environment of Ghana It will be important to keep all of these processes and procedures under review as the Fisheries and Aquaculture Sector Development Plan is taken forward to the implementation stage
The main responsibility for ensuring delivery of the Fisheries and Aquaculture Sector Development Programme will rest with the Fisheries Department of the Ministry of Food and Agriculture and the Fisheries Commission supported by the MCS Division and Ghana Navy However a key part of the programme is the development of local co-management arrangements and the Ministry of Local Government and Rural Development and individual District Assemblies will play a key role in helping to form and sustain Community Based Fisheries Management Committees
Over time a significant number of fishermen and individual fish processors are likely to leave the sector as harvesting landing and processing of the catch becomes more efficient Management of these changes especially where disadvantaged and vulnerable sections of the community are affected will need substantial support and investment and a high degree of coordination amongst government ministries and agencies NGOs and international partners to ensure that development assistance is effectively targeted
37
CHAPTER 5 WORLD BANK SAFEGUARD ISSUES
51 INTRODUCTION
The World Bankrsquos proposed funding support to the Government of Ghana covers an initial five yearsrsquo period which could potentially be extended at a later date As the Government of the Republic of Ghana notes in the draft FASDP ldquoimproving the management of the countryrsquos fisheries and ensuring that the impacts on individuals and communities are properly addressed will take 20 or more years to effectrdquo It has therefore been judged important in this report to distinguish between changes that might occur as a direct result of the World Bankrsquos financial assistance thereby triggering the Bankrsquos environmental and social safeguards and changes that could result from longer term adjustments to fisheries and other sectors of Ghanarsquos economy as a result of wider influences by Government other donors and world-wide factors (for example international progress in world trade agreements)
The aim in this chapter is to identify changes which are likely to fall within the purview of the World Banks reputational risks and responsibilities under the first five years of the Fisheries and Aquaculture Sector Development Plan (FASDP) It should be clearly understood that the views expressed are those of the consultancy team and it will be for the World Bankrsquos internal advisors to decide what formal recommendations are made to the World Bank Board
Trends that may emerge in later stages of the implementation of FASDP ndash subsequent to the initial five year period - are discussed in chapter 6
52 THE CURRENT SITUATION
The general status of Ghanarsquos fisheries has been described in Chapters 3 while the legal and policy context has been set out in Chapter 4 The World Bankrsquos investment is being planned specifically to support government policy with the aim of providing a more efficient and better regulated fisheries sector Currently open access is leading to progressive deterioration in fish stocks and lower economic returns Based on many international examples of successful intervention the current proposals (see Chapter 2) are to provide support to introduce formal licensing of all vessels and proper monitoring and control over the seasonal timing and location of fishing activity use of gear and approved nets and self regulation through co-management structures under which the Government and fishing communities will work together to achieve recovery of fish stocks higher income levels for fishers and better returns on catches by reducing post harvest losses and improving processing and marketing operations
53 ANTICIPATED OUTCOMES
It is expected that the proposed reforms and changes will eventually lead to significant improvement in the marine environment restoration of fisheries and enhanced incomes In this respect the provision of grants and loans from the World Bank will bring about major benefits to the economy livelihoods and the environment in the longer term The question that has to be addressed however is - are there likely to be any short term adverse environmental or social consequences from the Bankrsquos own investment strategy Answers are considered in relation to each of the planned components sub-components and activities which are summarised in Table 51 A colour coding and numbering system has been adopted to distinguish those activities that are seen as particularly relevant from the standpoint of the environmental and social assessment Elements highlighted in green are those likely to have positive and beneficial effects on the environment and social conditions those highlighted in orange red have potentially negative or adverse consequences if not handled properly
38
Component 1 Good Governance and Sustainable Management of the Fisheries
Sub-Component 11 seeks to develop the capacity rules procedures and practices that will lead to better governance As such these procedural interventions will have no direct effect on the environment or social conditions of fishing communities However it will be important to ensure that the drafting agencies (government departments and consultants) give due attention to environmental and social objectives during this phase of work Three specific areas are highlighted including undertaking a socio-economic impact assessment with mitigation measures as part of the plan for fishing capacity reduction reviewing the economic and social implications of subsidies and fish import tariffs in the fisheries sector and developing the policy for the development and operation of community-based management networks built around defined fisheries management units
In developing regulations and guidelines it will be important to consider how less able individuals and vulnerable sectors are going to adapt to new systems For example the new regulations on licensing canoes including completion of registration forms the display of registration numbers on vessels and demonstration of basic competence in health and safety standards may prove taxing demands for owners and crew lacking any formal education Similarly legal instruments that are used to remove fuel subsidies or other benefits will need to be carefully explained A socio-economic impact assessment is proposed in the draft PAD to be accompanied by appropriate mitigation measures This assessment should consider amongst other things
bull whether support should be offered and if so under what conditions to any company community or individual who fails to secure a license for a particular class of vessel
bull how the transfer or sale of licenses will be regulated in the wider public interest to ensure transparent processes and avoid the creation of monopolistic and oligopolistic elites
bull who wins and who loses from any planned changes to subsidies and fish import tariff adjustments
bull how the performance of community-based management networks will be judged bull what action will be taken to mitigate the loss of any traditional fishing grounds that become the
subject of marine protected area development or are subject to exclusion zones to protect oil drilling and production platforms
Sub-Component 12 introduces the concept of fishing rights This is to be initiated through a series of four pilot stakeholder-based fishery initiatives and the rolling out of licensing procedures Discussions with stakeholders have made it very clear that the credibility of the entire fisheries policy and programme could be challenged if these pilots do not show positive and constructive ways of moving forward with fisheries reform There is a great deal of distrust for new procedures amongst the fishing communities based on the knowledge that many previous initiatives have failed It is therefore essential that the pilots are led by a strong implementation team are adequately financed and include a credible transparent and inclusive process for debate discussion and consultation Co-operation from the selected communities will be more likely to be achieved if they can see early results in terms of income generating activities
Sub-Component 13 is targeted at adjusting fishing effort and capacity to more sustainable levels and supporting alternative livelihood opportunities These activities are critical in giving effect to the policy decisions that have already been taken to reduce the size of the industrial and semi-industrial fishing fleet and to strengthen the role of the canoe sector Specific measures are proposed for compensating crew members who lose their jobs and for providing training to young men who are willing to transfer
39
out of the fishing sector The scale of this task should not be under-estimated however since there are currently few alternative employment opportunities in the coastal belt for manual workers with low education and skill levels which typify the status of many young fishermen The concept of creating some additional employment with conservation of the coastal littoral and marine ecosystems is strongly supported since this can be linked with development of tourism
Sub-Component 14 is another element that is strongly focused on delivering improved livelihoods with its emphasis on social marketing communication and transparency The focus on stakeholder participation is particularly welcome and should lead to positive response providing it is backed with direct financial support to participating communities
Component 2 - Reduction of Illegal Fishing
There is no Sub-Component 21 within the Ghana Fisheries Programme
Sub-Component 22 aims to develop monitoring control and surveillance (MCS) systems These measures are largely procedural and apart from the relatively small team that will be recruited to operationalise the systems it will have minimal effects on either the environment or social conditions One element that is highlighted in Table 51 relates to provision of facilities and training for participatory coastal surveillance of small-scale fisheries This should have direct and strongly positive benefits for participants and the communities who are enrolled in the training programmes
Component 3 increasing the contribution of the marine fish resources to the local economies
Sub-Component 31 will support the development of basic infrastructure at nine marine fish landing sites and two inland sites The scale of physical construction will be restricted to repair and minor extension of roads and jetties wharves and construction of net mending screens and storage sheds These activities are unlikely to have any significant adverse environmental impacts and should lead to positive social effects
Sub-Component 32 will underpin efforts to improve fish product trade infrastructure information and systems Introduction of new technology for smoking and curing fish and the extension of existing ice preparation plants will start to have positive beneficial effects within the selected communities
Sub-Component 33 provides a modest level of support to marine and inland aquaculture development Aquaculture development should include finalization establishment and enforcement of current draft operational standards to cater for environmental friendliness of fish culture industry for its own survival The main focus will be on developing policy and legal frameworks together with support for stock improvement These measures will have some impact on affected communities in the short term but are clearly aimed at longer term benefits
40
Component 4 Coordination Monitoring and Evaluation and Program Management
Sub-Components 41 and 42 are directed specifically at strengthening the capacity of the Governmentrsquos institutions for national implementation and regional co-ordination As such they will have no direct environmental or social impacts
54 SUMMARY AND CONCLUSIONS
This review of potential environmental and social safeguard issues under the World Bankrsquos targeted programme concludes that there are unlikely to be any significant adverse environmental or social effects as a result of the planned investments
The only possible exception relates to the effectiveness of measures that are put in place under Sub-Component 12 to support pilot stakeholder-based fishery initiatives It is of paramount importance that these pilots are successful and win the confidence of all participants since failure to achieve positive results could set back the entire fisheries programme For this reason it is essential that planning of the pilot initiatives is linked closely with measures for supporting alternative livelihoods and strengthening processing and marketing initiatives under Sub-Components 13 and 14
A number of the planned interventions may have longer term consequences as policies regulations and bye-laws are put into effect but these will be addressed in subsequent work by the Government of Ghana (see Chapter 6)
Table 51 Elements of the World Bank Programme and assessment of potential environmental and social risks
Description of Component Sub-Component and Activities
Measure of Likely Effects
Large (3)
Moderate (2)
Small (1)
None
Beneficial
3
2
1
Adverse
3
2
1
Component 1 Good Governance amp Sustainable Management of the Fisheries
Sub-Component 11 Developing the Capacity Rules Procedures amp Practices for Good Governance of the Fisheries
Reviewing developing programmes and projects designed to support the Fisheries and Aquaculture Development Sector Plan (FASDEP)
Developing an operational policy to enable implementation of the Aquaculture and Fisheries
Plan for fishing capacity reduction (including socio-economic impact assessment and mitigation) 3 2
Commercial vessel and fishing activity licensing plan including allocation criteria rules for transfer of licenses
41
Sector Development Plan and timetable and schedule of license fees
Compliance strategy and plan
Regulations for the management of fisheries including the identification and specification of fisheries management units (ie stocks species areas)
Recommendations for environmental and social safeguards arising from the review of the economic and social implications of subsidies and fish import tariffs in the fisheries sector
3
Policy for the development and operation of community-based management networks built around defined fisheries management units
3
Policy on adaptation strategies for climate change and marine protected area development
2 2
Review of the Ghana Tuna Industry to identify policy or infrastructure needs that threaten Ghanarsquos hub status
Strengthening capture fisheries management systems and capability
Development of fisheries and aquaculture management systems and processes and training
Strengthening fisheries information systems
Installation and operation of fisheries lsquodashboardrsquo database and information collection
Sub-Component 12 Introducing Fishing Rights ($15 M GEF)
Developing 4 pilot Stakeholder-Based Fisheries Management initiatives around defined fisheries units (ie local management initiatives tied to defined fisheries resources including demand-side governance initiatives)
3 2
Introducing and administering a licensing regime (registry establishment training stakeholder education) 2 2
Sub-Component 13 Adjusting Fishing Effort and Capacity to more Sustainable Levels and Supporting Alternative Livelihood Opportunities where Needed
Vessel decommissioning Decommissioning of 60 to 80 industrial trawlers in an environmentally friendly manner
2
Developing alternative livelihoods for crew of decommissioned industrialsemi-industrial
Skills training and small business development training and support for young (18-30 yrs) industrialsemi-industrial crew members willing to transition out of the sector
3
42
vessels
Alternative livelihood development to incentivize voluntary capacity reduction in canoe sector
Alternative livelihoods fund and CDD support to targeted fishing communities
3 2
Marine Resource Conservation
Would include confirming conservation priorities and management regimes and possible provision of support for alternative livelihood options (funded under 133) associated with conservation of coastal littoral and marine ecosystems as well as de facto protected areas associated with the development of oil and gas extraction
3
Sub-Component 14 Social Marketing Communication and Transparency)
Communications stakeholder consultations and awareness raising programs to support fisheries development
3
Component 2 Reduction of Illegal Fishing
Sub-Component 21 does not apply to Ghana
Sub-Component 22 Monitoring Control and Surveillance (MCS) Systems
Developing compliance systems and capability
Development of judicial and policy capacity (training)
Compliance risk assessmentstrategy systems and process development
Enforcement Unit establishment (dedicated facility)
Coastal surveillance stations 2
Facilities and training for participatory coastal surveillance of small-scale fisheries
3
Training for surveillance officers
Operation of aerial and water patrols (vessel leases aerial patrols operational costs patrol vehicles)
Observer program
Compliance education (stakeholder training signage) 1
Upgrademaintenance of the Vessel Monitoring System (VMS)
43
Component 3 Increasing the Contribution of the Marine Fish Resources to the Local Economies
Sub-Component 31 Fish Landing Site Clusters
Product diversificationvalue chain development
9 marine landing sites (basic infrastructure) at Axim Dixcove Fete Jamestown Moree Mumford Senya-Beraku Teshi and Winneba
3 1
2 inland fish landing sites (improved access and berthing infrastructure) at Abotoase and Dzemeni
3 1
2 ports developed (technical studies for 1 new port at Axim and additional berthing space in existing port of Elmina)
3 2
Sub-Component 32 Fish Product Trade Infrastructure Information and Systems
Export certification center development
Fish processing technology improvements 1 1
Technical assistance training and goods to support the National Fisheries Advisory Group
Sub-Component 33 Marine and Inland Aquaculture Development
Developing aquaculture policy and legal framework
Improving genetic quality of Tilapia fingerlings and breedstock
Catalyzing aquaculture development 2
Component 4 Coordination Monitoring and Evaluation and Program Management
Sub-Component 41 National Implementation
Technical assistance for Secretariat to the Fisheries Commission to implement the Project
Sub-Component 42 Regional Coordination
Technical assistance for Regional Coordination Unit at the CSRP support to Fisheries Information Systems (lsquoDashboardrsquo)
45
CHAPTER 6 ENVIRONMENTAL AND SOCIAL ASSESSMENT OF DRAFT FISHERIES AND AQUACULTURE SECTOR DEVELOPMENT PLAN (FASDP)
61 INTRODUCTION
This chapter examines environmental and social issues which need to be considered as part of the overall structural and economic adjustments in Ghanarsquos fisheries sector in the longer term (ie 1-15 years) The assessment deliberately focuses on the longer term because it will take a number of years before current plans start to have their full effect However the same temporal considerations apply to measures that are designed to avoid or mitigate potentially harmful effects so it will be important to start planning remedial actions as part of the joint Government of Ghana and World Bank fisheries programme
611 Key sectors and activities The fishing industry is divided first into marine capture and inland capture fisheries and then aquaculture For each of these three sectors activities are then broken down as follows Marine Capture Fisheries CATEGORY ACTIVITY Stock Management Research Surveillance reef building Harvesting Vessels Gear Skills capacity Marketing Sellers Buyers Processing Fresh fish Sun dried Smoking Freezing Consumers By market sector Support Sectors Boat Canoe Building fuel supply net making kiln construction
refrigeration transport cold store management Legal Enforcement Financing Investment in all elements Infrastructure Harbour wharf processing plant construction
Inland Capture Fisheries CATEGORY ACTIVITY Stock Management Research Surveillance Harvesting Vessels Gear Skills capacity Marketing Sellers Buyers Processing Fresh fish Sun dried Smoking Freezing Support Sectors Boat Canoe Building fuel supply net making kiln construction
refrigeration transport cold store management Legal Enforcement Financing Investment in all elements Infrastructure Harbour wharf processing plant construction
46
Aquaculture and Mariculture CATEGORY ACTIVITY Stock Management Research Surveillance Rearing Roe fingerling production cage -pond rearing Harvesting Vessels Gear Skills capacity Marketing Sellers Buyers Processing Fresh fish Sun dried Smoking Freezing Support Sectors Boat Canoe Building fuel supply cage construction kiln construction
refrigeration transport cold store management Legal Enforcement Financing Investment in all elements Infrastructure Harbour wharf processing plant construction
612 Evaluation Criteria The environmental and social assessment has been undertaken using a matrix (See Annex 114) which analyses the key sectors and activities of the fishing industry and the changes that are envisaged against a set of evaluation criteria Evaluation Criteria are broken down into environmental and social issues distinguishing between beneficial and adverse effects Table 61 below shows the relationship between the groups of criteria Table 61 List of Evaluation Criteria
Environment Social
Positive Adverse Positive Adverse
bull Sea bed rejuvenated
bull Fish stocks recovered
bull Biodiversity enhanced
bull Sea bed degraded
bull Fish stocks reduced
bull Biodiversity reduced
bull Increased harvest (catch volume)
bull Increased catch value
bull Reduced costs of inputs
bull Increased profit
bull Enhanced livelihoods
bull Increased job opportunities
bull Increased local economic multiplier
bull Reduced harvest (catch volume)
bull Reduced catch value
bull Increased costs of inputs
bull Reduced profit
bull Reduced livelihoods
bull Reduced job opportunities
bull Reduced local economic multiplier
The assessment process has involved systematically considering each sectoractivity against the evaluation criteria and recording either positive or negative results by drawing on the judgement of the consultancy specialists The findings are discussed in the paragraphs that follow and are reflected in Table 81 forming part of the Draft Environmental and Social Management Plan
62 DETAILED ASSESSMENT OF THE MARINE AND AQUACULTURE SECTORS
47
TunaIndustrial fleet streamlined and catch per vessel improved At present industrial trawlers have to travel increasing distances to fishing grounds and while the level of catch is remaining broadly static costs are increasing against available economic returns A major shortcoming is lack of investment in re-equipping the aging fishing fleet Many of the 90 vessels that make up this sector are increasingly unseaworthy and need to be replaced with modern trawlers and gear The plan is to buy out owners of substandard vessels by offering compensation at market value based on a full commercial survey Vessels remaining in the fleet will be required to meet exacting standards By reducing the number of old and inefficient boats this will allow each of the remaining vessels to catch a higher proportion of fish The aim is to ensure that Ghana is equipped with the latest vessels and technology in order to preserve the countryrsquos position as the hub of the West African tuna fishing and processing industry (see also the section on canneries below) The effect of these measures on the environment will remain broadly neutral since the same number of fish will be caught Providing other policies and increased surveillance are successful in preventing trawling in inland waters the smaller fleet will have to fish in deep oceanic waters This could potentially transfer some environmental effects on fish populations to other parts of the migratory cycle However this would become part of the international effort through fishing quotas to regulate overall catches Reduction in the size of the industrial fleet will mean that fewer men are needed to crew and service the vessels However in practice many men who work in this sector have only part time work and since a significant percentage of boats no longer put to sea the number of crewmen who will be displaced could be in the range of 1000-30003
It will be important to set up support services for those losing their jobs including retraining and welfare assistance where necessary
Decommissioning will necessitate the sale of seaworthy vessels and their removal from Ghanaian waters Other boats will need to be broken up and scrapped This process requires heavy duty specialized equipment and can release significant quantities of waste oil other toxic chemicals including refrigerants and asbestos used in pipe and engine room cladding Measures will need to be taken to ensure that proper environmental and health safety precautions are taken that decommissioning takes place in properly equipped boatyards and that all waste products are disposed of without environmental risk Cannery sector optimized The Fisheries and Aquaculture Sector Development Plan seeks to maintain the port of Tema as the centre of the Tuna canning industry in Ghana At present a proportion of Ghanarsquos tuna catch is diverted to neighbouring countries due to constraints on processing capacity These limitations include poor port infrastructure ageing equipment and delays in handling catch for some operators due to preferential treatment of vessels that are part-owned by the existing canneries Options for improvement include encouraging upgrading of the capacity of one or more existing canneries or promoting more competition in the processing sector and improving the infrastructure Providing modern building designs and construction techniques are employed and a full environmental assessment is undertaken in accordance with Ghanarsquos EIA regulations there should be no significant environmental or social risks associated with these development possibilities The potential economic benefit resulting from encouraging investment in this sector is very high
Industrial fishing excluded from inshore waters A major longer-term intention under the new fisheries plan (FASDP) is to ensure that existing regulations that restrict industrial and semi-industrial vessels from trawling in inshore waters are properly enforced This requires provision of surveillance
3 Based on an average crew of 20
48
equipment fast patrol vessels capacity building and training and increased staffing within Government agencies together with a full programme of awareness raising training and financial support to local bodies providing self-governance under new co-management services Restriction of industrial trawling in coastal waters will greatly ease pressures on fish stocks and reduce environmental damage to the sea bed In time this should lead to healthier fish population with more fish to be caught by the canoe industry as a result However the task of policing and enforcing regulations will not be easy and will take a number of years to bring into full effect Reduction in fishing activity by inshore trawlers will displace a number of crew members and have a short-term impact on dependent families until these individuals are either absorbed into the canoe fleet or find alternative employment There will therefore be a need to assist genuinely deserving cases where crew members (and their families dependents) need to transfer to other sectors of the economy These measures will only be required in the short term since the anticipated improvement in fish stocks will lead to improved economic performance in the canoe sector within which the bulk of employment exists
Expansion of deep water fisheries The fisheries plan notes that there may be a potential for exploitation or increased exploitation of some deep sea fish resources However the status and population dynamics of some affected species is not well known so any such activities should be scientifically monitored through research and enforced by MCS
Tema Secondi Port infrastructure improvements (equipmentbuildings) Under present conditions the transfer of fish from commercial and industrial vessels to canneries is often delayed by the time taken to offload crates and manouvre within the port area where there are conflicting activities There are also difficulties that arise when vessels owned by the canneries are given priority for landing leaving other boats waiting for many hours which can result in quality deterioration At this stage no details are available about the precise improvements that could be introduced and this will need to be investigated as the fisheries plan is advanced Any environmental effects from infrastructure improvements would be contained within the existing port areas and should be largely positive in reducing fuel (energy) costs and increasing overall efficiency It will however be important to carry out an environmental review of specific development proposals at the design stage especially if these involve plans for any dredging or for altering facilities for discharging waste and disposing of bilge water Both of these activities can have damaging effects on the sea bed (The first through dispersal of silt and sediment and the second through release of potential contaminants) Socio-economic effects from the infrastructure improvements should also be beneficial by removing delays increasing efficiency and reducing waste However there could be some slight reduction in manpower requirements leading to the need for skills retraining Regulating the catch (eg Fishing for selected species reducing juvenile catch to improve value of catch in inshore waters) The fundamental aim of the fisheries plan is to reduce the harmful effects on fish stocks and low economic returns from fish catches by phasing out open access for all and introducing regulation of fishing activity This is to be achieved through close cooperation between the Fisheries Commission Monitoring and Surveillance Unit as well as marine fisheries management division and individual fishing communities working together under a co-management framework The practical details will need to be worked out through each individual co-management group and initially the World Bank is offering to assist in the establishment of four pilots These bodies will test exactly what is required to increase fishersrsquo awareness to build capacity in self regulation and agree on appropriate measures
49
From discussion with stakeholders it is clear that while the broad principles are accepted the majority of the fishing community simply do not believe that the new regulations will be enforced because they have witnessed the failure of so many previous efforts to introduce firm management A major issue for the planned programme is therefore how to change this critical mindset without which very little progress is likely to be made in practice It will be necessary to demonstrate through the pilots that by regulating fishing activity direct benefits will accrue to those participating fishing communities Unfortunately efforts to eliminate harmful practices are unlikely to result in an immediate gain in fish stocks Instead catches are likely to fall in the short term It will therefore be essential to introduce other forms of incentive to cushion short term losses Such measures might include the purchase of new nets and gear for sale at subsidized price to local cooperatives the introduction of cash incentives for canoes demonstrating best practice in the use of gear and nets preservation of the catch using ice and landing and marketing fish of the required size and quality As restriction of open access starts to take effect there should be positive environmental gains in terms of improving fish stocks and less damage of the sea bed On the other hand both fishers and fish processors will feel the adverse temporary effect of reduced catches These social and local economic impacts will need to be monitored closely and assistance provided to help foster alternative livelihoods Cephalopus (Octopus) harvesting encouraged in inshore waters Although most fish species are currently exploited to unacceptably high levels within coastal waters there is a specific opportunity to increase the number of octopus caught by pot fishing This fishery could be developed by both the semi-industrial and canoe sectors Taking octopus in pots would have no adverse physical impacts on the sea bed and could allow very slight expansion in fish species that are preyed on by octopus At the same time it is important to note that there is only limited information on species composition and functioning of selected marine habitats including those of the octopus and more research should be undertaken on this and other species that could be selected for expanded fishing activity There would be clear socio-economic benefits arising from the creation of this new fishery Focusing fish landing at specific landing sites (to improve opportunities for subsequent marketing processing) Plans are already being developed for the enhancement of landing and processing facilities at a number of existing locations along the coast These locations include the construction of harbours at Jamestown and Elmina and development of landing sites at Teshie Ada Axim Dixcove Winneba Mumford SenyaBeraku Gomoa Fetteh Moree Keta Dzemeni and Tapa Abotoase Two sets of issues need to be considered in relation to these improvements all of which affect existing fish landing and processing sites The first is the nature of the physical works and infrastructure and it s potential effect on the marine and terrestrial environment The second is the socio-economic impact Both Elmina and Jamestown are long established fishing ports where the catch is landed either directly onto the beach or shallow wharves It is understood that the primary aim of the improvements will be to increase the area of permanent wharves to make it easier for fish to be offloaded to reduce the time taken in transferring stock to processing plants and to introduce modern technology In the case of other smaller landing sites the scale of improvements will be quite modest involving improvement to existing short stretches of access road the erection of stores for nets and other gear and provision of covered areas to provide shade for net-mending With all proposals for physical infrastructure development there will be a need to consider possible
50
environmental implications Due to the existing nature of these sites there are no major industrial or other commercial processes in the vicinity which could give rise to cumulative impacts including contamination of fish products The scale of plant needed for ice-making and storage and commercial smokeries is commensurate with the artisanal nature of the fishing activity itself and would not give rise to any significant environmental effects on air or water quality Harbour works could potentially involve some small scale dredging (for example the removal of accumulated silt) Where dredging is required it will be important to identify disposal areas (either at sea or on land) where silt can be deposited without damage to sensitive habitats In terms of economic and social impacts it is not clear at this stage who are likely to be the major investors from the private sector although it may be assumed that existing operators who have access to finance will be the main beneficiaries Over time as landing marketing and processing become more efficient it is possible that individuals in the traditional fish smoking sector will lose a significant proportion of their trade as the product switches to fresh or frozen fish sales for transfer to the major urban markets and the beach price for fish rises The draft Ghana fisheries and aquaculture sector development Plan notes in annex 2 that proposed facilities associated with the ports and landing sites may not have support from fish mammies or at least formidable commercial advocates able to resist any opposition from that quarter Inspection of major fish landing areas like Elmina and Sekondi indicates that the existing social and commercial structure of support activities to fish harvesting is very complex and involves almost every member of the community including children and the elderly Such activities include net mending boatbuilding metalworking (for cooking pots stoves and grills supplies (ropes weights tar paint wood) fuel supplies ice crates transport etc Leaders of the fishing community confirmed that in principle the improvements of facilities is welcomed provided that safeguards are in place for those who may lose part or all of their current trading activity through rationalisation Stabilise fleet capacity at a sustainable level Fishery experts consider that there would be significant benefits in reducing the number of canoes from the present 10000-12000 to around 8000-9000 which correlates with the number operating in the mid 1990rsquos when catches were at optimum levels At the same time the Fisheries and Aquaculture Plan stresses that the canoe sector will remain at the heart of the Ghana fishing industry and this has strong political enforcement Consequently there is unlikely to be any enforced reduction in the number of canoes holding licenses and owners of all existing canoes will be able to register their vessels The ability of canoe owners to pay annual licence fees should rise as the overall measures to increase efficiency and improve catches take effect However many people anticipate that over time as the annual cost of holding licenses rises less efficient fishers will sell their licenses (and hence their rights to fish) There may therefore be a de facto reduction in the size of the canoe fleet Even if numbers do not decrease the fleet could be stabilized at its present size by taking a decision not to grant new licences The draft plan discusses the fact that under existing law (section 53) there is a requirement for licenses to be issued on demand (presumably to ensure that Ghanaians are not barred from subsistence fishing) It is argued in the plan that this is a misconception since canoe fishing is largely a commercial activity and it is concluded that lsquoit is therefore essential that the number of canoe licenses can be controlled in future and the legal basis for these controls must be reviewed as a matter of priorityrsquo Decisions of this nature will require the full support of local co-management groups if they are to be effective but committees could easily come under pressure to make exceptions as the coastal population continues to rise and families without alternative livelihoods start lobbying for assistance
51
Accusations of preferential treatment of certain individuals by committees (or committee officials) - possibly linked with suggestions of bribery and corruption -could cause a lot of social tension and start to undermine community trust in the need to work together to improve fisheries management It is therefore most important that the detailed proposals for co-management address this risk and include proposals for mitigating individual hardship of the less advantaged ndash for example by offering voluntary retirement with some form of incentive Influencing marketing to maximise value and reduce post harvest losses (marketing cooperatives strong market structures etc) FAO has estimated that physical post harvest losses in Ghana amount to between 3 and 17 of smoked fish production and 16-20 of gillnet landings The plan notes that introduction of lsquonew generationrsquo small scale fish smokers should be introduced to replace the traditional Chorkor model This would improve fish product quality by eliminating charring of fish over open flames and also protecting operatorsrsquo eyes from the damaging effect of smoke and particles The other major improvement in post harvest value and profits would arise from greater use of ice throughout the supply chain Developing Aquaculture A distinction needs to be made between aquaculture development in ponds and dugouts which are self-contained and fish rearing in cages within open water In the case of farm ponds the commercial rearing of fish is little different to other forms of intensive livestock rearing Providing there is no direct connection to rivers and streams there is little likelihood of interaction between farmed and wild stocks which could spread fish infections and parasites In the case of fish farms in open water (rivers and lakes) there are well known risks of the spread of disease which can arise if overstocking occurs Intensive feeding of large numbers of fish in a confined area can lead to significant deterioration in water quality through the build up of nutrients from wood and waste It is also possible for antibiotics and growth hormones to be dispersed beyond the area of farm cages Genetic modification of farmed fish can also affect the local fish population through escapes All of these issues are capable of being managed and mitigated through good initial planning and design and subsequent maintenance and supervision It will therefore be necessary to develop additional regulations and guidelines specifically for the aquaculture sector 63 SUMMARY OF ENVIRONMENTAL RISKS AND OPPORTUNITIES Review of the full range of governance and development activities suggests that there are no high levels of risk to the marine or littoral environment Successful implementation of the Policy and plan should in fact result in very significant environmental gains Over a timespan of 5-20 years five activities in particular should result in significant improvements in the condition of the sea bed in coastal waters (to a depth of 30 metres) reestablishment of benthic flora and niche habitats increased fish stock and enriched biodiversity These interlinked activities are bull The exclusion of industrial vessels and trawling within coastal waters bull Regulation of fish catches through zonation seasonal control of fishing and standards for vessels
gear bull Stabilisation of the fishing fleet within sustainable harvesting yields bull The adoption of management plans formulated and agreed with full cooperation of local
communities bull The introduction of fishing rights through co-management agreements and bull Well planned consultation and information dissemination throughout the fisheries sector
52
Three components of the development plan have been identified where minor to moderate risk to the physical and biological environment could arise if proper design and implementation standards are not adhered to These relate to bull A potential risk of over-exploitation of new catch species in deep water off the continental shelf if
such development is not accompanied by through research to establish the sustainable yield of target species
bull Strictly localized effects on the physical environment from construction of landing wharves or jetties and other harbour facilities and
bull Infrastructure development at the existing ports of Tema and Takoradi All of these risks are capable of being fully managed by improved governance in the fishing sector and EIA procedures that are well-established in Ghana 64 SUMMARY OF SOCIO-ECONOMIC RISKS AND OPPORTUNITIES Implementation of the Plan Project will bring about substantial change in the fisheries sector and over time increased revenue reduction of post[harvest losses and added value to fish products will bring major economic returns At the same time there will be some individuals who do not participate in direct gains and whose livelihoods could be adversely affected if appropriate safeguarding measures are not put in place The level and extent of these socio-economic risks will be determined by 1 the level of commitment that is entered into by Government and its development partners to
deliver incentives to vulnerable and disadvantaged groups and 2 the speed with which the sector is transformed Rapid change could cause significant
displacement of less-efficient operators especially within the semi-industrial and canoe sector which would have serious ramifications for dependent communities However these effects can be marginalized if the development programme is carefully phased to ensure that alternative livelihood and employment incentives are available
The main risks to local livelihoods relate to the potential for bull loss of employment for crews of unseaworthy obsolete vessels ( from all sectors including
industrial semi-industrial and canoes) that are withdrawn from the fishing fleet because they no longer comply with license regulations
bull the inability of vulnerable and disadvantaged groups including artisanal fishers vendors and individual fish processors in small fishing villages to adjust to new market conditions at selected landing sites
53
CHAPTER 7 ASSESSMENT OF POLICY OPTIONS
71 INTRODUCTION
In order to place the significance of the environmental and social safeguards assessment in context this chapter examines the possible consequences of different policy responses to the existing challenges that face the fisheries sector in Ghana These different policy responses range from a continuation of the status ndashquo effectively a ldquodo-nothingrdquo option (A) to full-scale commitment by all stakeholders to achieving a sustainable fisheries future the ldquoOptimum Solutionrdquo option (C) Various less sustainable outcomes lie in between these two ends of a continuum of policy choices and these are represented by the ldquoWeak Solutionrdquo option (B) 72 OPTION A ndash DO NOTHING Background research and discussion with stakeholders indicates that practical capacity to deliver on clearly stated national goals for sustainable fisheries livelihoods and the reduction of poverty is weak This situation exists despite the fact that Ghana has a strong legal framework for management of its fisheries including the Law Policies and Regulations There is inertia and strong resistance on the part of the majority of players to accept that it is largely their own actions which are responsible for present conditions This in turn leads to the attitude that it is only the lsquoGovernmentrsquo that must act by providing increased subsidies and cushioning the industry against further deterioration in catches Unfortunately there is overwhelming evidence from around the world that where fish stocks are exploited beyond their natural capacity to regenerate this can lead to sudden and near-total collapse Ghana has historically been one of the strongest fisheries in West Africa but the signs are ominous that current levels of exploitation are leading to progressive decreases in annual catches for most species in both marine and inland waters As fishing effort intensifies with an increasing number of all types of vessel using illegal methods and inappropriate gear the distinction between the traditional lsquopeak season and lean season (linked to migration patterns breeding cycles and upwelling) is becoming blurred This is clearly illustrated by a statement from one of Elminarsquos fish mammies ldquowe use to smoke the herring in the peak but now the fishers bring them all the yearrdquo Use of monofilament nets light dynamite and chemicals to obtain fish in the lean season is aggravating a situation where too many boats are chasing too few fish Many fishers blame the reduction of catch on global warming for increasing water temperature the emergent oil and gas industry for restricting access to traditional fishing grounds and industry and urban development for increasing pollution leading to deterioration in water quality Each of these assertions warrants careful consideration but the industry is generally in denial when it comes to the primary fact ndash too many fish including juveniles are caught to allow regeneration of the stock In addition weak governance and lack of resources to ensure implementation of policy result in a situation where the law can be ignored with impunity If collective failure to recognize the seriousness of the current position and lack of commitment to taking hard decisions continues the omens for the future are not good Within a period of 10-15 years fish catches could fall by 50 or more from their present level Impacts on each species would vary and catches of some fish with regional or global migration patterns could remain viable (although this depends on the international conservation effort) On the other hand stocks of fish that provide the mainstay of local food resources herring and sardine could be decimated
54
Complete collapse of all fish species is unlikely but it is possible to envisage a situation where catches might fall below 300000 tonnes a year by 2025 (a reduction of more than 25 from present levels) The most serious consequences would be felt as a result of the social and local economic impact on fishing communities Perhaps 30000 men representing the crews of 3000 canoes and semi industrial boats and 15000 women engaged in marketing and processing would lose their present livelihoods Population migration away from the coast could follow and severe social pressures and local economic hardship This is clearly a ldquoworst caserdquo scenario and if conditions were to worsen gradually it might be possible to intervene but the fact has to be accepted that fish stocks are dynamic and subject to rapid decline (as in the case of the North Sea Herring and Atlantic Cod) 73 OPTION B THE lsquoWEAKrsquo SOLUTION The bleak future painted in Option A is unlikely to arise if the present policy and draft fisheries development plan is followed since these are specifically directed to addressing the major challenges However realization of the aims is dependent upon delivery across a wide range of initiatives by multiple stakeholders The following paragraphs illustrate some of the ways in which delivery of policy objectives might be thwarted These may be summarized as
bull Commitment to good governance and institutional reform bull Political resolve to implement unpopular measures bull Availability of adequate technical and financial resources bull Inertia to necessary changes in fishing practice
Good Governance and Institutional Reform Fundamental reforms are required to fully equip the national fisheries management effort at government level This includes introduction of change management clarification of responsibilities for senior staff rationalization of financial management systems provision of equipment expansion of staff numbers additional training and capacity building As an illustration of the extent of the effort required reference can be made to just one topic area the issue of monitoring control and surveillance At present the Fisheries Commissionrsquos MCS Unit has only 10 employees to oversee implementation of the fisheries regulations throughout Ghana This number will be increased as other institutions are engaged in joint monitoring initiatives but it is obvious that staff numbers and capacity will need to be expanded if regulations on fishing activities are to be affected Enforcement is only one part of the equation however Much greater emphasis will need to be placed on voluntary controls and self-policing at community level through Co-management schemes
Failure to press ahead with governance and institutional reform could delay the process of introducing and registering licenses which represents a crucial first step in moving from open access to managed access in the fisheries sector Given the urgency for action the five years allowed in the current plan for completing the registration process seems very generous Political resolve to implement unpopular measures Stakeholder meetings have confirmed the significance of party political influence as a constraint on achieving progress in the reform of the fisheries sector The offer of incentives like subsidies or the promise of new facilities and equipment are regularly employed by individual politicians to garner votes whether or not these form part of party manifestos Examples have been quoted to the consultants where enabling regulations that might restrict fishing access and prove unpopular amongst the fishing community are quietly ignored and officers may be discouraged from pursuing breaches of the law where the offender has political influence These issues arise with governments of all political
55
persuasions and can apply at all levels from District Assemblies through to regional and national committees
A serious issue with fisheries sector reform is that once actions have been taken to conserve fish stocks it may be years before the full benefits are felt and the results are evident in terms of increased catches This makes it harder for governments to institute unpopular reforms ndash even though these are in the best interests of the nation fishing communities and individuals Fishermen and their families are used to seeing an instant lsquosame day returnrsquo on their catch and are less willing or able than stakeholders in other economic sectors to wait for gradual improvements There is an urgent need to establish cross-party support for the fisheries sector in Ghana and to seek agreements between the main political parties to support established policy and regulations where these are in the interests of delivering sustainable fish stocks Availability of Technical and Financial Resources The process of moving from complete open access to restricted use rights for both marine and inland capture fisheries will take many years to complete Progress will be heavily influenced by the level of political will availability of technical assistance and financial support Existing subsidies (pre-mix fuel and import tariffs) are seen as a deterrent to the encouragement of more efficient business practices However in order to reduce dependencies on these forms of government aid there is also a need to underwrite new forms of economic enterprise by giving help to start-up businesses developing training centres and promoting alternative livelihoods for those individuals who are either displaced or voluntarily give up work in the fisheries sector Inertia to Change Traditional fishing practices are quite literally a way of life for many Ghanaians and have been handed down from generation to generation These traditions are closely interlinked with cultural practices and power and influence resides in specific families with hereditary authority In order to change attitudes and gain acceptance of new approaches to fishing there is a need for a major awareness building and communications strategy targeting in particular the traditional leaders of the fishing industry Without such a plan it will be difficult to break down the internal resistance and inertia towards change The constraints that have been outlined above in relation to the lsquoweakrsquo option are very real and in combination they present a serious barrier to progress It will require real political commitment on the part of Government and strong financial support from international partners to break down these barriers 74 OPTION C THE lsquoOPTIMUMrsquo SOLUTION
The new Draft Fisheries and Aquaculture Plan together with the Act and Policies provide a solid foundation for revitalising the fisheries sector in Ghana However for the reasons discussed in relation to options A and B above there are a number of impediments that need to be overcome In addition to the measures in Option B an ldquoOptimumrdquo solution would also include
A coherent mix of Incentives (carrots) and Regulation (sticks) A top priority in developing existing strategies and plans will be to ensure that measures are in place to offer encouragement and practical assistance to fishers to convert to more sustainable practices while at the same time introducing effective enforcement There are some real challenges with both of these goals
56
New forms of incentive need to be developed to convince boat owners and their crews that it is worth their while to drop illegal methods (dynamiting use of monofilament nets etc) and to reduce the level of fishing effort (through close seasons introduction of restricted zones etc) Without these incentives it is highly unlikely that there will be significant take-up of the fisheries stock management and conservation message Special attention needs to be given to the role of chief fishermen and local community councils in developing effective local policing since it is impractical to rely on a national MCS team to regulate canoe activity in either the marine or inland capture fisheries The national MCS team will have its own responsibilities for policing local and international waters in relation to industrial and semi-industrial sized vessels Integrated Coastal Development The long term success of the fisheries strategy depends upon reducing fishing effort to a level at which catches become both sustainable and profitable for those who remain in the business This in turn requires that those displaced from the industry are able to find gainful employment and livelihoods in other sectors of the economy The fisheries industry is often seen as a separate economic sector which attracts its own funding and support but in order for the necessary reforms to take place these attitudes will need to change A new approach is required to lsquointegrated coastal developmentrsquo following the lessons from integrated rural development Many fishing inland and marine fishing communities are almost wholly dependent on fishing with less than 10 of the local economy being devoted to other industries Reform of the fishing sector therefore requires that as much ndash if not more ndash effort is devoted by government and its international partners to building up complementary economic activities in construction transportation manufacturing food processing environmental conservation and tourism There is a need to explore new state industry partnerships to establish appropriate economic development agencies and to coordinate activities between relevant state institutions ministries and departments under the current decentralisation initiatives with district assemblies taking a prominent role If initiatives of this sort are taken forward it will make the task much easier in persuading conservatively ndashminded fishing communities that they need to simultaneously develop their own entrepreneurial flair and impose their own discipline
57
Chapter 8 DRAFT ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK (ESMF) 81 INTRODUCTION Previous chapters of this report have described the principal environmental and social impacts that are likely to arise from reform in the fisheries sector This chapter sets out the Framework (ESMF) for an Environmental and Social Management Plan (ESMP)The first step has been to outline specific objectives to be achieved through implementation of the ESMF These objectives relate specifically to the issues described in earlier chapters Subsequent sections of the chapter detail the measures which are required to respond to specific areas of environmental and social impact through mitigation and amelioration works They also describe the types and level of environmental monitoring required together with the institutional aspects which need to be improved in order to support the fisheries sector 82 STRATEGY AND OBJECTIVES The basic aim of the environmental and social management plan is to set out guidelines for participatory programs under which members of local fishing communities and civil society in general can become involved in the design and implementation of local fishery co-management maintaining sustainable local livelihoods and achieving local monitoring of fishery efforts The basic principle for future fisheries management is that both marine and inland waters will be demarcated as territories for use rights to fisheries (TURFs) The principal goal of government policy in the fisheries sector is to ensure that the fisheries industry plays an increasingly important role in supporting the growth of the economy as outlined in the Ghana poverty reduction strategy (GPRS II) and the Republic of Ghana fisheries and aquaculture policy This goal will be supported by implementation of the fisheries and aquaculture sector development plan over the next five years In this timescale the aim will be to bull improve management of fisheries the conservation of aquatic resources and protection of the
natural environment bull promote value addition in the fisheries sector and the improvement of livelihoods in fisheries
communities bull encourage sustainable development of aquaculture bull improve the services provided to the fisheries sector by the fisheries commission and supporting
institutions The overall consequences of this strategy and the investments that are being made by the government and its aid partners will be stabilisation of fish stocks and sustainable catch levels a strengthening of the national economy and creation of a more robust fisheries industry with consequent benefits for fishing communities Impact assessment confirms that the result will be significant benefits for the marine environment and local economy However depending on the rate of transition from an open access to a fully regulated market a number of adverse effects could arise unless appropriate mitigation measures are put in place Specific issues which require attention in this plan are listed below bull potential risks of environmental degradation through development of new fishing targets in
deep water
58
bull localised environmental impacts at construction sites bull loss of resources for individual operators due to restricted or controlled access to fishing
grounds bull displacement of labour from crews of vessels that are withdrawn from the industrial and semi-
industrial fleet bull Decommissioning of obsolete industrial vessels may not necessarily lead to recovery of fish
stocks Catch Per Unit Effort (CPUE) may increase This could lead to loss of livelihoods to crew members and the owners of the decommissioned vessels it could increase catch for the few vessels remaining in the system
bull increase production costs due to idling time in closed seasons for fishing bull exclusion of some groups and individuals seeking entrance to the industry following completion
of licensing bull concentration of processing and marketing at selected landing sites leaving Fish Mammies and
their dependents in other smaller fishing communities at an economic disadvantage bull displacement of traditional canoe building and other ancillary support industries by more
efficient and modern methods of construction and the inability of some workers in these trades to train and re-skill in the use of modern materials
bull lack of employment opportunities in alternative sectors The ESMF will set out specific actions to address these concerns through a coordinated set of interlinked proposals as follows 1) Preparation of local management plans and close surveillance of all new fishing enterprises in
deep waters
2) Preparation of environmental protection clauses to be included in all contracts and agreements for physical development work
3) Regular inspection by environmental protection officers of construction work at harbours and landing sites
4) Establishment of community management plans to provide support to those groups and individuals who are adversely affected by any of the measures listed above
5) Creation of community liaison groups to actively support community development alternative livelihoods and conversion to new areas of economic activity for those Fisher families or individual fishers who are adversely impacted
6) Introduction of skills training centres and business advice for small and medium enterprise development
7) Establishment of a coastal development agency drawing on the resources of the ministry of local government agriculture and tourism (others to be added) to coordinate integrated projects and initiatives for economic development linked with the existing coastal zone management plans
8) Creation of a liaison group between the government of Ghana and its international development partners to ensure that investment in the fisheries sector is targeted in the most effective way to deliver plan objectives and avoid duplication of effort
59
83 COMPONENTS OF THE ESMF The following paragraphs provide a summary of the draft ESMF 831 Local Management Plans these plans will be prepared for discrete zones of influence around specified fishing settlements Each plan will contain the same standard list of relevant activities that are to be monitored 832 Environmental Protection In relation to construction activity a checklist will be prepared identifying precisely what level of environmental scrutiny is required for specific types of development This checklist will be prepared by the Fisheries Commission with the support and advice of the Environmental Protection Agency 833 Small-Scale Project Development and Livelihood Restoration a list of potential micro-projects will be prepared by the Fisheries Commission which are regarded as suitable for support funding Demand for these micro-projects will be determined at the local level (ie in villages and fishing communities) Applications for funding of micro-projects will be submitted to the community liaison group for vetting and recommendation based on pre-established eligibility criteria Recommended projects will be referred for formal approval at national level (or through the Coastal Development Agency) 84 POTENTIAL PROJECT IMPACTS ON ASSETS AND LIVELIHOODS The project will have some adverse impacts on assets and livelihoods Therefore provisions will be made under the ESMF to minimize all such impacts including those of socio- economic significance and on any environmentally sensitive sites Provisions are also made in the RPF to accommodate all potential situations including cases that may entail actual displacement and livelihood restoration assistance in accordance with the Governmentrsquos policy and World Bank Policy on Involuntary Resettlement OP412 (see Chapters 9 and 10) The potential social and environmental impacts associated with the project (see Chapters 5 and 6) are summarised in Table 81 and the approach to related mitigation measures is defined in section 85 and Table 82 below
Table 81 Potential Environmental impacts and Social issues
Type of Activity Description Environmental Significance
Social Significance
Decommissioning of obsolete industrial vessels
Scrapping of vessels may release toxic waste (contaminated oils asbestos pipe wrapping and insulation etc)
Contamination of landfill dumps
Related health hazards
Laying off of work force Recovery of fish stocks in areas currently over-fished by trawling
Decommissioning of excessovercapacity would result in loss of livelihoods for crew members
60
Plan for fishing capacity reduction
introduction of licensing system for canoes and enforcement of licensing system for semi industrial vessels
Reduced catch from the decline in the use of prohibited fishing methods (activities) as stipulated in the Fisheries Regulation 2010 (LI1968) eg use of light dynamite etc
Reduction in fishing capacity should lead to significant recovery of fish stocks with long term benefits for all
Short term reduction in fishing effort and increased regulation may prejudice vulnerable sectors (illiterate elderly fishers) Capping on new entrants may remove the safety net opportunity offered by fisheries to would-be fishers who may be without alternative livelihoods
Harbour development and landing site improvements
Construction of access road improvements Erection of fish processing and ice making plant The Project could give rise to a small level of physical displacement for some sectors of individual communities
Removal of shelters homes Displacement of boat repair and trading sites for local community
Possible non-voluntary resettlement including vulnerable groups (women children and the elderly)
Adaptation Strategies to climate change
Introduction over time of regulations relating to fishing activity in rivers lakes estuaries lagoons and lsquoareas of upwelling affected by climate change
Measures to combat tackle rising temperature and other climate induced changes should ameliorate environmental impacts
Both beneficial and adverse effects may result from changes in climate (eg faster growth rates from higher water temperature spread of invasive species)
Establishment of exclusion zones ndash oil production and marine protection areas
Restrictions on fishing in oil production areas and marine protection areas
Positive ndash recovery of fish stocks but also potential risks of pollution from oil leaks and human waste
Temporary loss of livelihood for those fishers displaced from lsquotraditionalrsquo fishing grounds
Development of Co-Management System
Creation of 4 pilot Stakeholder ndashbased Fisheries Management Initiatives
Demonstration of practical benefits for the marine environment resulting from elimination of damaging practices
Greater social cohesion and sense of purpose established
61
Type of Activity Description Environmental Significance
Social Significance
Support for PAPs Establishment of enterprise training programmes
Development of criteria for defining Project Affected Persons (PAP) Development of skills training schemes enterprise allowances alternative livelihoods fund
Major benefits for PAPs ndash but scope for misinterpretation mismanagement of programme at local level Jobs created under social significance should be familiar to the fishers ie things they will be willing to do
Developing Compliance Systems
Establishment of enforcement unit and development of facilities and training for participatory coastal surveillance of small-scale fisheries
This component will greatly improve controls over environmentally unfriendly damaging activities
A number of new jobs should be created under this programme
Improvements in fish processing technology
Development of more efficient fish processing plant
This measure should reduce significantly the proportion of fish lost or degraded post harvest Improved fish processing technology will also reduce wood used from the forest as firewood for fish smoking
Potential displacement of vulnerable groups (women children and the elderly)who currently participate in fish drying curing using basic equipment
Construction of fish ponds
Expanding areas of dug-outs and other farm ponds
Small scale impacts on vegetation stream flow
Displacement of existing land users
Catalysing aquaculture development
Encouragement of larger fish farming enterprises Installation of fish cage aquaculture
Localised deterioration in water quality increased nutrients leading to eutrophication potential spread of fish parasites disease
Potential competition with free capture fisheries displacing vulnerable groups in existing fishing villages
62
85 PROPOSED MITIGATION MEASURES AND COST ESTIMATES Mitigation measures The potential environmental and social impacts to be addressed within the context of preparing this Environmental and Social Management Framework are generalized as shown in Table 82 below It is not possible at this time to prepare specific mitigation measures It is expected though that environmental and social assessment studies will be carried out within specific localities as and when required The framework for compensationresettlement (See Chapters 9 and 10) will then be applied incorporating (1) specific institutional arrangements (2) resettlementcompensation eligibility criteria (3) implementation procedures (4) financial responsibilities and (5) monitoring and evaluation plan Livelihood restoration measures Furthermore the livelihood restoration measures will consider issues such as
(1) income levels of affected persons
(2) other non-monetary sources of livelihood
(3) constraints and opportunities for income generation
(4) number of persons not able to revert to previous occupation and
(5) existing skills of affected persons
Table 82 Proposed mitigation measures for some potential impacts
Type of Impact Description of mitigation measures
1 Decommissioning of obsolete industrial vessels
a) A register will be prepared of all industrial vessels that are due to be decommissioned recording the owner and location of each vessel b) A system will be introduced for tracking progress on decommissioning including the means of disposal and measures taken to dispose of all potentially toxic or hazardous materials c) Persons who lose their job or livelihood as a result of a decision to decommission any particular vessel will be entitled to benefit from the skills training schemes enterprise allowances alternative livelihoods fund being developed
2 Plan for fishing capacity reduction
a) A full Social and Environmental Impact Assessment will be carried out on the Plan for fishing capacity reduction and appropriate measures for ameliorating and mitigating adverse effects on affected sectors of the community and PAPs will be incorporated in a revised edition of this Fisheries Environmental and Social Management Framework
63
3 Harbour development and landing site improvements
a) All harbour development proposals will be subject to Environmental and Social Impact Assessment (ESSA) in accordance with EPA Regulations b) Proposals for improvement of individual landing sites will be assessed in accordance with the checklist (832) and submitted to EPA for a ruling on the level of environmental assessment that is required which will depend on the nature of the intended works
4 Adaptation Strategies to climate change
a) An adaptation Strategy shall include proposals for mitigating any impacts on the environment or social welfare of local communities
b) Any strategy for responding to potential effects of climate change on the fisheries sector will be submitted to EPA for review to determine whether an SEA or EIA is required
5 Establishment of exclusion zones ndash oil production and marine protection areas
a) Proposals for restricting access of fishing vessels to oil production areas and marine production areas shall be subject to an Environmental and Social Assessment which shall be submitted for approval to EPA b) In the event that restrictions are likely to adversely affect fishersrsquo livelihoods the provisions set out in 7 below will apply
6 Development of Co-Management System
a) Development of co-management systems will require full cooperation and engagement of all stakeholders In the unlikely event that the provisions of any scheme are challenged by local communities there shall be a right of appeal to the Minister of Food and Agriculture and the Fisheries Commission acting jointly
7 Support for PAPs
Establishment of enterprise training programmes
a) Identification of vulnerable people including women children and the elderly and identification of the cause and impacts of their vulnerability shall be established through direct interviews and procedures to be developed as part of 6 above b) A high priority within the Fisheries and Aquaculture Sector Development Plansrsquo first five year programme will be the development of specific proposals for the establishment of skills training programmes and the establishment of enterprise allowances and an alternative livelihoods fund c) The measures outlined in 7b) above will be targeted specifically at PAPs and vulnerable sectors of the community
8 Developing Compliance Systems
a) All proposals for securing compliance with fisheries regulations shall be subject to review by a fisheries stakeholder committee to be established by the Fisheries Commission with the remit of ensuring that the measures themselves and penalties for failure to comply are commensurate with the ability of offenders to make restitution and do not unfairly penalize vulnerable sectors of the community
9 Improvements in fish processing technology
a) All plans and proposals for the introduction of new fish processing technology shall be published and shall include a statement on the likely impact of the project on existing processors within the local community
64
b) Any members of the public who consider they are unfairly disadvantaged by proposals for the introduction of new technology may apply to the local co-management committee to determine whether or not they fall within the category of PAP (see 6 and 7 above)
10 Construction of fish ponds Proposals for the construction of new fish ponds shall be assessed in accordance with the checklist (see section 832)
11 Catalysing aquaculture development
a) All proposals for aquaculture development shall be in accordance with the provisions laid down in Local Management Plans applying to specific TURFs
65
9
The report is based on three major areas of activity 1 documentary analysis and utilisation of the studies already carried out by the fisheries commission 2 meetings with institutional stakeholders principally affected by the project and 3 Consultations and visits to some of the key fishing villages and communities The planned presentation of findings to Stakeholders has been postponed at the Clientrsquos request due to other pressing commitments in the agriculture and fisheries sectors This presentation will however need to be subsequently undertaken by the Ministry and the Fisheries Commission
11
CHAPTER 2 PLAN AND PROGRAMME DESCRIPTION
INTRODUCTION This chapter is divided into two parts Part 1 sets out the progress which the government Ghana is making in giving effect to the legislation policy and regulations Part 2 describes the proposed programme of assistance being offered by the World Bank with the specific aims of strengthening governance and enforcement systems (Components 1 and 2) and in promoting value addition and reduction of post-harvest losses
PART 1- THE DRAFT FISHERIES AND AQUACULTURE SECTOR DEVELOPMENT PLAN (FASDP) This plan (FASDP) covers the period 2010-2015 It recognises the importance of Ghanarsquos fisheries which generate in the order of US$ 1 billion a year contribute 45 to GDP and indirectly support the livelihoods of 22 million people However through over-fishing and lack of investment in management and value addition the average income per canoe has dropped by up to 40 over the last ten years to the point where it costs as much to fish as the catch is worth By comparison well managed fisheries in other parts of the world are capable of generating economic returns of 30-60 on investment (equivalent to a potential income of US$ 300 million a year for Ghanarsquos fisheries) The Draft FASDP acknowledges that the fishing sector is expected to make a substantial contribution towards doubling the size of the Ghanaian economy by 2015 (GPRS II) as part of the Republic of Ghana Fisheries and Aquaculture Policy Seven targets are set in the draft FASDP 1 Maintaining capture fisheries production at current levels 2amp3 Increasing revenue and profitability in capture fisheries by at least US$ 50 million a year after
five years 4 Increasing aquaculture production to 35000 tonnes a year after five years 5 Retaining Ghana as a landing and processing hub for the West Africa tuna industry 6 Developing fisheries management to allow effective control of all commercial fishing effort in
Ghanaian waters and 7 Ensuring fisheries management costs are sustainable and that the fisheries sector overall make a
fiscal contribution to Government revenues There is an underlying presumption that the canoe sector will remain at the heart of Ghanarsquos fishing industry but the plan is not prescriptive and leaves open the ways of achieving the overall goals At the same time there is an underlying assumption that the long term sustainability of Ghanarsquos fisheries will depend upon discouraging further entry by new operators
PART 2 THE WORLD BANKrsquos CONTRIBUTION TO GHANA FISHERIESPLAN (FASDP)
The essential aim of the World Bankrsquos contribution to FASDP is to provide investment which will build the necessary policy and capacity for effective fisheries management designed to reduce fishing effort while maintaining approximately the same catch levels and to address the impacts of change for fishers
12
and the communities in which they live Based on the currently available draft Project Appraisal Document (PAD) each of the components is now described in turn Component 1 - Good governance and sustainable management of the fisheries This component on good governance comprises four subcomponents which are broken down in turn into a number of separate activities Sub-component 11 developing the capacity rules procedures and practices for good governance of the fisheries Activity 111 reviewing the Fisheries Act and developing regulations to support the Sector Policy and the Fisheries and Aquaculture Sector Development Plan Activity 112 Developing an operational policy to enable implementation of the aquaculture and fisheries sector development plan Activity 11 3 strengthening fisheries management systems and capability (fisheries management plan development aquaculture implementation technical support and training) Activity 114 strengthening fisheries Information Systems (catch recording and monitoring systems statistical analysis and training)
Sub-component 12 introducing fishing rights
Activity 121 developing pilot stakeholder-based fisheries management initiatives around defined fisheries units (ie local management initiatives tighter defining fisheries resources in up to 6 selected Fisher communities) Activity 122 introducing and administering a licensing regime
Subcomponent 13 Adjusting fishing effort and capacity to more sustainable levels marine resource conservation and supporting alternative livelihood opportunities when needed Activity 131 vessel decommissioning Activity 132 compensation packages for crew of decommissioned industrialsemi-industrial vessels Activity 133 alternative livelihood development to incentivise voluntary capacity reduction in the canoe sector Activity 134 marine resources management and conservation
Subcomponent 14 social marketing communication and transparency Activity 141 communications stakeholder consultations and awareness raising programmes to support fishery development Component 2 reduction of illegal fishing Under the West Africa regional fisheries programme subcomponent 21 allows for enabling environment for reduction of illegal fishing These provisions already exist within Ghana and this subcomponent is therefore omitted Subcomponent 22 monitoring control and surveillance (MCS) systems Activity 221 developing compliant systems and capability
13
Component 3 increasing the contribution of the marine fish resources to the local economies Subcomponent 31 product diversificationvalue chain development (freshfrozen producttrade facilitation) Activity 311 landing site development Activity 312 Port development Subcomponent 32 fish product trade infrastructure information and systems - regional minimum integrated trade expansion platform (MITEP) Activity 321 export certification centre development Activity 322 fish processing technology improvements Activity 323 national fisheries advisory group Subcomponent 33 marine and inland aquaculture development Activity 331 space developing aquaculture policy and legal framework Activity 332 improving genetic policy of tilapia fingerlings and breedstock Activity 333 catalysing aquaculture development Component 4 Coordination monitoring and evaluation and program management Subcomponent 41 national implementation subcomponent 42 regional coordination Each of the components sub-components and activities are described in more detail in Chapter 5 which assesses the nature of environmental and social safeguards issues in terms of the World Bankrsquos planned investment
15
CHAPTER 3 BASELINE CONDITIONS
INTRODUCTION This chapter discusses the existing fishery resources of Ghana and describes recent environmental and social trends It identifies some of the pressures that led to the reduction in value of fishing activity and indicates the threats that could be posed if no action is taken in accordance with the planned fisheries and aquaculture program to deal with them FISHERY RESOURCES The continental and coastal waters of Ghana are potentially very rich due to a combination of warm waters and nutrients carried in ocean currents which up-well seasonally on the continental shelf The tonnage of fish caught in marine waters peaked in the mid-1990s around 500000 tonnes and currently averages around 400000 t(See Figure 1) Figure 1 Wild Capture Production in Ghana 1950-2005
2
Table31 Top 10 Species Exported (by value)
1 Canned tuna ($72000000) 2 Fresh tuna ($7200000) 3 Tilapia (no figure available) 4 Miscellaneous dried fish ($1000000) 5 Salmonids frozen ($900000) 6 Marine fish frozen ($600000) 7 Cuttlefish and squid ($600000) 8 Shrimps and prawns ($90000) 9 Sardines ($80000) 10 Crustaceans frozen ($50000) Source FAO Fishstat
The principal catch from deep waters is tuna Industrial vessels registered in Ghana target these species in international waters but also illegally in coastal waters Herring sardine and anchovies are fished in coastal waters by semi-industrial vessels and canoes Table 31 shows the top 10 species of fish exported from Ghana in 2005 PROFILE OF THE FISHING INDUSTRY Fishing is of vital importance in Ghana not only in terms of its contribution to gross domestic product (45 per annum) but because fish provides 65 of the countrys protein In recent years (between 2003-2008) and more specifically in 2004 the countryrsquos annual fish requirement has been estimated to be 882000 tonnes of which the country produces just about half (Tetteh 2007) Of the total population of 22 million people it has been estimated that between 15 and 22 million people are employed or gain their livelihoods from fishing (8-10) Of these there are 210000 men who are directly employed as
2 This figure is the Fisheries Departmentrsquos estimate for 2008
16
fishers The total export of seafood was valued US$824 billion in 2005 Ghanas fishing industry can be divided into three sections marine capture inland capture and aquaculture It can be further analysed by scale of operations distinguishing between industrial semi-industrial and artisanal sectors Marine fisheries Industrial sector Commercial fishing for tuna began in 1962 In the early 1980s Ghana sought to develop an industrial fishing fleet and there are currently 90 industrial trawlers and other vessels which are located in Tema and Takoradi Sekondi The port of Tema was expanded from 1962 to create four main areas the Inner Harbour Outer Harbour Canoe Basin and Commercial Area In 1999 fish landing facilities were improved at the Albert Bosumtwi Sam Fishing Harbour built in Sekondi This harbour is equipped with a cold store an ice-making plant offices a berthing bay for inshore vessels a jetty for canoes and a net drying area Under Ghanaian law more than 50 of the ownership of industrial vessels must be registered with a Ghanaian company or individuals However in practice many vessels are owned by foreign nationals with token Ghanaian ownership Relatively few of these large vessels regularly put to sea and a number are in poor condition or obsolete Nevertheless the impact of trawling activities by Ghanaian registered and foreign owned vessels has been very considerable in coastal waters in recent years Fish landed from industrial vessels is usually transferred directly to Canning factories in Tema and Takoradi Ghana has the largest canning industry in West Africa In the region of 30000 tonnes of tuna are landed In addition to trawling some industrial vessels are engaged in shrimping the use of tuna lines and polls purse seining and demersal trawling Semi-industrial sector in addition to deep sea trawlers there are around 230 large semi-industrial ships propelled by inboard motors which are used for trawling in shallow waters during the off-season and purse seining during upwelling seasons There are currently reported to be 48 bottom trawlers 14 pair trawlers 2 shrimpers 33 pole and line vessels and 10 tuna purse seiners operating from 2 of the 7 landing sites Canoe sector Ghanas artisanal fishing sector is based on between 10000 and 12000 wooden canoes Fifty seven per cent of the fleet is powered by outboard motors supported by paddle and occasionally sail Each Canoe carries a crew of between three and 20 men depending on size and length There are over 334 landing sites along the 550 km coast of Ghana and the majority of fish caught by canoe (180000 tonnes) is returned to these sites accounting for 70 of Ghanarsquos fish production The principal landing sites are at Teshie Jamestown Chorkor Shama Axim Elmina Winneba Mumford Akplabonya Adina Atiteti Abutiakope and more Fishing is undertaken by men but the majority of canoes are owned by women who pre-finance fishing trips (purchasing gear and premixed fuel) and purchase the catch Women also predominate in processing and marketing fish and fish products Only about 20 of fish sold fresh a further 20 is salted and the majority (60) is smoked It is estimated that up to 30 of the catch is spoilt through lack of ice for storage or alternative processing facilities
17
Inland fisheries Water Resources Ghanarsquos inland fishery resources consist of a natural lake( Lake Bosomtwe) and nine major river basins which from east to west of the country are
bull the Volta bull Densu bull Ayensu bull Ochi bull Kakum bull Pra bull Ankobra and bull the Tano
The River Tano forms the border between Ghana and Cote drsquo Ivoire The largest of the rivers is the Volta which drains more than two-thirds of the country through several large tributaries in virtually all regions of the country The Volta river system also incorporates the Volta reservoir generally known as the Volta Lake which has a surface area of around 8400 km2 The Volta lake discharges through the Akosombo dam before flowing through a delta into the Atlantic Ocean The eight other river systems are relatively smaller simpler and open more directly into the Atlantic There are also several reservoirs created on the smaller river systems mainly for potable water production irrigation and flood control These reservoirs irrespective of their primary purposes enhance availability of more permanent aquatic habitable space for fish and therefore support some fisheries Finally with all the river systems opening into the Atlantic there are a series of lagoons and estuaries which act as interfaces between the rivers and the sea These water areas constitute another type of inland water resource for salt and brackish water fishes Inland Fish resources Within the inland water resources of Ghana there are over 150 fish species more than 90 of which are fished for food
In commenting on inland fisheries in Ghana it must be noted that virtually all available information on inland fisheries is obtained from the Volta Lake No national fish production records have been kept on the fisheries of the eight smaller river systems and the lagoons and estuaries Thus the usual statement that inland fish production constitutes about 20 of what the country produces should refer to fish production from the Volta Lake In practice the total inland fish contribution could more realistically be estimated at about 30-35 of national fish production This is a very considerable but understated contribution to national food security and nutrition
Fishing vessels The dominant fishing vessel on the Volta Lake is the canoe the majority of which are built from wooden planks On some other river systems while plank canoes predominate a small number are carved as dug-outs from single tree trunks There is some variety in sizes of the canoes depending on how many planks are used to build the boat and the size of tree trunk used in building a canoe The total number of canoes estimated on the Volta Lake during a survey in 2000 was 24035 On the tributary rivers of the Volta Lake and other river systems in the country the planked canoe is the main vessel used in fishing
18
Fishing gear There are about eleven main kinds of gear used for fishing on the Volta Lake They are Gill Nets Cast Nets Hook and Line Basket and wire mesh traps Winch net Beach seine Bamboo Nifa-nifa Wangara Spears and Atidzas On other rivers in the country Gill nets Cast nets Hook and Line and traps are the fishing gear used On both the lake and rivers the Gill net is the main gear
People Involved In the 2000 frame survey of the Volta Lake conducted by the Fisheries Directorate of Ghana the estimate of fishers on the Volta Lake was put at 71861 Fishers on the lake work in collaboration with a host of fishmongers or handlers who also function as wholesalers for individual fishing groups Assuming that the fisher population on the lake has increased by a modest 3 in the ten years from 1998 to 2010 a fisher population of about 93500 could be considered to be on the Volta Lake now If again it is estimated that number of fishers on rivers in the country were to be a tenth of those on the lake this would put the fisher population on inland waters (apart from the Volta Lake) at about 9350 fishers A very conservative estimate therefore puts the total number of individuals who are directly engaged in inland fishing at over 100000 This excludes all directly associated groups such as fish handlers processors and traders An estimate of secondary fisheries operators such as boat builders out-board motor operators and mechanics as well as bulk salt and fuel wood sellers and those engaged in buying selling and distributing fish would have to be considered in developing estimates for both direct and indirect employment in inland fisheries but the number can be assumed to lie between 125000 and 150000 people
Aquaculture Under Ghanarsquos legal framework aquaculture is defined as ldquoany activity designed to cultivate or farm fish and other aquatic living resourcesrdquo Currently only fin fishes are involved in aquaculture in Ghana
Current culture media and environment Currently fish culture takes place almost exclusively in fresh water in Ghana either in cages brush parks or dugouts Dug-outs are excavations made in floodplains in the savannah parts of the country were water scarcity has been a major hindrance to development in general and food security in particular Dug-outs get filled with flood waters and whatever the water carries during major wet periods of a year in the savannah areas Waters that fill Dug-outs invariably contain fish which are trapped in the Dug-out after the wet period These water bodies are managed until the end of the dry period and the fish are harvested before the next flood period Since the 1960rsquos various strategies to augment fish production from Dug-outs have been developed and tested These involve adding fingerlings of selected fish species to those which are lsquonaturally stockedrsquo in Dug-outs by floods Dug-outs are the major fish culture production approach in the savannah parts of the country which accounts for a little more than half the area of the country The Environment of fish culture Currently fish culture is taking place mainly in freshwater environments Brackish water fish culture and mari-culture activities which will bring lagoons estuaries and the sea into fish culture production have long term potential for development Fishes in culture Fishes being cultivated in Ghana In order of importance are Nile tilapia Oreochromis niloticus the African catfish Clarias gariepinus species of the catfish Heterobranchus and the Bony tongue Heterotis niloticus Scale of Culture Based on level of production fish culture operations can be categorized as follows
bull Large scale commercial where an enterprise produces up to 10000 tonnes per year
19
bull Medium scale commercial where a single enterprise produces between 50 and 500 tonnes bull Small scale commercial where an enterprise produces between one and 20 tonnes and bull Very small scale commercial with productions below 20 tonnes
Fish culture production Cultured fish contribution to national production was officially stated as 9000 tonnes for the year 2009 However informed opinion amongst fish farmers indicates that a figure of between 16000 and 20000 tonnes in 2010 would be closer to reality This statement is based on the facts that most producersrsquo published figures are underestimates several small to medium scale producers are not recorded in official lists and the recording of newly established fish farms has lagged actual establishment especially since 2009 Although cultured production up till 2009 may not have been significant considering a shortfall of about 460000 mt (as recorded in 2004) between captured fish production and national demand this reflected the fact that there were only two large scale commercial producers in the country each of which had had less than ten years of operation Anticipated growth in fish culture production within the next five years is expected to be dramatic as some of the critical challenges of the industry are resolved
CHALLENGES AND PROSPECTS Marine Fisheries The fishing sector is vital for food security and job creation to help alleviate rural poverty in Ghana However the levels of fisheries harvests are generally considered to be close to or to have exceeded the maximum sustained yield Future sustainability in the industry will depend upon the restriction of open access to fisheries and the introduction of management systems which allow fish stocks to recover and the establishment of consistent yields in both marine and inland waters Inland Fisheries Environmental conditions on the Volta Lake constitute the major environmental and social challenges for fisheries its sustainability and profitability In terms of future prospects success will depend heavily on implementation of the lsquoGhana Fisheries and Aquaculture Sector Development Planrsquo and the capacity of the system in Ghana to enforce the Fisheries Regulations passed by parliament in August 2010 Aspects of the Development plan that offers great prospects for the lakes fisheries include the provisions for eventually licensing boats (although the scale of this task should not be underestimated) and measures to involve communities in management of fisheries resources of the Lake
Aquaculture The main challenges facing aquaculture development in Ghana relate to bull The high cost of fish feed (significantly due to its importation from other countries) bull None availability of commercial fish hatcheries as enterprises bull Lack of a nation-wide distribution network for fish seed and cultured fish producers Most
sources of fingerlings are concentrated in one part of the country and since farms all over Ghana obtain their fingerlings individually transportation costs add significantly to overall production costs
bull Now emerging certification and monitoring to check the health and safety of aquaculture processes and products
bull The absence of adequate regulations regarding establishment of an aquaculture enterprise until August 2010 (In the absence of regulations only the large and medium scale commercial farms worked towards conforming to international performance Standards and operational regulations for certification of farms and their products still remain in a draft state)
bull Low national support for research to support expansion and systematic development of aquaculture
20
The prospects for development of aquaculture as an industry in Ghana are good since a number of practical policy and legal frameworks have been put in place to resolve the basic challenges to the industry listed above These include
bull Construction of the first local fish feed plant by an international fish feed company with the expectation of having initial products on the Ghanaian market during 2011
bull A lsquoLarge scale commercial fish farmrsquo with great capacity for fingerling production is shifting emphasis to fish seed production And several localized fish seed producers are expanding operations
bull Distribution strategies by cultured fish producers have started to emerge on a limited scale and are expected to evolve with increasing production as existing commercial farms expand and new ones join in
Now that regulations regarding establishment of aquaculture enterprises have been gazetted there is likely to be a positive response amongst fish farmers of all size categories New operational standards are being prepared which will introduce minimum standards for local certification This should set the stage for preparation of fish culture products and the broadening of choice for consumers while also qualifying Ghanaian producers to enter external markets
ENVIRONMENTAL CONDITIONS The coastal and marine environment a critical zone of influence for this study comprises a 550 km coastline a coastal belt ranging from 1 to 20 km in width and coastal waters extending to 200 nautical mile limit which was established in 1977(under the territorial waters and continental shelf act 1973 as amended by the territorial waters and continental shelf amendment decree 1977) The Coastal Belt The coastal belt accounts for only 65 of the land mass of Ghana but it is one of the most densely settled areas accounting for 25 of the population and80 of the industrial establishments in Ghana Historically the coastal zone was cultivated for coconut (copra) but this industry is in decline Vegetables and other agricultural produce are grown on better soils but the principal economic activities are fishing transportation salt production and sand and stone winning Tourism also offers great potential There is considerable expectation that the discovery of offshore oil and gas deposits will bring new wealth to parts of the coastal corridor However present plans to transfer crude products to tankers at sea and then export them directly will limit industrial activity to a support role A high percentage of industrial and municipal wastes is dumped at landfill sites within the coastal zone which creates pollution risks The coastal belt is generally a low-lying area less than 200 m above sea level Vegetation types reflect the rainfall gradient and consist of coastal shrub and Savannah to Winneba southern marginal forest to the east of Sekondi dry semi-deciduous and moist semi-deciduous forest to the east of Cape Three Points estuary and wet evergreen forest in the extreme south Soils are variable within this area ranging from fertile pockets river valleys to Sandy poorer quality soils close to the sea The Coast The coast line divides into three sections (Ly 1980)
bull West of Cape Three Points this area has a wide and flat beaches backed by coastal lagoons and
21
wave heights are generally low bull Between Cape three points and Tema the coast consists of a series of rock headlands enclosing
shallow bays together with sandbars or spits enclosing coastal lagoons The surf zone is a medium to high energy environment with wave heights often exceeding 1 m South-westerly prevailing winds give rise to longshore drift in an easterly direction
bull Between Tema and Aflao most of the shore is sandy although there are rocky outlets The coastal zone is important internationally in providing feeding roosting and nesting sites for thousands of migratory birds Environmental degradation is significant in Ghana and is recognized in the countryrsquos environmental action plan It contributes to rising poverty levels coupled with poor human health and inadequately planned urbanization which fuel a vicious cycle inhibiting human development The core issues include
bull Domestic sanitation bull Increased urbanization without appropriate infrastructure bull Wetlands and mangrove degradation bull Coastal erosion and bull General biodiversity loss
Briefly each of the above could directly or indirectly adversely influence fisheries and aquaculture separately or together For example in a recently completed study of water quality scenarios of the Volta Lake in relation to fish production as a component of a comprehensive study (The Challenge Program Project of Water amp Food) it was concluded among others that poor sanitation in highly populated fisheries communities adversely influenced water quality to the detriment of fish life and thus fish production With reference to aquaculture the same unsanitary conditions in highly populated shore communities adversely influenced water quality especially in terms of oxygen depletion when lake waters extend to the shore in high water periods This is a situation which has caused fish kills in cages because caged fish cannot escape lsquopollutedrsquo waters Degradation of wetlands and mangroves leads directly to a reduction in their capacities as spawning and nursery zones for both marine and inland water fishes which reduce fish production in both environments The situation outlined above is often contributed to by anthropogenic and industrial pollution due to urbanization without appropriate infrastructure Another issue linking human activity to a deteriorating environment is demonstrated by the encroachment of aquatic weeds on inland waters such as the Volta Lake Weed growth is accelerated by farming reservoir catchments which increases nutrient levels and the building of dams which reduce or cut off intrusion of sea water into rivers Currently as climatic change observable impacts such as floods seem to escape predictions The project could possibly contribute to mitigating against direct and indirect effects of climate change on fishing and aquaculture through investment into climate change orientation and education of fishers and fish farmers to mainly influence reasonable precautions they take Marine waters The continental shelf is relatively narrow projecting out to 25-35 km except in the area of Cape Coast to Salt Pond where it extends to almost 80 kms Sandy and rocky substrates which previously supported coral and seaweeds have been severely affected by former trawling activity which indiscriminately
22
dredges material from the seabed Coastal waters are enriched by freshwater discharges from the relatively small number of rivers and by two seasonal up-wellings which occur between late June and early October (the main upwelling) and January and March (the minor upwelling) The origin and driving mechanisms of these up-wellings are not fully understood and both their location and strength varies from year to year
Lake Volta and other inland water
Major environmental issues on the Volta Lake which might also be considered as challenges to sustainable fisheries on the major inland fisheries resource can be summarised as follows
bull The Volta Lake is known to be low in nutrients It therefore has low standing crops of phytoplankton and zoo plankton to support high fish production
bull The northern segment of the lake together with tributary rivers constitute the spawning and feeding grounds for majority of fish species in the lake during the wet season however these segments are intensely fished during the same period
bull The Volta Lake is divided into eight unequal strata with different distribution of boats per Km2 At the last estimation of carrying capacity in 2000 stratum V and II had the highest (527) and lowest(157) number of boatsKm2 respectively
bull The rate of siltation in the lake is considered to be increasing due to erosion associated with high rates of deforestation
bull A major challenge exists in getting fishers fishing communities and fishing entrepreneurs to understand and comply with fishing regulations aimed at conserving fish and fisheries resources
bull There is a lack of resources studies and research to support fisheries management of the Lake
bull High illiteracy exists amongst lake shore communities
bull Open access to the fish resources of the Lake has been in operation since its formation
bull Declining fish yields are occurring in the lake (468 Kgha in 1976 to 320 Kgha in 2003-MOFA) brought about by the constraints listed above
bull The commonly assumed estimate of potential fish production from the lake of around 75500 mtyr) is considered to be a serious underestimate since Stratum VII alone was estimated to produce 33800mtyr in 1996
bull The policy environment for aquaculture is currently strongly supportive of the industry and related enterprises
bull There is good quality and more than sufficient water to allow some kind of aquaculture to be developed in every region of the country with the Volta lake (about 8400 Km2) as the single most important water unit for fish culture Currently it appears that the free access to the fish resources of the lake has to some extent been applied to establishment of small scale caged fish culture enterprises a situation constituting environmental risk to investments of large scale commercial fish culture establishments in the lake
bull The Volta Lake is low in nutrients (Obeng 1964) resulting in a situation where higher fish yields could be sustained if greater quantities of fish feed were available
23
bull In Ghana the Nile tilapia O niloticus occurred naturally only in the Volta system Due to positive culture characteristics of the fish it has been moved into virtually all other river basins in the country The situation provides opportunities for hybridization of the Nile tilapia with other tilapia species native to the river basin into which the Nile tilapia has been moved
25
CHAPTER 4 POLICY AND LEGAL FRAMEWORK FOR ENVIRONMENTAL AND SOCIAL ISSUES
41 INTRODUCTION
Development and implementation of the Ghana Fisheries and Aquaculture Sector Development Plan and the World Bankrsquos supporting program need to be developed with full regard to existing international conventions national legislation policies and regulations This chapter highlights the main legislative and policy considerations for the protection of the environment natural resources fisheries and social and economic development It begins with reference to the World Bankrsquos safeguard framework and those of other donors This is followed by a section on the governance framework in Ghana
42 WORLD BANK AND OTHER DONORSrsquo SAFEGUARDS POLICIES
The World Bankrsquos safeguard policies exist to ensure that all projects which it finances are developed and implemented on environmentally and socially sound principles A range of different policies exist and these have been carefully considered to ensure that the Ghana Fisheries and Aquaculture Development Sector Development Plan complies with these safeguards All policies have been screened and those that have no bearing on the fisheries programme have been excluded from Table 41 below Table 41 lists policies which could have some applicability to the FASDP even if this interaction might be very slight It is important to stress that the comments in the third column of Table 41 relate to the entirety of the Fisheries and Aquaculture Sector Development Plan whose effects will continue to be experienced long after the World Bankrsquos financial support has been expended Most of the activities in the FASDP will have no effect in relation to safeguard objectives and where there are implications these are likely to occur at precise locations (for example at fish landing sites) rather than throughout the industry Where potential interactions have been noted the necessary mitigating measures are incorporated in the Draft Process Framework
Table 41 World Bank Safeguard Policies in Context
Safeguard Policy
Safeguard Policy Objective Brief Description and relevance to FASDP
OP 401 Environmental Assessment
This policy aims to ensure that Bank-financed projects are environmentally sound and sustainable and that the decision-making process is improved through appropriate analysis of actions and mitigation of their likely environmental impacts This policy is triggered if a project is likely to carry potentially adverse environmental risks and impacts on its area of influence OP 401 covers impacts on the natural environment (air water and land)
The majority of actions planned under FASDP will be beneficial to the marine environment and to inland waters However new construction activities could have impacts and depending on the project and the nature of impacts a range of instruments can be used to ameliorate and mitigate adverse effects while enhancing beneficial effects These include EIA environmental audit risk assessment and environmental management plans (EMP) The need for EIA and EMP is considered in this report
26
OP 404 Natural Habitats
This policy recognizes that conservation of natural habitats is essential to safeguard their unique biodiversity and to maintain environmental services and goods for human society and for long-term sustainable development The Bank therefore supports the protection management and restoration of natural habitats in its project financing as well as policy dialogue and economic and sectoral work Natural habitats comprise many types of terrestrial freshwater coastal and marine ecosystems They include areas lightly modified by human activities but retaining their ecological functions and most native species
This policy is triggered by any project (including any sub-project under a sector investment or financial intermediary) with the potential to cause significant conversion (loss) or degradation of natural habitats whether directly (through construction) or indirectly (through human activities induced by the project) This policy is applicable to the Ghana Fisheries Programme because the project focuses on the integrated management of natural habitats However by screening all proposals under the ESMF any sub-projects that might impact these habitats will not be funded
OP 409 Pest Management
The objective of this project is to (i) promote the use of biological or environmental control and reduce reliance on synthetic chemical pesticides and (ii) strengthen the capacity of the countryrsquos regulatory framework and institutions to promote and support safe effective and environmentally sound pest management
The policy is triggered if (i) procurement of pesticides or pesticide application equipment is envisaged either directly through the project or indirectly through on-lending co-financing or government counterpart funding (ii) the project supports an activity requiring the use of pesticides that may have negative effects on the environment The only instance in which this policy might be triggered by the Ghana Fisheries Programme is if aquatic herbicides or antibiotics were to be used in connection with aquaculture This is most unlikely but can be monitored through the implementation programme
OP 411 Physical Cultural Resources
The policy objective is to assist countries in avoiding or mitigating adverse impacts of development projects on physical cultural resources For the purposes of this policy ldquophysical cultural resourcesrdquo are defined as movable or immovable objects sites structures groups of structures natural features and landscapes that have
Under the Ghana Fisheries Programme construction and rehabilitation activities that could have negative impacts on cultural property will be avoided In the case of discovery of remains national procedures will be applied
27
archaeological paleontological historical architectural religious aesthetic or other cultural significance
OP 412 Involuntary Resettlement
The objective of this policy is to (i) avoid or minimize involuntary resettlement where feasible while exploring all viable alternative project designs (ii) to assist displaced persons in raising their former living standards income-earning capacity and production levels or at least in restoring them (iii) encourage community participation in planning and implementing resettlement and (iv) provide assistance to affected people regardless of the legality of land tenure
The policy covers not only physical relocation but any loss of land or other assets resulting in (i) relocation or loss of shelter (ii) loss of assets or access to assets (iii) loss of income sources or means of livelihood whether or not the affected people must move to another location The activities of the Ghana Fisheries Programme are likely to result in loss of assets or access to assets and loss of income sources or means of livelihood for some groups and individuals The potential for such losses will be carefully scrutinised and compensated for through the National Process Framework and Resettlement Policy Framework described in this report and appropriate procedures will be followed where necessary
Other donors and aid agencies including International and National NGOs play an active role within the fisheries sector in Ghana and their safeguards standards will be observed through operation of the Environmental and Social Safeguards Management Plan
28
43 THE GOVERNANCE FRAMEWORK IN GHANA
The Ministry of Food and Agriculture (MOFA) Preparation of Fisheries laws and policies fall under the responsibilities of the Minister of Food and Agriculture who in turn delegates functions including implementation to a semi-autonomous body the Fisheries Commission
The Fisheries Commission (FC) was established under the Fisheries Commission Act (625 2002) It oversees management regulation and utilisation of the fisheries resources of Ghana drawing on powers set out in the Fisheries Law (PNDC 256 1991) Fisheries Act 625 provided for the establishment of a more robust Fisheries Commission (FC) which is an amalgamation of the erstwhile FC and Department of Fisheries
Ten individuals constitute the Board which is led by a chairman (appointed by the President of Ghana in consultation with the Council of State) supported by three members drawn from the ministries of transport defence and environment There are three representatives from the following parastatal organizations - the Ghana Marine Fishing Officers Association Water Research Institute and Ghana Irrigation Development Authority- and two representatives (one from the artisanal and one from the industrial sections )of the National Fisheries Association of Ghana Finally the tenth member is a person with requisite knowledge of the fishing industry or natural resources renewal management
The day to day work of the Fisheries Commission is undertaken by the Department of Fisheries (DOF) which serves as the implementation secretariat of the Fisheries Commission as stipulated by the Fisheries Act 625 of 2002 Specific tasks that are undertaken by the Department of Fisheries include
bull preparing fishery resource management plans bull developing regulations for the fishing industry bull organizing monitoring surveillance and enforcement for the national fishery resources and
ensuring compliance with national fisheries law and institutionalizing co-management concepts
The MCS Division of the DoF (established under the Fisheries Sub sector Capacity Building project) works in conjunction with the Ghana Navy and undertakes sea patrols to exclude industrial fishing vessels from the 30-metre depth IEZ reserved for artisanal fisheries The MCS also conducts inspection of industrial vessels at the fishing ports of Tema and Takoradi for
bull valid fishing licences bull legality of fishing gear bull skipperrsquos certificate bull log book and crew composition
The MCS undertakes similar functions for inland fisheries on Lake Volta
The Ministry of Local Government and Rural Development (MLGRD) is responsible for managing fishers fish processors and fishery resources at district and sub-district levels which it undertakes through the District Assemblies In 2002 the District Assemblies in collaboration with DoF were mandated to facilitate fishery resource management by
bull helping to form and sustain Community Based Fisheries Management Committees (CBFMCs) bull cooperating with the DoF MCS units bull providing legal and financial support to the CBFMCs and bull approving levies proposed by the CBFMCs
29
Community-Based Fisheries Management Committees are charged with the responsibility of enforcing national fisheries laws at community level as well as initiating and enforcing their own by-laws
44 THE LEGAL FRAMEWORK
441 International Conventions
Ghana has ratified a number of international conventions and treaties which have an important bearing on the state of its marine and inland waters and the condition of the fisheries These are listed in Box 1 below
Box 1 International Conventions treaties and agreements to which Ghana is a signatory 1 International Convention for the Prevention of Pollution of the sea by Oil 21 October 1962 2 Convention on the Africa Migratory Locust 25 May 1962 3 Treaty Banning Nuclear Weapon Tests in the Atmosphere in Outer Space and Under Water 5th August 1963 4 International Convention for the Conservation of Atlantic Tunas 4 May 1966 5 Africa Convention on the Conservation of Nature and Natural Resources 15 September 1968 6 International Convention on Civil Liability for Oil Pollution Damage 29 November 1969 7 International Convention Relating to Intervention on the High Seas in Cases of Oil Pollution Causalities 8 Convention on Wetlands of International Importance Especially as Waterfowl Habitats 2 February 1971 9 Treaty and Prohibition of the Emplacement of Nuclear Weapons of Mass Destruction on the Seabed and the Ocean Floor and in the Subsoil Thereof 11 January 1971 10 International Convention on the Establishment of an International Fund for Compensation of Oil Pollution Damage 18th December 1971 11 Convention Concerning the Protection of World Cultural and Natural Heritage 16 November 1972 12 Convention on International Trade on Endangered Species of Wild Fauna and For a 3 March 1973 13 Convention on the Military or Any other Hostile Use of the Environmental Modification Techniques 10 December 1976 14 Convention on the Conservation of Migratory Species of Wild Animals 23 June 1979 15 Convention for the Cooperation in the Protection and Development of the Marine and Coastal Environment of the West and Central African Region1981(Abidjan Convention) 16 United Nation Convention on the Law of the Sea 10 December 1982 17 Montreal Protocol on Substances that Deplete the Ozone Layer 24 July 1989 18 Convention to Combat Drought and Desertification 19 Framework Convention on Climate Change June 1992 20 Convention on Biological Diversity1992 442 Environmental-Related Conventions Environmentally related conventions ratified by Ghana include
bull International Convention for the Prevention of Pollution of the sea by Oil 21 October 1962
bull Convention on the Africa Migratory Locust 25 May 1962 Treaty Banning Nuclear Weapon Tests in the Atmosphere in Outer Space and Under Water 5th August 1963
bull International Convention for the Conservation of Atlantic Tunas 4 May 1966 bull Africa Convention on the Conservation of Nature and Natural Resources 15 September 1968 bull 992256International Convention on Civil Liability for Oil Pollution Damage 29 November
1969 bull International Convention Relating to Intervention on the High Seas in Cases of Oil
30
Pollution Causalities bull Convention on Wetlands of International Importance Especially as Waterfowl Habitats
2 February 1971 bull Treaty and Prohibition of the Emplacement of Nuclear Weapons of Mass Destruction
on the Seabed and the Ocean Floor and in the Subsoil Thereof 11 January 1971 bull International Convention on the Establishment of an International Fund for
Compensation of Oil Pollution Damage 18th December 1971 bull Convention Concerning the Protection of World Cultural and Natural Heritage 16
November 1972 bull Convention on International Trade on Endangered Species of Wild Fauna and For a 3
March 1973 bull Convention on the Military or Any other Hostile Use of the Environmental
Modification Techniques 10 December 1976 bull Convention on the Conservation of Migratory Species of Wild Animals 23 June 1979 bull Convention for the Cooperation in the Protection and Development of the Marine and
Coastal Environment of the West and Central African Region1981(Abidjan Convention)
bull United Nation Convention on the Law of the Sea 10 December 1982 bull Montreal Protocol on Substances that Deplete the Ozone Layer 24 July 1989 bull Convention to Combat Drought and Desertification bull Framework Convention on Climate Change June 1992 bull Convention on Biological Diversity1992
443 National Legislation
The principal national legislation that affects fisheries in Ghana is listed below
1 Fisheries Regulation 1984 LI 1294 2 Fisheries (Amendment) Regulation 1977 3 Maritime Zones (Delimitation) Law 1986 4 PNDC Law 256 of 1991 5 Fisheries Commission Act of 1993 and 6 Fisheries Act 625 of 2002 7 Fisheries Regulations passed in 2010 LI 1968
Other laws that have relevance to the fisheries sector include
1 Wild Animals Preservation Act 1961 (Act 43) 2 Volta River Development Act 1961 (Act 46) 3 Ghana Water and Sewerage Corporation Act 1965 (Act 310) 4 Oil in Navigable Waters Act 1964 (Act 235) 5 Irrigation Development Authority Decree 1977 (SMCD 85) 6 Minerals and Mining Law 1986 (PNDCL 153) 7 Environmental Protection Agency Act 1994 (Act 490) 8 Ghana Highway Authority Act 1997 (Act 540) 9 Timber Resources Management Act 1998 (Act 547) and 10 Minerals and Mining Act 2006 (Act 703
31
434 Policies A number of Environmental related Policies exist in Ghana however there is no specific policy on the coastal zone These include
bull The National Environment Policy bull National Wetlands Policy bull Agricultural Policy bull Tourism Development Policy bull Land Management Policy bull National Health Policy bull Energy Policy bull Minerals Policy bull Wildlife Conservation Policy
The main thrust and orientation of national policies on the protection management and development of the marine and coastal environment focuses on the following three major areas
bull Integrated coastal zone management and sustainable development bull Marine environmental protection both from land-based activities and from sea-based
activities and bull Sustainable use and conservation of marine living resources (both of the high seas and
under national jurisdiction) Specific plans have been developed to ensure the realization of prudent management of the marine and coastal environment These include
bull Coastal Zone Management Indicative Plan 1990 bull National Environmental Action Plan 1994 bull Draft Integrated Coastal Zone Plan 1998 bull Coastal Zone Profile of Ghana 1998 bull National Oil Spill Contingency Plan with specific reference to the marine environment
2002 bull Environmental sensitivity map of the coastal areas of Ghana 1999 and 2004
Despite the existence of these plans active integration and coordination has been lacking in practice at local level 434 Regulations Though several legislations exist on coastal protection and sustainable development there is no omnibus legislation on the environment Legislation relating to the area include the following
bull Beaches Obstruction Ordinance 1897 (Cap 240) bull The Mineral and Mining Law 1986 (PNDC 153) bull Rivers Ordinance 1903 (Cap 226) bull Land Planning and Soil Conservation Ordinance No 32 of 1953 as Amended by the bull Land Planning and Soil Conservation (Amendment) Act 1957 (No 35 of 1957) bull Maritime Zones (Delimitation) Law 1986 (PNDCL 159) urban planning and
32
bull development bull Town and Country Planning Ordinance (Cap 84) bull Wild Animals Preservation Act Act 235 1964 bull The Towns Ordinance (Cap 86) bull National Building Regulations 1996 (LI 1630) bull Volta River Development Act 1961 bull Fisheries Act 2002 Act 625 bull Fisheries Law 1991 (PNDC 256) bull Fisheries (Amended) Regulations 1977 and 1984
The sustainable use and conservation of marine resources is encouraged through legislation regulations education and awareness creation programmes as well as the enforcement of existing regulations and legislation The legal framework for coastal zones issues and management in the country are contained in the following documents
bull The 1992 constitution bull EPA Act 1994 (Act 490) bull Environmental Assessment Regulations 1999 (LI 1652) bull Local Government Act 1993 (Act 462) bull Environmental Standards and Guidelines bull
In addition there are other specific legal frameworks which include a) The legal framework for Ecosystem Protection which are
bull Wild Animals Preservation Act 1961 (Act 43) bull Wildlife Conservation Regulations 1971 (LI685) bull Wild Reserves Regulations 1971 (LI 740) bull The Wetland Management (Ramsar sites) Regulation 1999 bull Oil in Navigable Waters Act 1964 (Act 235)
b) The legal framework for Fisheries Resources which are bull Fisheries Law 1971 (PNDCL 256) bull Fisheries Act 2000
c) The legal framework for Oil and Gas Industry bull Petroleum (Exploration and production) Law 1984 (PNDCL 84) bull Mineral (Offshore) Regulations 1963 (LI 257) bull Mineral (Oil and Gas) Regulations 1963 (LI 256) bull Oil and Mining Regulations 1957 (LI 221)
d) The legal framework for Tourism Promotion (including coastal tourism) bull Ghana investment Promotion Centre Act 1994 (Act 478) bull Companies Code 1963 (Act 179) bull Free Zone Act 1995 (Act 504) bull Ghana Tourism Board bull Ghana Commission on Culture
44 ACTIVITIES RELATING TO FISHERIES INTERESTS
33
Over the years several activities have been undertaken which are of relevance to protection of the marine environment and fisheries These include
bull Ghana Environmental Resource Management Project in Coastal Wetlands Management Component
bull Gulf of Guinea Large Marine Ecosystem Project bull Fisheries Sub-sector Capacity Building Project bull Establishment of a Protected Wetland Ecosystem on the coast bull Development and Implementation of Oil Spill Contingency Plan bull Monitoring of fish stock levels and associated oceanographic parameters bull Institution of a programme of Monitoring Compliance and Surveillance of the marine
environment bull Development of industrial pollution standards bull Development of University course on Coastal Zone Management bull Increased public education on sound coastal and marine environmental practices
45 RELEVANT INSTITUTIONS With regards to protection management and development of the marine and coastal environment a number of ministries and agencies have been identified as potential stakeholders Those shown with an asterisk are likely to have a particularly active role
bull Ministry of Environment and Science bull The Environmental Protection Agency bull Ministry of Tourism bull Ministry of Local Government and Rural Development bull Ministry of Ports bull District Assemblies bull Ghana Ports and Harbours Authority bull Hydrological Services Department bull Ministry of Food and Agriculture bull Ghana Tourist Board bull Ghana Investment Promotion Centre bull Fisheries Commission Ministry of trade Industries and PSI bull Ministry of Lands and Natural Resources Forestry and Mines bull Ministry of Energy bull Ministry of Health bull Ministry of Education Youth and Sports bull Ministry of Defence bull Ghana Navy bull Ministry of Works and Housing bull Ministry of Women and Childrenrsquos Affairs bull Ministry of Roads and Transport bull National Development Planning Commission bull Council for Scientific and Industrial Research bull Universities and Research Institutions bull Ghana Meteorological Agency bull Town and Country Planning Department bull Water Resources Commission
34
bull Ghana National Petroleum Corporation bull Volta River Authority bull Geological Survey Department bull Forestry Commission (Forestry and Wildlife Division) bull Traditional Rulers and their analogous ministry and laws
Non-Governmental Organisations including Resource Development amp Environmental Oriented Development Organisation
bull Friends of the Earth bull Green Earth bull Wildlife Society bull Recerca e Cooperazione bull Centre for African Wetlands bull And many others
46 PARTNERSHIPS Few formal partnerships exist However support for coastal conservation activities has been received from the private sector as well as from Government Regional and sub-regional collaboration efforts occur at various levels although the level of practical intervention is sometimes limited The science and technology unit of ECOWAS is engaged on issues relating to the management of the Gulf of Guinea In addition a bilateral arrangement exists between Ghana and Cote drsquoIvoire for the management of and datasharing on Sardinella stocks which migrate between the two countries The NEPAD framework among the coastal states of Africa is also developing an interest in marine and coastal management 461 Technical and financial support Ghana receives technical support in the form of training research and project implementation from national bilateral and multi-lateral sources Financing of activities in the sector is primarily supported from the national budget However donor support from both bilateral and multilateral sources has also been obtained for specific programmes such as the World Bank sponsored Fisheries Sub-sector Capacity Building Project UNOPS sponsored Environmental Sensitivity Map for Coastal Areas The Ghana Coastal Wetland Project of the World Bank UNEPrsquos WACAF Programmes and The Darwin Marine Biodiversity of West Africa Project by DFID implemented by the University of Ghana 47 ACTIVITIES Activities undertaken in the country with importance to the marine and coastal area are outlined in the following sections 471 Environment-related activities
bull Ecological Baseline studies of Korle Lagoon (1990-2000) This was carried out to satisfy EIA requirement and as a result pollution status of the lagoon was established
bull Lower Volta Mangrove Project (1996-1998) The objective is to ensure sustainable management of mangrove stands and as such baseline information was documented
bull Save the Seashore Birds Project (1985-1995) This was to protect the seashore birds and as a result conservation awareness of seashore birds was achieved
bull Ghana coastal wetlands management project (1996-1999) In this management of the five coastal wetlands designated as Ramsar Site was put in place
bull Darwin Marine Biodiversity of West Africa Project It is a training project in marine biodiversity assessment
35
472 Social-related activities bull A considerable amount of attention is currently being given to the potential impact of oil-related
development in coastal regions following the publication of Environmental and Social Impact Assessments and Management Plans relating to the Jubilee Oil Field discoveries
473 Coastal area management bull Climate and vulnerability and adaptation assessment on water resources agriculture and the
coastal zone Projects (1997-1999) The projects assessed the vulnerability of the coastal zone to climate change
bull Coastal area management plan for Princess Town (1998-2000) which aimed at providing a plan for the management of Princess Town
bull Keta Sea Defence Project Work (2000-2004) The project aimed at protecting the Keta and its environs from the episodes of erosion faced in the area and also to ensure improvement in environmental and socio-economic conditions at Keta and its immediate surroundings
474 Regional Programmes bull Gulf of Guinea Large Marine Ecosystems Project (1996-1999) The project developed an
effective approach to prevent and control pollution in the Gulf of Guinea and conserve its biodiversity As a result regional institutional capacities were strengthened and also a coastal zone management profile and plans produced
bull UNEP WACAF Projects 1 amp 2 This aims at institutionalising and coordination of national contingency plans monitoring of pollution in the marine environment and control of coastal erosion
475 Other major programmes Other recent programmes and activities in the marine and coastal environments have included
bull Ghana Environmental Resources Management Project in Coastal Wetlands bull Fisheries sub-sector Capacity Building Project bull Establishment of a Protected Wetland Ecosystem on the coast bull Development and Implementation of Oil Spill Contingency Plan bull
48 ONGOING PROJECTS Ghana is currently implementing several projects in the marine and coastal area Some of these projects are linked to developmental projects for which impact assessments are required under the Environmental Assessment Regulations of 1999 Some of the projects are large scale in nature with extensive baseline and monitoring studies like the Keta Sea Defence Project and the West Africa Gas Pipeline project Others are projects being implemented under the auspices of the United Nations agencies and non-governmental organisations include
bull Combating Living Resource Depletion and Coastal Area Degradation in the Guinea Current LME through Ecosystem-based Regional Actions
bull Amansuri Conservation and Integrated Development Project (ACID) bull Danida Water and Sanitation Sector Programme II Support to Integrated Water Resources
Management (IWRM) Component (2004-2008)The Densu Basin aspect of the IWRM component
bull Reduction of Environmental Impact from coastal tourism
bull Bui Hydro Power Project
bull Sea Defence Project at Atorkor
bull Sea Defence Projects in selected towns in the Western Region of Ghana
36
49 CONCLUDING REMARKS
This chapter has highlighted the wide range of conventions laws policies regulations and activities affecting the inland and coastal regions and inland freshwater and marine environment of Ghana It will be important to keep all of these processes and procedures under review as the Fisheries and Aquaculture Sector Development Plan is taken forward to the implementation stage
The main responsibility for ensuring delivery of the Fisheries and Aquaculture Sector Development Programme will rest with the Fisheries Department of the Ministry of Food and Agriculture and the Fisheries Commission supported by the MCS Division and Ghana Navy However a key part of the programme is the development of local co-management arrangements and the Ministry of Local Government and Rural Development and individual District Assemblies will play a key role in helping to form and sustain Community Based Fisheries Management Committees
Over time a significant number of fishermen and individual fish processors are likely to leave the sector as harvesting landing and processing of the catch becomes more efficient Management of these changes especially where disadvantaged and vulnerable sections of the community are affected will need substantial support and investment and a high degree of coordination amongst government ministries and agencies NGOs and international partners to ensure that development assistance is effectively targeted
37
CHAPTER 5 WORLD BANK SAFEGUARD ISSUES
51 INTRODUCTION
The World Bankrsquos proposed funding support to the Government of Ghana covers an initial five yearsrsquo period which could potentially be extended at a later date As the Government of the Republic of Ghana notes in the draft FASDP ldquoimproving the management of the countryrsquos fisheries and ensuring that the impacts on individuals and communities are properly addressed will take 20 or more years to effectrdquo It has therefore been judged important in this report to distinguish between changes that might occur as a direct result of the World Bankrsquos financial assistance thereby triggering the Bankrsquos environmental and social safeguards and changes that could result from longer term adjustments to fisheries and other sectors of Ghanarsquos economy as a result of wider influences by Government other donors and world-wide factors (for example international progress in world trade agreements)
The aim in this chapter is to identify changes which are likely to fall within the purview of the World Banks reputational risks and responsibilities under the first five years of the Fisheries and Aquaculture Sector Development Plan (FASDP) It should be clearly understood that the views expressed are those of the consultancy team and it will be for the World Bankrsquos internal advisors to decide what formal recommendations are made to the World Bank Board
Trends that may emerge in later stages of the implementation of FASDP ndash subsequent to the initial five year period - are discussed in chapter 6
52 THE CURRENT SITUATION
The general status of Ghanarsquos fisheries has been described in Chapters 3 while the legal and policy context has been set out in Chapter 4 The World Bankrsquos investment is being planned specifically to support government policy with the aim of providing a more efficient and better regulated fisheries sector Currently open access is leading to progressive deterioration in fish stocks and lower economic returns Based on many international examples of successful intervention the current proposals (see Chapter 2) are to provide support to introduce formal licensing of all vessels and proper monitoring and control over the seasonal timing and location of fishing activity use of gear and approved nets and self regulation through co-management structures under which the Government and fishing communities will work together to achieve recovery of fish stocks higher income levels for fishers and better returns on catches by reducing post harvest losses and improving processing and marketing operations
53 ANTICIPATED OUTCOMES
It is expected that the proposed reforms and changes will eventually lead to significant improvement in the marine environment restoration of fisheries and enhanced incomes In this respect the provision of grants and loans from the World Bank will bring about major benefits to the economy livelihoods and the environment in the longer term The question that has to be addressed however is - are there likely to be any short term adverse environmental or social consequences from the Bankrsquos own investment strategy Answers are considered in relation to each of the planned components sub-components and activities which are summarised in Table 51 A colour coding and numbering system has been adopted to distinguish those activities that are seen as particularly relevant from the standpoint of the environmental and social assessment Elements highlighted in green are those likely to have positive and beneficial effects on the environment and social conditions those highlighted in orange red have potentially negative or adverse consequences if not handled properly
38
Component 1 Good Governance and Sustainable Management of the Fisheries
Sub-Component 11 seeks to develop the capacity rules procedures and practices that will lead to better governance As such these procedural interventions will have no direct effect on the environment or social conditions of fishing communities However it will be important to ensure that the drafting agencies (government departments and consultants) give due attention to environmental and social objectives during this phase of work Three specific areas are highlighted including undertaking a socio-economic impact assessment with mitigation measures as part of the plan for fishing capacity reduction reviewing the economic and social implications of subsidies and fish import tariffs in the fisheries sector and developing the policy for the development and operation of community-based management networks built around defined fisheries management units
In developing regulations and guidelines it will be important to consider how less able individuals and vulnerable sectors are going to adapt to new systems For example the new regulations on licensing canoes including completion of registration forms the display of registration numbers on vessels and demonstration of basic competence in health and safety standards may prove taxing demands for owners and crew lacking any formal education Similarly legal instruments that are used to remove fuel subsidies or other benefits will need to be carefully explained A socio-economic impact assessment is proposed in the draft PAD to be accompanied by appropriate mitigation measures This assessment should consider amongst other things
bull whether support should be offered and if so under what conditions to any company community or individual who fails to secure a license for a particular class of vessel
bull how the transfer or sale of licenses will be regulated in the wider public interest to ensure transparent processes and avoid the creation of monopolistic and oligopolistic elites
bull who wins and who loses from any planned changes to subsidies and fish import tariff adjustments
bull how the performance of community-based management networks will be judged bull what action will be taken to mitigate the loss of any traditional fishing grounds that become the
subject of marine protected area development or are subject to exclusion zones to protect oil drilling and production platforms
Sub-Component 12 introduces the concept of fishing rights This is to be initiated through a series of four pilot stakeholder-based fishery initiatives and the rolling out of licensing procedures Discussions with stakeholders have made it very clear that the credibility of the entire fisheries policy and programme could be challenged if these pilots do not show positive and constructive ways of moving forward with fisheries reform There is a great deal of distrust for new procedures amongst the fishing communities based on the knowledge that many previous initiatives have failed It is therefore essential that the pilots are led by a strong implementation team are adequately financed and include a credible transparent and inclusive process for debate discussion and consultation Co-operation from the selected communities will be more likely to be achieved if they can see early results in terms of income generating activities
Sub-Component 13 is targeted at adjusting fishing effort and capacity to more sustainable levels and supporting alternative livelihood opportunities These activities are critical in giving effect to the policy decisions that have already been taken to reduce the size of the industrial and semi-industrial fishing fleet and to strengthen the role of the canoe sector Specific measures are proposed for compensating crew members who lose their jobs and for providing training to young men who are willing to transfer
39
out of the fishing sector The scale of this task should not be under-estimated however since there are currently few alternative employment opportunities in the coastal belt for manual workers with low education and skill levels which typify the status of many young fishermen The concept of creating some additional employment with conservation of the coastal littoral and marine ecosystems is strongly supported since this can be linked with development of tourism
Sub-Component 14 is another element that is strongly focused on delivering improved livelihoods with its emphasis on social marketing communication and transparency The focus on stakeholder participation is particularly welcome and should lead to positive response providing it is backed with direct financial support to participating communities
Component 2 - Reduction of Illegal Fishing
There is no Sub-Component 21 within the Ghana Fisheries Programme
Sub-Component 22 aims to develop monitoring control and surveillance (MCS) systems These measures are largely procedural and apart from the relatively small team that will be recruited to operationalise the systems it will have minimal effects on either the environment or social conditions One element that is highlighted in Table 51 relates to provision of facilities and training for participatory coastal surveillance of small-scale fisheries This should have direct and strongly positive benefits for participants and the communities who are enrolled in the training programmes
Component 3 increasing the contribution of the marine fish resources to the local economies
Sub-Component 31 will support the development of basic infrastructure at nine marine fish landing sites and two inland sites The scale of physical construction will be restricted to repair and minor extension of roads and jetties wharves and construction of net mending screens and storage sheds These activities are unlikely to have any significant adverse environmental impacts and should lead to positive social effects
Sub-Component 32 will underpin efforts to improve fish product trade infrastructure information and systems Introduction of new technology for smoking and curing fish and the extension of existing ice preparation plants will start to have positive beneficial effects within the selected communities
Sub-Component 33 provides a modest level of support to marine and inland aquaculture development Aquaculture development should include finalization establishment and enforcement of current draft operational standards to cater for environmental friendliness of fish culture industry for its own survival The main focus will be on developing policy and legal frameworks together with support for stock improvement These measures will have some impact on affected communities in the short term but are clearly aimed at longer term benefits
40
Component 4 Coordination Monitoring and Evaluation and Program Management
Sub-Components 41 and 42 are directed specifically at strengthening the capacity of the Governmentrsquos institutions for national implementation and regional co-ordination As such they will have no direct environmental or social impacts
54 SUMMARY AND CONCLUSIONS
This review of potential environmental and social safeguard issues under the World Bankrsquos targeted programme concludes that there are unlikely to be any significant adverse environmental or social effects as a result of the planned investments
The only possible exception relates to the effectiveness of measures that are put in place under Sub-Component 12 to support pilot stakeholder-based fishery initiatives It is of paramount importance that these pilots are successful and win the confidence of all participants since failure to achieve positive results could set back the entire fisheries programme For this reason it is essential that planning of the pilot initiatives is linked closely with measures for supporting alternative livelihoods and strengthening processing and marketing initiatives under Sub-Components 13 and 14
A number of the planned interventions may have longer term consequences as policies regulations and bye-laws are put into effect but these will be addressed in subsequent work by the Government of Ghana (see Chapter 6)
Table 51 Elements of the World Bank Programme and assessment of potential environmental and social risks
Description of Component Sub-Component and Activities
Measure of Likely Effects
Large (3)
Moderate (2)
Small (1)
None
Beneficial
3
2
1
Adverse
3
2
1
Component 1 Good Governance amp Sustainable Management of the Fisheries
Sub-Component 11 Developing the Capacity Rules Procedures amp Practices for Good Governance of the Fisheries
Reviewing developing programmes and projects designed to support the Fisheries and Aquaculture Development Sector Plan (FASDEP)
Developing an operational policy to enable implementation of the Aquaculture and Fisheries
Plan for fishing capacity reduction (including socio-economic impact assessment and mitigation) 3 2
Commercial vessel and fishing activity licensing plan including allocation criteria rules for transfer of licenses
41
Sector Development Plan and timetable and schedule of license fees
Compliance strategy and plan
Regulations for the management of fisheries including the identification and specification of fisheries management units (ie stocks species areas)
Recommendations for environmental and social safeguards arising from the review of the economic and social implications of subsidies and fish import tariffs in the fisheries sector
3
Policy for the development and operation of community-based management networks built around defined fisheries management units
3
Policy on adaptation strategies for climate change and marine protected area development
2 2
Review of the Ghana Tuna Industry to identify policy or infrastructure needs that threaten Ghanarsquos hub status
Strengthening capture fisheries management systems and capability
Development of fisheries and aquaculture management systems and processes and training
Strengthening fisheries information systems
Installation and operation of fisheries lsquodashboardrsquo database and information collection
Sub-Component 12 Introducing Fishing Rights ($15 M GEF)
Developing 4 pilot Stakeholder-Based Fisheries Management initiatives around defined fisheries units (ie local management initiatives tied to defined fisheries resources including demand-side governance initiatives)
3 2
Introducing and administering a licensing regime (registry establishment training stakeholder education) 2 2
Sub-Component 13 Adjusting Fishing Effort and Capacity to more Sustainable Levels and Supporting Alternative Livelihood Opportunities where Needed
Vessel decommissioning Decommissioning of 60 to 80 industrial trawlers in an environmentally friendly manner
2
Developing alternative livelihoods for crew of decommissioned industrialsemi-industrial
Skills training and small business development training and support for young (18-30 yrs) industrialsemi-industrial crew members willing to transition out of the sector
3
42
vessels
Alternative livelihood development to incentivize voluntary capacity reduction in canoe sector
Alternative livelihoods fund and CDD support to targeted fishing communities
3 2
Marine Resource Conservation
Would include confirming conservation priorities and management regimes and possible provision of support for alternative livelihood options (funded under 133) associated with conservation of coastal littoral and marine ecosystems as well as de facto protected areas associated with the development of oil and gas extraction
3
Sub-Component 14 Social Marketing Communication and Transparency)
Communications stakeholder consultations and awareness raising programs to support fisheries development
3
Component 2 Reduction of Illegal Fishing
Sub-Component 21 does not apply to Ghana
Sub-Component 22 Monitoring Control and Surveillance (MCS) Systems
Developing compliance systems and capability
Development of judicial and policy capacity (training)
Compliance risk assessmentstrategy systems and process development
Enforcement Unit establishment (dedicated facility)
Coastal surveillance stations 2
Facilities and training for participatory coastal surveillance of small-scale fisheries
3
Training for surveillance officers
Operation of aerial and water patrols (vessel leases aerial patrols operational costs patrol vehicles)
Observer program
Compliance education (stakeholder training signage) 1
Upgrademaintenance of the Vessel Monitoring System (VMS)
43
Component 3 Increasing the Contribution of the Marine Fish Resources to the Local Economies
Sub-Component 31 Fish Landing Site Clusters
Product diversificationvalue chain development
9 marine landing sites (basic infrastructure) at Axim Dixcove Fete Jamestown Moree Mumford Senya-Beraku Teshi and Winneba
3 1
2 inland fish landing sites (improved access and berthing infrastructure) at Abotoase and Dzemeni
3 1
2 ports developed (technical studies for 1 new port at Axim and additional berthing space in existing port of Elmina)
3 2
Sub-Component 32 Fish Product Trade Infrastructure Information and Systems
Export certification center development
Fish processing technology improvements 1 1
Technical assistance training and goods to support the National Fisheries Advisory Group
Sub-Component 33 Marine and Inland Aquaculture Development
Developing aquaculture policy and legal framework
Improving genetic quality of Tilapia fingerlings and breedstock
Catalyzing aquaculture development 2
Component 4 Coordination Monitoring and Evaluation and Program Management
Sub-Component 41 National Implementation
Technical assistance for Secretariat to the Fisheries Commission to implement the Project
Sub-Component 42 Regional Coordination
Technical assistance for Regional Coordination Unit at the CSRP support to Fisheries Information Systems (lsquoDashboardrsquo)
45
CHAPTER 6 ENVIRONMENTAL AND SOCIAL ASSESSMENT OF DRAFT FISHERIES AND AQUACULTURE SECTOR DEVELOPMENT PLAN (FASDP)
61 INTRODUCTION
This chapter examines environmental and social issues which need to be considered as part of the overall structural and economic adjustments in Ghanarsquos fisheries sector in the longer term (ie 1-15 years) The assessment deliberately focuses on the longer term because it will take a number of years before current plans start to have their full effect However the same temporal considerations apply to measures that are designed to avoid or mitigate potentially harmful effects so it will be important to start planning remedial actions as part of the joint Government of Ghana and World Bank fisheries programme
611 Key sectors and activities The fishing industry is divided first into marine capture and inland capture fisheries and then aquaculture For each of these three sectors activities are then broken down as follows Marine Capture Fisheries CATEGORY ACTIVITY Stock Management Research Surveillance reef building Harvesting Vessels Gear Skills capacity Marketing Sellers Buyers Processing Fresh fish Sun dried Smoking Freezing Consumers By market sector Support Sectors Boat Canoe Building fuel supply net making kiln construction
refrigeration transport cold store management Legal Enforcement Financing Investment in all elements Infrastructure Harbour wharf processing plant construction
Inland Capture Fisheries CATEGORY ACTIVITY Stock Management Research Surveillance Harvesting Vessels Gear Skills capacity Marketing Sellers Buyers Processing Fresh fish Sun dried Smoking Freezing Support Sectors Boat Canoe Building fuel supply net making kiln construction
refrigeration transport cold store management Legal Enforcement Financing Investment in all elements Infrastructure Harbour wharf processing plant construction
46
Aquaculture and Mariculture CATEGORY ACTIVITY Stock Management Research Surveillance Rearing Roe fingerling production cage -pond rearing Harvesting Vessels Gear Skills capacity Marketing Sellers Buyers Processing Fresh fish Sun dried Smoking Freezing Support Sectors Boat Canoe Building fuel supply cage construction kiln construction
refrigeration transport cold store management Legal Enforcement Financing Investment in all elements Infrastructure Harbour wharf processing plant construction
612 Evaluation Criteria The environmental and social assessment has been undertaken using a matrix (See Annex 114) which analyses the key sectors and activities of the fishing industry and the changes that are envisaged against a set of evaluation criteria Evaluation Criteria are broken down into environmental and social issues distinguishing between beneficial and adverse effects Table 61 below shows the relationship between the groups of criteria Table 61 List of Evaluation Criteria
Environment Social
Positive Adverse Positive Adverse
bull Sea bed rejuvenated
bull Fish stocks recovered
bull Biodiversity enhanced
bull Sea bed degraded
bull Fish stocks reduced
bull Biodiversity reduced
bull Increased harvest (catch volume)
bull Increased catch value
bull Reduced costs of inputs
bull Increased profit
bull Enhanced livelihoods
bull Increased job opportunities
bull Increased local economic multiplier
bull Reduced harvest (catch volume)
bull Reduced catch value
bull Increased costs of inputs
bull Reduced profit
bull Reduced livelihoods
bull Reduced job opportunities
bull Reduced local economic multiplier
The assessment process has involved systematically considering each sectoractivity against the evaluation criteria and recording either positive or negative results by drawing on the judgement of the consultancy specialists The findings are discussed in the paragraphs that follow and are reflected in Table 81 forming part of the Draft Environmental and Social Management Plan
62 DETAILED ASSESSMENT OF THE MARINE AND AQUACULTURE SECTORS
47
TunaIndustrial fleet streamlined and catch per vessel improved At present industrial trawlers have to travel increasing distances to fishing grounds and while the level of catch is remaining broadly static costs are increasing against available economic returns A major shortcoming is lack of investment in re-equipping the aging fishing fleet Many of the 90 vessels that make up this sector are increasingly unseaworthy and need to be replaced with modern trawlers and gear The plan is to buy out owners of substandard vessels by offering compensation at market value based on a full commercial survey Vessels remaining in the fleet will be required to meet exacting standards By reducing the number of old and inefficient boats this will allow each of the remaining vessels to catch a higher proportion of fish The aim is to ensure that Ghana is equipped with the latest vessels and technology in order to preserve the countryrsquos position as the hub of the West African tuna fishing and processing industry (see also the section on canneries below) The effect of these measures on the environment will remain broadly neutral since the same number of fish will be caught Providing other policies and increased surveillance are successful in preventing trawling in inland waters the smaller fleet will have to fish in deep oceanic waters This could potentially transfer some environmental effects on fish populations to other parts of the migratory cycle However this would become part of the international effort through fishing quotas to regulate overall catches Reduction in the size of the industrial fleet will mean that fewer men are needed to crew and service the vessels However in practice many men who work in this sector have only part time work and since a significant percentage of boats no longer put to sea the number of crewmen who will be displaced could be in the range of 1000-30003
It will be important to set up support services for those losing their jobs including retraining and welfare assistance where necessary
Decommissioning will necessitate the sale of seaworthy vessels and their removal from Ghanaian waters Other boats will need to be broken up and scrapped This process requires heavy duty specialized equipment and can release significant quantities of waste oil other toxic chemicals including refrigerants and asbestos used in pipe and engine room cladding Measures will need to be taken to ensure that proper environmental and health safety precautions are taken that decommissioning takes place in properly equipped boatyards and that all waste products are disposed of without environmental risk Cannery sector optimized The Fisheries and Aquaculture Sector Development Plan seeks to maintain the port of Tema as the centre of the Tuna canning industry in Ghana At present a proportion of Ghanarsquos tuna catch is diverted to neighbouring countries due to constraints on processing capacity These limitations include poor port infrastructure ageing equipment and delays in handling catch for some operators due to preferential treatment of vessels that are part-owned by the existing canneries Options for improvement include encouraging upgrading of the capacity of one or more existing canneries or promoting more competition in the processing sector and improving the infrastructure Providing modern building designs and construction techniques are employed and a full environmental assessment is undertaken in accordance with Ghanarsquos EIA regulations there should be no significant environmental or social risks associated with these development possibilities The potential economic benefit resulting from encouraging investment in this sector is very high
Industrial fishing excluded from inshore waters A major longer-term intention under the new fisheries plan (FASDP) is to ensure that existing regulations that restrict industrial and semi-industrial vessels from trawling in inshore waters are properly enforced This requires provision of surveillance
3 Based on an average crew of 20
48
equipment fast patrol vessels capacity building and training and increased staffing within Government agencies together with a full programme of awareness raising training and financial support to local bodies providing self-governance under new co-management services Restriction of industrial trawling in coastal waters will greatly ease pressures on fish stocks and reduce environmental damage to the sea bed In time this should lead to healthier fish population with more fish to be caught by the canoe industry as a result However the task of policing and enforcing regulations will not be easy and will take a number of years to bring into full effect Reduction in fishing activity by inshore trawlers will displace a number of crew members and have a short-term impact on dependent families until these individuals are either absorbed into the canoe fleet or find alternative employment There will therefore be a need to assist genuinely deserving cases where crew members (and their families dependents) need to transfer to other sectors of the economy These measures will only be required in the short term since the anticipated improvement in fish stocks will lead to improved economic performance in the canoe sector within which the bulk of employment exists
Expansion of deep water fisheries The fisheries plan notes that there may be a potential for exploitation or increased exploitation of some deep sea fish resources However the status and population dynamics of some affected species is not well known so any such activities should be scientifically monitored through research and enforced by MCS
Tema Secondi Port infrastructure improvements (equipmentbuildings) Under present conditions the transfer of fish from commercial and industrial vessels to canneries is often delayed by the time taken to offload crates and manouvre within the port area where there are conflicting activities There are also difficulties that arise when vessels owned by the canneries are given priority for landing leaving other boats waiting for many hours which can result in quality deterioration At this stage no details are available about the precise improvements that could be introduced and this will need to be investigated as the fisheries plan is advanced Any environmental effects from infrastructure improvements would be contained within the existing port areas and should be largely positive in reducing fuel (energy) costs and increasing overall efficiency It will however be important to carry out an environmental review of specific development proposals at the design stage especially if these involve plans for any dredging or for altering facilities for discharging waste and disposing of bilge water Both of these activities can have damaging effects on the sea bed (The first through dispersal of silt and sediment and the second through release of potential contaminants) Socio-economic effects from the infrastructure improvements should also be beneficial by removing delays increasing efficiency and reducing waste However there could be some slight reduction in manpower requirements leading to the need for skills retraining Regulating the catch (eg Fishing for selected species reducing juvenile catch to improve value of catch in inshore waters) The fundamental aim of the fisheries plan is to reduce the harmful effects on fish stocks and low economic returns from fish catches by phasing out open access for all and introducing regulation of fishing activity This is to be achieved through close cooperation between the Fisheries Commission Monitoring and Surveillance Unit as well as marine fisheries management division and individual fishing communities working together under a co-management framework The practical details will need to be worked out through each individual co-management group and initially the World Bank is offering to assist in the establishment of four pilots These bodies will test exactly what is required to increase fishersrsquo awareness to build capacity in self regulation and agree on appropriate measures
49
From discussion with stakeholders it is clear that while the broad principles are accepted the majority of the fishing community simply do not believe that the new regulations will be enforced because they have witnessed the failure of so many previous efforts to introduce firm management A major issue for the planned programme is therefore how to change this critical mindset without which very little progress is likely to be made in practice It will be necessary to demonstrate through the pilots that by regulating fishing activity direct benefits will accrue to those participating fishing communities Unfortunately efforts to eliminate harmful practices are unlikely to result in an immediate gain in fish stocks Instead catches are likely to fall in the short term It will therefore be essential to introduce other forms of incentive to cushion short term losses Such measures might include the purchase of new nets and gear for sale at subsidized price to local cooperatives the introduction of cash incentives for canoes demonstrating best practice in the use of gear and nets preservation of the catch using ice and landing and marketing fish of the required size and quality As restriction of open access starts to take effect there should be positive environmental gains in terms of improving fish stocks and less damage of the sea bed On the other hand both fishers and fish processors will feel the adverse temporary effect of reduced catches These social and local economic impacts will need to be monitored closely and assistance provided to help foster alternative livelihoods Cephalopus (Octopus) harvesting encouraged in inshore waters Although most fish species are currently exploited to unacceptably high levels within coastal waters there is a specific opportunity to increase the number of octopus caught by pot fishing This fishery could be developed by both the semi-industrial and canoe sectors Taking octopus in pots would have no adverse physical impacts on the sea bed and could allow very slight expansion in fish species that are preyed on by octopus At the same time it is important to note that there is only limited information on species composition and functioning of selected marine habitats including those of the octopus and more research should be undertaken on this and other species that could be selected for expanded fishing activity There would be clear socio-economic benefits arising from the creation of this new fishery Focusing fish landing at specific landing sites (to improve opportunities for subsequent marketing processing) Plans are already being developed for the enhancement of landing and processing facilities at a number of existing locations along the coast These locations include the construction of harbours at Jamestown and Elmina and development of landing sites at Teshie Ada Axim Dixcove Winneba Mumford SenyaBeraku Gomoa Fetteh Moree Keta Dzemeni and Tapa Abotoase Two sets of issues need to be considered in relation to these improvements all of which affect existing fish landing and processing sites The first is the nature of the physical works and infrastructure and it s potential effect on the marine and terrestrial environment The second is the socio-economic impact Both Elmina and Jamestown are long established fishing ports where the catch is landed either directly onto the beach or shallow wharves It is understood that the primary aim of the improvements will be to increase the area of permanent wharves to make it easier for fish to be offloaded to reduce the time taken in transferring stock to processing plants and to introduce modern technology In the case of other smaller landing sites the scale of improvements will be quite modest involving improvement to existing short stretches of access road the erection of stores for nets and other gear and provision of covered areas to provide shade for net-mending With all proposals for physical infrastructure development there will be a need to consider possible
50
environmental implications Due to the existing nature of these sites there are no major industrial or other commercial processes in the vicinity which could give rise to cumulative impacts including contamination of fish products The scale of plant needed for ice-making and storage and commercial smokeries is commensurate with the artisanal nature of the fishing activity itself and would not give rise to any significant environmental effects on air or water quality Harbour works could potentially involve some small scale dredging (for example the removal of accumulated silt) Where dredging is required it will be important to identify disposal areas (either at sea or on land) where silt can be deposited without damage to sensitive habitats In terms of economic and social impacts it is not clear at this stage who are likely to be the major investors from the private sector although it may be assumed that existing operators who have access to finance will be the main beneficiaries Over time as landing marketing and processing become more efficient it is possible that individuals in the traditional fish smoking sector will lose a significant proportion of their trade as the product switches to fresh or frozen fish sales for transfer to the major urban markets and the beach price for fish rises The draft Ghana fisheries and aquaculture sector development Plan notes in annex 2 that proposed facilities associated with the ports and landing sites may not have support from fish mammies or at least formidable commercial advocates able to resist any opposition from that quarter Inspection of major fish landing areas like Elmina and Sekondi indicates that the existing social and commercial structure of support activities to fish harvesting is very complex and involves almost every member of the community including children and the elderly Such activities include net mending boatbuilding metalworking (for cooking pots stoves and grills supplies (ropes weights tar paint wood) fuel supplies ice crates transport etc Leaders of the fishing community confirmed that in principle the improvements of facilities is welcomed provided that safeguards are in place for those who may lose part or all of their current trading activity through rationalisation Stabilise fleet capacity at a sustainable level Fishery experts consider that there would be significant benefits in reducing the number of canoes from the present 10000-12000 to around 8000-9000 which correlates with the number operating in the mid 1990rsquos when catches were at optimum levels At the same time the Fisheries and Aquaculture Plan stresses that the canoe sector will remain at the heart of the Ghana fishing industry and this has strong political enforcement Consequently there is unlikely to be any enforced reduction in the number of canoes holding licenses and owners of all existing canoes will be able to register their vessels The ability of canoe owners to pay annual licence fees should rise as the overall measures to increase efficiency and improve catches take effect However many people anticipate that over time as the annual cost of holding licenses rises less efficient fishers will sell their licenses (and hence their rights to fish) There may therefore be a de facto reduction in the size of the canoe fleet Even if numbers do not decrease the fleet could be stabilized at its present size by taking a decision not to grant new licences The draft plan discusses the fact that under existing law (section 53) there is a requirement for licenses to be issued on demand (presumably to ensure that Ghanaians are not barred from subsistence fishing) It is argued in the plan that this is a misconception since canoe fishing is largely a commercial activity and it is concluded that lsquoit is therefore essential that the number of canoe licenses can be controlled in future and the legal basis for these controls must be reviewed as a matter of priorityrsquo Decisions of this nature will require the full support of local co-management groups if they are to be effective but committees could easily come under pressure to make exceptions as the coastal population continues to rise and families without alternative livelihoods start lobbying for assistance
51
Accusations of preferential treatment of certain individuals by committees (or committee officials) - possibly linked with suggestions of bribery and corruption -could cause a lot of social tension and start to undermine community trust in the need to work together to improve fisheries management It is therefore most important that the detailed proposals for co-management address this risk and include proposals for mitigating individual hardship of the less advantaged ndash for example by offering voluntary retirement with some form of incentive Influencing marketing to maximise value and reduce post harvest losses (marketing cooperatives strong market structures etc) FAO has estimated that physical post harvest losses in Ghana amount to between 3 and 17 of smoked fish production and 16-20 of gillnet landings The plan notes that introduction of lsquonew generationrsquo small scale fish smokers should be introduced to replace the traditional Chorkor model This would improve fish product quality by eliminating charring of fish over open flames and also protecting operatorsrsquo eyes from the damaging effect of smoke and particles The other major improvement in post harvest value and profits would arise from greater use of ice throughout the supply chain Developing Aquaculture A distinction needs to be made between aquaculture development in ponds and dugouts which are self-contained and fish rearing in cages within open water In the case of farm ponds the commercial rearing of fish is little different to other forms of intensive livestock rearing Providing there is no direct connection to rivers and streams there is little likelihood of interaction between farmed and wild stocks which could spread fish infections and parasites In the case of fish farms in open water (rivers and lakes) there are well known risks of the spread of disease which can arise if overstocking occurs Intensive feeding of large numbers of fish in a confined area can lead to significant deterioration in water quality through the build up of nutrients from wood and waste It is also possible for antibiotics and growth hormones to be dispersed beyond the area of farm cages Genetic modification of farmed fish can also affect the local fish population through escapes All of these issues are capable of being managed and mitigated through good initial planning and design and subsequent maintenance and supervision It will therefore be necessary to develop additional regulations and guidelines specifically for the aquaculture sector 63 SUMMARY OF ENVIRONMENTAL RISKS AND OPPORTUNITIES Review of the full range of governance and development activities suggests that there are no high levels of risk to the marine or littoral environment Successful implementation of the Policy and plan should in fact result in very significant environmental gains Over a timespan of 5-20 years five activities in particular should result in significant improvements in the condition of the sea bed in coastal waters (to a depth of 30 metres) reestablishment of benthic flora and niche habitats increased fish stock and enriched biodiversity These interlinked activities are bull The exclusion of industrial vessels and trawling within coastal waters bull Regulation of fish catches through zonation seasonal control of fishing and standards for vessels
gear bull Stabilisation of the fishing fleet within sustainable harvesting yields bull The adoption of management plans formulated and agreed with full cooperation of local
communities bull The introduction of fishing rights through co-management agreements and bull Well planned consultation and information dissemination throughout the fisheries sector
52
Three components of the development plan have been identified where minor to moderate risk to the physical and biological environment could arise if proper design and implementation standards are not adhered to These relate to bull A potential risk of over-exploitation of new catch species in deep water off the continental shelf if
such development is not accompanied by through research to establish the sustainable yield of target species
bull Strictly localized effects on the physical environment from construction of landing wharves or jetties and other harbour facilities and
bull Infrastructure development at the existing ports of Tema and Takoradi All of these risks are capable of being fully managed by improved governance in the fishing sector and EIA procedures that are well-established in Ghana 64 SUMMARY OF SOCIO-ECONOMIC RISKS AND OPPORTUNITIES Implementation of the Plan Project will bring about substantial change in the fisheries sector and over time increased revenue reduction of post[harvest losses and added value to fish products will bring major economic returns At the same time there will be some individuals who do not participate in direct gains and whose livelihoods could be adversely affected if appropriate safeguarding measures are not put in place The level and extent of these socio-economic risks will be determined by 1 the level of commitment that is entered into by Government and its development partners to
deliver incentives to vulnerable and disadvantaged groups and 2 the speed with which the sector is transformed Rapid change could cause significant
displacement of less-efficient operators especially within the semi-industrial and canoe sector which would have serious ramifications for dependent communities However these effects can be marginalized if the development programme is carefully phased to ensure that alternative livelihood and employment incentives are available
The main risks to local livelihoods relate to the potential for bull loss of employment for crews of unseaworthy obsolete vessels ( from all sectors including
industrial semi-industrial and canoes) that are withdrawn from the fishing fleet because they no longer comply with license regulations
bull the inability of vulnerable and disadvantaged groups including artisanal fishers vendors and individual fish processors in small fishing villages to adjust to new market conditions at selected landing sites
53
CHAPTER 7 ASSESSMENT OF POLICY OPTIONS
71 INTRODUCTION
In order to place the significance of the environmental and social safeguards assessment in context this chapter examines the possible consequences of different policy responses to the existing challenges that face the fisheries sector in Ghana These different policy responses range from a continuation of the status ndashquo effectively a ldquodo-nothingrdquo option (A) to full-scale commitment by all stakeholders to achieving a sustainable fisheries future the ldquoOptimum Solutionrdquo option (C) Various less sustainable outcomes lie in between these two ends of a continuum of policy choices and these are represented by the ldquoWeak Solutionrdquo option (B) 72 OPTION A ndash DO NOTHING Background research and discussion with stakeholders indicates that practical capacity to deliver on clearly stated national goals for sustainable fisheries livelihoods and the reduction of poverty is weak This situation exists despite the fact that Ghana has a strong legal framework for management of its fisheries including the Law Policies and Regulations There is inertia and strong resistance on the part of the majority of players to accept that it is largely their own actions which are responsible for present conditions This in turn leads to the attitude that it is only the lsquoGovernmentrsquo that must act by providing increased subsidies and cushioning the industry against further deterioration in catches Unfortunately there is overwhelming evidence from around the world that where fish stocks are exploited beyond their natural capacity to regenerate this can lead to sudden and near-total collapse Ghana has historically been one of the strongest fisheries in West Africa but the signs are ominous that current levels of exploitation are leading to progressive decreases in annual catches for most species in both marine and inland waters As fishing effort intensifies with an increasing number of all types of vessel using illegal methods and inappropriate gear the distinction between the traditional lsquopeak season and lean season (linked to migration patterns breeding cycles and upwelling) is becoming blurred This is clearly illustrated by a statement from one of Elminarsquos fish mammies ldquowe use to smoke the herring in the peak but now the fishers bring them all the yearrdquo Use of monofilament nets light dynamite and chemicals to obtain fish in the lean season is aggravating a situation where too many boats are chasing too few fish Many fishers blame the reduction of catch on global warming for increasing water temperature the emergent oil and gas industry for restricting access to traditional fishing grounds and industry and urban development for increasing pollution leading to deterioration in water quality Each of these assertions warrants careful consideration but the industry is generally in denial when it comes to the primary fact ndash too many fish including juveniles are caught to allow regeneration of the stock In addition weak governance and lack of resources to ensure implementation of policy result in a situation where the law can be ignored with impunity If collective failure to recognize the seriousness of the current position and lack of commitment to taking hard decisions continues the omens for the future are not good Within a period of 10-15 years fish catches could fall by 50 or more from their present level Impacts on each species would vary and catches of some fish with regional or global migration patterns could remain viable (although this depends on the international conservation effort) On the other hand stocks of fish that provide the mainstay of local food resources herring and sardine could be decimated
54
Complete collapse of all fish species is unlikely but it is possible to envisage a situation where catches might fall below 300000 tonnes a year by 2025 (a reduction of more than 25 from present levels) The most serious consequences would be felt as a result of the social and local economic impact on fishing communities Perhaps 30000 men representing the crews of 3000 canoes and semi industrial boats and 15000 women engaged in marketing and processing would lose their present livelihoods Population migration away from the coast could follow and severe social pressures and local economic hardship This is clearly a ldquoworst caserdquo scenario and if conditions were to worsen gradually it might be possible to intervene but the fact has to be accepted that fish stocks are dynamic and subject to rapid decline (as in the case of the North Sea Herring and Atlantic Cod) 73 OPTION B THE lsquoWEAKrsquo SOLUTION The bleak future painted in Option A is unlikely to arise if the present policy and draft fisheries development plan is followed since these are specifically directed to addressing the major challenges However realization of the aims is dependent upon delivery across a wide range of initiatives by multiple stakeholders The following paragraphs illustrate some of the ways in which delivery of policy objectives might be thwarted These may be summarized as
bull Commitment to good governance and institutional reform bull Political resolve to implement unpopular measures bull Availability of adequate technical and financial resources bull Inertia to necessary changes in fishing practice
Good Governance and Institutional Reform Fundamental reforms are required to fully equip the national fisheries management effort at government level This includes introduction of change management clarification of responsibilities for senior staff rationalization of financial management systems provision of equipment expansion of staff numbers additional training and capacity building As an illustration of the extent of the effort required reference can be made to just one topic area the issue of monitoring control and surveillance At present the Fisheries Commissionrsquos MCS Unit has only 10 employees to oversee implementation of the fisheries regulations throughout Ghana This number will be increased as other institutions are engaged in joint monitoring initiatives but it is obvious that staff numbers and capacity will need to be expanded if regulations on fishing activities are to be affected Enforcement is only one part of the equation however Much greater emphasis will need to be placed on voluntary controls and self-policing at community level through Co-management schemes
Failure to press ahead with governance and institutional reform could delay the process of introducing and registering licenses which represents a crucial first step in moving from open access to managed access in the fisheries sector Given the urgency for action the five years allowed in the current plan for completing the registration process seems very generous Political resolve to implement unpopular measures Stakeholder meetings have confirmed the significance of party political influence as a constraint on achieving progress in the reform of the fisheries sector The offer of incentives like subsidies or the promise of new facilities and equipment are regularly employed by individual politicians to garner votes whether or not these form part of party manifestos Examples have been quoted to the consultants where enabling regulations that might restrict fishing access and prove unpopular amongst the fishing community are quietly ignored and officers may be discouraged from pursuing breaches of the law where the offender has political influence These issues arise with governments of all political
55
persuasions and can apply at all levels from District Assemblies through to regional and national committees
A serious issue with fisheries sector reform is that once actions have been taken to conserve fish stocks it may be years before the full benefits are felt and the results are evident in terms of increased catches This makes it harder for governments to institute unpopular reforms ndash even though these are in the best interests of the nation fishing communities and individuals Fishermen and their families are used to seeing an instant lsquosame day returnrsquo on their catch and are less willing or able than stakeholders in other economic sectors to wait for gradual improvements There is an urgent need to establish cross-party support for the fisheries sector in Ghana and to seek agreements between the main political parties to support established policy and regulations where these are in the interests of delivering sustainable fish stocks Availability of Technical and Financial Resources The process of moving from complete open access to restricted use rights for both marine and inland capture fisheries will take many years to complete Progress will be heavily influenced by the level of political will availability of technical assistance and financial support Existing subsidies (pre-mix fuel and import tariffs) are seen as a deterrent to the encouragement of more efficient business practices However in order to reduce dependencies on these forms of government aid there is also a need to underwrite new forms of economic enterprise by giving help to start-up businesses developing training centres and promoting alternative livelihoods for those individuals who are either displaced or voluntarily give up work in the fisheries sector Inertia to Change Traditional fishing practices are quite literally a way of life for many Ghanaians and have been handed down from generation to generation These traditions are closely interlinked with cultural practices and power and influence resides in specific families with hereditary authority In order to change attitudes and gain acceptance of new approaches to fishing there is a need for a major awareness building and communications strategy targeting in particular the traditional leaders of the fishing industry Without such a plan it will be difficult to break down the internal resistance and inertia towards change The constraints that have been outlined above in relation to the lsquoweakrsquo option are very real and in combination they present a serious barrier to progress It will require real political commitment on the part of Government and strong financial support from international partners to break down these barriers 74 OPTION C THE lsquoOPTIMUMrsquo SOLUTION
The new Draft Fisheries and Aquaculture Plan together with the Act and Policies provide a solid foundation for revitalising the fisheries sector in Ghana However for the reasons discussed in relation to options A and B above there are a number of impediments that need to be overcome In addition to the measures in Option B an ldquoOptimumrdquo solution would also include
A coherent mix of Incentives (carrots) and Regulation (sticks) A top priority in developing existing strategies and plans will be to ensure that measures are in place to offer encouragement and practical assistance to fishers to convert to more sustainable practices while at the same time introducing effective enforcement There are some real challenges with both of these goals
56
New forms of incentive need to be developed to convince boat owners and their crews that it is worth their while to drop illegal methods (dynamiting use of monofilament nets etc) and to reduce the level of fishing effort (through close seasons introduction of restricted zones etc) Without these incentives it is highly unlikely that there will be significant take-up of the fisheries stock management and conservation message Special attention needs to be given to the role of chief fishermen and local community councils in developing effective local policing since it is impractical to rely on a national MCS team to regulate canoe activity in either the marine or inland capture fisheries The national MCS team will have its own responsibilities for policing local and international waters in relation to industrial and semi-industrial sized vessels Integrated Coastal Development The long term success of the fisheries strategy depends upon reducing fishing effort to a level at which catches become both sustainable and profitable for those who remain in the business This in turn requires that those displaced from the industry are able to find gainful employment and livelihoods in other sectors of the economy The fisheries industry is often seen as a separate economic sector which attracts its own funding and support but in order for the necessary reforms to take place these attitudes will need to change A new approach is required to lsquointegrated coastal developmentrsquo following the lessons from integrated rural development Many fishing inland and marine fishing communities are almost wholly dependent on fishing with less than 10 of the local economy being devoted to other industries Reform of the fishing sector therefore requires that as much ndash if not more ndash effort is devoted by government and its international partners to building up complementary economic activities in construction transportation manufacturing food processing environmental conservation and tourism There is a need to explore new state industry partnerships to establish appropriate economic development agencies and to coordinate activities between relevant state institutions ministries and departments under the current decentralisation initiatives with district assemblies taking a prominent role If initiatives of this sort are taken forward it will make the task much easier in persuading conservatively ndashminded fishing communities that they need to simultaneously develop their own entrepreneurial flair and impose their own discipline
57
Chapter 8 DRAFT ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK (ESMF) 81 INTRODUCTION Previous chapters of this report have described the principal environmental and social impacts that are likely to arise from reform in the fisheries sector This chapter sets out the Framework (ESMF) for an Environmental and Social Management Plan (ESMP)The first step has been to outline specific objectives to be achieved through implementation of the ESMF These objectives relate specifically to the issues described in earlier chapters Subsequent sections of the chapter detail the measures which are required to respond to specific areas of environmental and social impact through mitigation and amelioration works They also describe the types and level of environmental monitoring required together with the institutional aspects which need to be improved in order to support the fisheries sector 82 STRATEGY AND OBJECTIVES The basic aim of the environmental and social management plan is to set out guidelines for participatory programs under which members of local fishing communities and civil society in general can become involved in the design and implementation of local fishery co-management maintaining sustainable local livelihoods and achieving local monitoring of fishery efforts The basic principle for future fisheries management is that both marine and inland waters will be demarcated as territories for use rights to fisheries (TURFs) The principal goal of government policy in the fisheries sector is to ensure that the fisheries industry plays an increasingly important role in supporting the growth of the economy as outlined in the Ghana poverty reduction strategy (GPRS II) and the Republic of Ghana fisheries and aquaculture policy This goal will be supported by implementation of the fisheries and aquaculture sector development plan over the next five years In this timescale the aim will be to bull improve management of fisheries the conservation of aquatic resources and protection of the
natural environment bull promote value addition in the fisheries sector and the improvement of livelihoods in fisheries
communities bull encourage sustainable development of aquaculture bull improve the services provided to the fisheries sector by the fisheries commission and supporting
institutions The overall consequences of this strategy and the investments that are being made by the government and its aid partners will be stabilisation of fish stocks and sustainable catch levels a strengthening of the national economy and creation of a more robust fisheries industry with consequent benefits for fishing communities Impact assessment confirms that the result will be significant benefits for the marine environment and local economy However depending on the rate of transition from an open access to a fully regulated market a number of adverse effects could arise unless appropriate mitigation measures are put in place Specific issues which require attention in this plan are listed below bull potential risks of environmental degradation through development of new fishing targets in
deep water
58
bull localised environmental impacts at construction sites bull loss of resources for individual operators due to restricted or controlled access to fishing
grounds bull displacement of labour from crews of vessels that are withdrawn from the industrial and semi-
industrial fleet bull Decommissioning of obsolete industrial vessels may not necessarily lead to recovery of fish
stocks Catch Per Unit Effort (CPUE) may increase This could lead to loss of livelihoods to crew members and the owners of the decommissioned vessels it could increase catch for the few vessels remaining in the system
bull increase production costs due to idling time in closed seasons for fishing bull exclusion of some groups and individuals seeking entrance to the industry following completion
of licensing bull concentration of processing and marketing at selected landing sites leaving Fish Mammies and
their dependents in other smaller fishing communities at an economic disadvantage bull displacement of traditional canoe building and other ancillary support industries by more
efficient and modern methods of construction and the inability of some workers in these trades to train and re-skill in the use of modern materials
bull lack of employment opportunities in alternative sectors The ESMF will set out specific actions to address these concerns through a coordinated set of interlinked proposals as follows 1) Preparation of local management plans and close surveillance of all new fishing enterprises in
deep waters
2) Preparation of environmental protection clauses to be included in all contracts and agreements for physical development work
3) Regular inspection by environmental protection officers of construction work at harbours and landing sites
4) Establishment of community management plans to provide support to those groups and individuals who are adversely affected by any of the measures listed above
5) Creation of community liaison groups to actively support community development alternative livelihoods and conversion to new areas of economic activity for those Fisher families or individual fishers who are adversely impacted
6) Introduction of skills training centres and business advice for small and medium enterprise development
7) Establishment of a coastal development agency drawing on the resources of the ministry of local government agriculture and tourism (others to be added) to coordinate integrated projects and initiatives for economic development linked with the existing coastal zone management plans
8) Creation of a liaison group between the government of Ghana and its international development partners to ensure that investment in the fisheries sector is targeted in the most effective way to deliver plan objectives and avoid duplication of effort
59
83 COMPONENTS OF THE ESMF The following paragraphs provide a summary of the draft ESMF 831 Local Management Plans these plans will be prepared for discrete zones of influence around specified fishing settlements Each plan will contain the same standard list of relevant activities that are to be monitored 832 Environmental Protection In relation to construction activity a checklist will be prepared identifying precisely what level of environmental scrutiny is required for specific types of development This checklist will be prepared by the Fisheries Commission with the support and advice of the Environmental Protection Agency 833 Small-Scale Project Development and Livelihood Restoration a list of potential micro-projects will be prepared by the Fisheries Commission which are regarded as suitable for support funding Demand for these micro-projects will be determined at the local level (ie in villages and fishing communities) Applications for funding of micro-projects will be submitted to the community liaison group for vetting and recommendation based on pre-established eligibility criteria Recommended projects will be referred for formal approval at national level (or through the Coastal Development Agency) 84 POTENTIAL PROJECT IMPACTS ON ASSETS AND LIVELIHOODS The project will have some adverse impacts on assets and livelihoods Therefore provisions will be made under the ESMF to minimize all such impacts including those of socio- economic significance and on any environmentally sensitive sites Provisions are also made in the RPF to accommodate all potential situations including cases that may entail actual displacement and livelihood restoration assistance in accordance with the Governmentrsquos policy and World Bank Policy on Involuntary Resettlement OP412 (see Chapters 9 and 10) The potential social and environmental impacts associated with the project (see Chapters 5 and 6) are summarised in Table 81 and the approach to related mitigation measures is defined in section 85 and Table 82 below
Table 81 Potential Environmental impacts and Social issues
Type of Activity Description Environmental Significance
Social Significance
Decommissioning of obsolete industrial vessels
Scrapping of vessels may release toxic waste (contaminated oils asbestos pipe wrapping and insulation etc)
Contamination of landfill dumps
Related health hazards
Laying off of work force Recovery of fish stocks in areas currently over-fished by trawling
Decommissioning of excessovercapacity would result in loss of livelihoods for crew members
60
Plan for fishing capacity reduction
introduction of licensing system for canoes and enforcement of licensing system for semi industrial vessels
Reduced catch from the decline in the use of prohibited fishing methods (activities) as stipulated in the Fisheries Regulation 2010 (LI1968) eg use of light dynamite etc
Reduction in fishing capacity should lead to significant recovery of fish stocks with long term benefits for all
Short term reduction in fishing effort and increased regulation may prejudice vulnerable sectors (illiterate elderly fishers) Capping on new entrants may remove the safety net opportunity offered by fisheries to would-be fishers who may be without alternative livelihoods
Harbour development and landing site improvements
Construction of access road improvements Erection of fish processing and ice making plant The Project could give rise to a small level of physical displacement for some sectors of individual communities
Removal of shelters homes Displacement of boat repair and trading sites for local community
Possible non-voluntary resettlement including vulnerable groups (women children and the elderly)
Adaptation Strategies to climate change
Introduction over time of regulations relating to fishing activity in rivers lakes estuaries lagoons and lsquoareas of upwelling affected by climate change
Measures to combat tackle rising temperature and other climate induced changes should ameliorate environmental impacts
Both beneficial and adverse effects may result from changes in climate (eg faster growth rates from higher water temperature spread of invasive species)
Establishment of exclusion zones ndash oil production and marine protection areas
Restrictions on fishing in oil production areas and marine protection areas
Positive ndash recovery of fish stocks but also potential risks of pollution from oil leaks and human waste
Temporary loss of livelihood for those fishers displaced from lsquotraditionalrsquo fishing grounds
Development of Co-Management System
Creation of 4 pilot Stakeholder ndashbased Fisheries Management Initiatives
Demonstration of practical benefits for the marine environment resulting from elimination of damaging practices
Greater social cohesion and sense of purpose established
61
Type of Activity Description Environmental Significance
Social Significance
Support for PAPs Establishment of enterprise training programmes
Development of criteria for defining Project Affected Persons (PAP) Development of skills training schemes enterprise allowances alternative livelihoods fund
Major benefits for PAPs ndash but scope for misinterpretation mismanagement of programme at local level Jobs created under social significance should be familiar to the fishers ie things they will be willing to do
Developing Compliance Systems
Establishment of enforcement unit and development of facilities and training for participatory coastal surveillance of small-scale fisheries
This component will greatly improve controls over environmentally unfriendly damaging activities
A number of new jobs should be created under this programme
Improvements in fish processing technology
Development of more efficient fish processing plant
This measure should reduce significantly the proportion of fish lost or degraded post harvest Improved fish processing technology will also reduce wood used from the forest as firewood for fish smoking
Potential displacement of vulnerable groups (women children and the elderly)who currently participate in fish drying curing using basic equipment
Construction of fish ponds
Expanding areas of dug-outs and other farm ponds
Small scale impacts on vegetation stream flow
Displacement of existing land users
Catalysing aquaculture development
Encouragement of larger fish farming enterprises Installation of fish cage aquaculture
Localised deterioration in water quality increased nutrients leading to eutrophication potential spread of fish parasites disease
Potential competition with free capture fisheries displacing vulnerable groups in existing fishing villages
62
85 PROPOSED MITIGATION MEASURES AND COST ESTIMATES Mitigation measures The potential environmental and social impacts to be addressed within the context of preparing this Environmental and Social Management Framework are generalized as shown in Table 82 below It is not possible at this time to prepare specific mitigation measures It is expected though that environmental and social assessment studies will be carried out within specific localities as and when required The framework for compensationresettlement (See Chapters 9 and 10) will then be applied incorporating (1) specific institutional arrangements (2) resettlementcompensation eligibility criteria (3) implementation procedures (4) financial responsibilities and (5) monitoring and evaluation plan Livelihood restoration measures Furthermore the livelihood restoration measures will consider issues such as
(1) income levels of affected persons
(2) other non-monetary sources of livelihood
(3) constraints and opportunities for income generation
(4) number of persons not able to revert to previous occupation and
(5) existing skills of affected persons
Table 82 Proposed mitigation measures for some potential impacts
Type of Impact Description of mitigation measures
1 Decommissioning of obsolete industrial vessels
a) A register will be prepared of all industrial vessels that are due to be decommissioned recording the owner and location of each vessel b) A system will be introduced for tracking progress on decommissioning including the means of disposal and measures taken to dispose of all potentially toxic or hazardous materials c) Persons who lose their job or livelihood as a result of a decision to decommission any particular vessel will be entitled to benefit from the skills training schemes enterprise allowances alternative livelihoods fund being developed
2 Plan for fishing capacity reduction
a) A full Social and Environmental Impact Assessment will be carried out on the Plan for fishing capacity reduction and appropriate measures for ameliorating and mitigating adverse effects on affected sectors of the community and PAPs will be incorporated in a revised edition of this Fisheries Environmental and Social Management Framework
63
3 Harbour development and landing site improvements
a) All harbour development proposals will be subject to Environmental and Social Impact Assessment (ESSA) in accordance with EPA Regulations b) Proposals for improvement of individual landing sites will be assessed in accordance with the checklist (832) and submitted to EPA for a ruling on the level of environmental assessment that is required which will depend on the nature of the intended works
4 Adaptation Strategies to climate change
a) An adaptation Strategy shall include proposals for mitigating any impacts on the environment or social welfare of local communities
b) Any strategy for responding to potential effects of climate change on the fisheries sector will be submitted to EPA for review to determine whether an SEA or EIA is required
5 Establishment of exclusion zones ndash oil production and marine protection areas
a) Proposals for restricting access of fishing vessels to oil production areas and marine production areas shall be subject to an Environmental and Social Assessment which shall be submitted for approval to EPA b) In the event that restrictions are likely to adversely affect fishersrsquo livelihoods the provisions set out in 7 below will apply
6 Development of Co-Management System
a) Development of co-management systems will require full cooperation and engagement of all stakeholders In the unlikely event that the provisions of any scheme are challenged by local communities there shall be a right of appeal to the Minister of Food and Agriculture and the Fisheries Commission acting jointly
7 Support for PAPs
Establishment of enterprise training programmes
a) Identification of vulnerable people including women children and the elderly and identification of the cause and impacts of their vulnerability shall be established through direct interviews and procedures to be developed as part of 6 above b) A high priority within the Fisheries and Aquaculture Sector Development Plansrsquo first five year programme will be the development of specific proposals for the establishment of skills training programmes and the establishment of enterprise allowances and an alternative livelihoods fund c) The measures outlined in 7b) above will be targeted specifically at PAPs and vulnerable sectors of the community
8 Developing Compliance Systems
a) All proposals for securing compliance with fisheries regulations shall be subject to review by a fisheries stakeholder committee to be established by the Fisheries Commission with the remit of ensuring that the measures themselves and penalties for failure to comply are commensurate with the ability of offenders to make restitution and do not unfairly penalize vulnerable sectors of the community
9 Improvements in fish processing technology
a) All plans and proposals for the introduction of new fish processing technology shall be published and shall include a statement on the likely impact of the project on existing processors within the local community
64
b) Any members of the public who consider they are unfairly disadvantaged by proposals for the introduction of new technology may apply to the local co-management committee to determine whether or not they fall within the category of PAP (see 6 and 7 above)
10 Construction of fish ponds Proposals for the construction of new fish ponds shall be assessed in accordance with the checklist (see section 832)
11 Catalysing aquaculture development
a) All proposals for aquaculture development shall be in accordance with the provisions laid down in Local Management Plans applying to specific TURFs
65
11
CHAPTER 2 PLAN AND PROGRAMME DESCRIPTION
INTRODUCTION This chapter is divided into two parts Part 1 sets out the progress which the government Ghana is making in giving effect to the legislation policy and regulations Part 2 describes the proposed programme of assistance being offered by the World Bank with the specific aims of strengthening governance and enforcement systems (Components 1 and 2) and in promoting value addition and reduction of post-harvest losses
PART 1- THE DRAFT FISHERIES AND AQUACULTURE SECTOR DEVELOPMENT PLAN (FASDP) This plan (FASDP) covers the period 2010-2015 It recognises the importance of Ghanarsquos fisheries which generate in the order of US$ 1 billion a year contribute 45 to GDP and indirectly support the livelihoods of 22 million people However through over-fishing and lack of investment in management and value addition the average income per canoe has dropped by up to 40 over the last ten years to the point where it costs as much to fish as the catch is worth By comparison well managed fisheries in other parts of the world are capable of generating economic returns of 30-60 on investment (equivalent to a potential income of US$ 300 million a year for Ghanarsquos fisheries) The Draft FASDP acknowledges that the fishing sector is expected to make a substantial contribution towards doubling the size of the Ghanaian economy by 2015 (GPRS II) as part of the Republic of Ghana Fisheries and Aquaculture Policy Seven targets are set in the draft FASDP 1 Maintaining capture fisheries production at current levels 2amp3 Increasing revenue and profitability in capture fisheries by at least US$ 50 million a year after
five years 4 Increasing aquaculture production to 35000 tonnes a year after five years 5 Retaining Ghana as a landing and processing hub for the West Africa tuna industry 6 Developing fisheries management to allow effective control of all commercial fishing effort in
Ghanaian waters and 7 Ensuring fisheries management costs are sustainable and that the fisheries sector overall make a
fiscal contribution to Government revenues There is an underlying presumption that the canoe sector will remain at the heart of Ghanarsquos fishing industry but the plan is not prescriptive and leaves open the ways of achieving the overall goals At the same time there is an underlying assumption that the long term sustainability of Ghanarsquos fisheries will depend upon discouraging further entry by new operators
PART 2 THE WORLD BANKrsquos CONTRIBUTION TO GHANA FISHERIESPLAN (FASDP)
The essential aim of the World Bankrsquos contribution to FASDP is to provide investment which will build the necessary policy and capacity for effective fisheries management designed to reduce fishing effort while maintaining approximately the same catch levels and to address the impacts of change for fishers
12
and the communities in which they live Based on the currently available draft Project Appraisal Document (PAD) each of the components is now described in turn Component 1 - Good governance and sustainable management of the fisheries This component on good governance comprises four subcomponents which are broken down in turn into a number of separate activities Sub-component 11 developing the capacity rules procedures and practices for good governance of the fisheries Activity 111 reviewing the Fisheries Act and developing regulations to support the Sector Policy and the Fisheries and Aquaculture Sector Development Plan Activity 112 Developing an operational policy to enable implementation of the aquaculture and fisheries sector development plan Activity 11 3 strengthening fisheries management systems and capability (fisheries management plan development aquaculture implementation technical support and training) Activity 114 strengthening fisheries Information Systems (catch recording and monitoring systems statistical analysis and training)
Sub-component 12 introducing fishing rights
Activity 121 developing pilot stakeholder-based fisheries management initiatives around defined fisheries units (ie local management initiatives tighter defining fisheries resources in up to 6 selected Fisher communities) Activity 122 introducing and administering a licensing regime
Subcomponent 13 Adjusting fishing effort and capacity to more sustainable levels marine resource conservation and supporting alternative livelihood opportunities when needed Activity 131 vessel decommissioning Activity 132 compensation packages for crew of decommissioned industrialsemi-industrial vessels Activity 133 alternative livelihood development to incentivise voluntary capacity reduction in the canoe sector Activity 134 marine resources management and conservation
Subcomponent 14 social marketing communication and transparency Activity 141 communications stakeholder consultations and awareness raising programmes to support fishery development Component 2 reduction of illegal fishing Under the West Africa regional fisheries programme subcomponent 21 allows for enabling environment for reduction of illegal fishing These provisions already exist within Ghana and this subcomponent is therefore omitted Subcomponent 22 monitoring control and surveillance (MCS) systems Activity 221 developing compliant systems and capability
13
Component 3 increasing the contribution of the marine fish resources to the local economies Subcomponent 31 product diversificationvalue chain development (freshfrozen producttrade facilitation) Activity 311 landing site development Activity 312 Port development Subcomponent 32 fish product trade infrastructure information and systems - regional minimum integrated trade expansion platform (MITEP) Activity 321 export certification centre development Activity 322 fish processing technology improvements Activity 323 national fisheries advisory group Subcomponent 33 marine and inland aquaculture development Activity 331 space developing aquaculture policy and legal framework Activity 332 improving genetic policy of tilapia fingerlings and breedstock Activity 333 catalysing aquaculture development Component 4 Coordination monitoring and evaluation and program management Subcomponent 41 national implementation subcomponent 42 regional coordination Each of the components sub-components and activities are described in more detail in Chapter 5 which assesses the nature of environmental and social safeguards issues in terms of the World Bankrsquos planned investment
15
CHAPTER 3 BASELINE CONDITIONS
INTRODUCTION This chapter discusses the existing fishery resources of Ghana and describes recent environmental and social trends It identifies some of the pressures that led to the reduction in value of fishing activity and indicates the threats that could be posed if no action is taken in accordance with the planned fisheries and aquaculture program to deal with them FISHERY RESOURCES The continental and coastal waters of Ghana are potentially very rich due to a combination of warm waters and nutrients carried in ocean currents which up-well seasonally on the continental shelf The tonnage of fish caught in marine waters peaked in the mid-1990s around 500000 tonnes and currently averages around 400000 t(See Figure 1) Figure 1 Wild Capture Production in Ghana 1950-2005
2
Table31 Top 10 Species Exported (by value)
1 Canned tuna ($72000000) 2 Fresh tuna ($7200000) 3 Tilapia (no figure available) 4 Miscellaneous dried fish ($1000000) 5 Salmonids frozen ($900000) 6 Marine fish frozen ($600000) 7 Cuttlefish and squid ($600000) 8 Shrimps and prawns ($90000) 9 Sardines ($80000) 10 Crustaceans frozen ($50000) Source FAO Fishstat
The principal catch from deep waters is tuna Industrial vessels registered in Ghana target these species in international waters but also illegally in coastal waters Herring sardine and anchovies are fished in coastal waters by semi-industrial vessels and canoes Table 31 shows the top 10 species of fish exported from Ghana in 2005 PROFILE OF THE FISHING INDUSTRY Fishing is of vital importance in Ghana not only in terms of its contribution to gross domestic product (45 per annum) but because fish provides 65 of the countrys protein In recent years (between 2003-2008) and more specifically in 2004 the countryrsquos annual fish requirement has been estimated to be 882000 tonnes of which the country produces just about half (Tetteh 2007) Of the total population of 22 million people it has been estimated that between 15 and 22 million people are employed or gain their livelihoods from fishing (8-10) Of these there are 210000 men who are directly employed as
2 This figure is the Fisheries Departmentrsquos estimate for 2008
16
fishers The total export of seafood was valued US$824 billion in 2005 Ghanas fishing industry can be divided into three sections marine capture inland capture and aquaculture It can be further analysed by scale of operations distinguishing between industrial semi-industrial and artisanal sectors Marine fisheries Industrial sector Commercial fishing for tuna began in 1962 In the early 1980s Ghana sought to develop an industrial fishing fleet and there are currently 90 industrial trawlers and other vessels which are located in Tema and Takoradi Sekondi The port of Tema was expanded from 1962 to create four main areas the Inner Harbour Outer Harbour Canoe Basin and Commercial Area In 1999 fish landing facilities were improved at the Albert Bosumtwi Sam Fishing Harbour built in Sekondi This harbour is equipped with a cold store an ice-making plant offices a berthing bay for inshore vessels a jetty for canoes and a net drying area Under Ghanaian law more than 50 of the ownership of industrial vessels must be registered with a Ghanaian company or individuals However in practice many vessels are owned by foreign nationals with token Ghanaian ownership Relatively few of these large vessels regularly put to sea and a number are in poor condition or obsolete Nevertheless the impact of trawling activities by Ghanaian registered and foreign owned vessels has been very considerable in coastal waters in recent years Fish landed from industrial vessels is usually transferred directly to Canning factories in Tema and Takoradi Ghana has the largest canning industry in West Africa In the region of 30000 tonnes of tuna are landed In addition to trawling some industrial vessels are engaged in shrimping the use of tuna lines and polls purse seining and demersal trawling Semi-industrial sector in addition to deep sea trawlers there are around 230 large semi-industrial ships propelled by inboard motors which are used for trawling in shallow waters during the off-season and purse seining during upwelling seasons There are currently reported to be 48 bottom trawlers 14 pair trawlers 2 shrimpers 33 pole and line vessels and 10 tuna purse seiners operating from 2 of the 7 landing sites Canoe sector Ghanas artisanal fishing sector is based on between 10000 and 12000 wooden canoes Fifty seven per cent of the fleet is powered by outboard motors supported by paddle and occasionally sail Each Canoe carries a crew of between three and 20 men depending on size and length There are over 334 landing sites along the 550 km coast of Ghana and the majority of fish caught by canoe (180000 tonnes) is returned to these sites accounting for 70 of Ghanarsquos fish production The principal landing sites are at Teshie Jamestown Chorkor Shama Axim Elmina Winneba Mumford Akplabonya Adina Atiteti Abutiakope and more Fishing is undertaken by men but the majority of canoes are owned by women who pre-finance fishing trips (purchasing gear and premixed fuel) and purchase the catch Women also predominate in processing and marketing fish and fish products Only about 20 of fish sold fresh a further 20 is salted and the majority (60) is smoked It is estimated that up to 30 of the catch is spoilt through lack of ice for storage or alternative processing facilities
17
Inland fisheries Water Resources Ghanarsquos inland fishery resources consist of a natural lake( Lake Bosomtwe) and nine major river basins which from east to west of the country are
bull the Volta bull Densu bull Ayensu bull Ochi bull Kakum bull Pra bull Ankobra and bull the Tano
The River Tano forms the border between Ghana and Cote drsquo Ivoire The largest of the rivers is the Volta which drains more than two-thirds of the country through several large tributaries in virtually all regions of the country The Volta river system also incorporates the Volta reservoir generally known as the Volta Lake which has a surface area of around 8400 km2 The Volta lake discharges through the Akosombo dam before flowing through a delta into the Atlantic Ocean The eight other river systems are relatively smaller simpler and open more directly into the Atlantic There are also several reservoirs created on the smaller river systems mainly for potable water production irrigation and flood control These reservoirs irrespective of their primary purposes enhance availability of more permanent aquatic habitable space for fish and therefore support some fisheries Finally with all the river systems opening into the Atlantic there are a series of lagoons and estuaries which act as interfaces between the rivers and the sea These water areas constitute another type of inland water resource for salt and brackish water fishes Inland Fish resources Within the inland water resources of Ghana there are over 150 fish species more than 90 of which are fished for food
In commenting on inland fisheries in Ghana it must be noted that virtually all available information on inland fisheries is obtained from the Volta Lake No national fish production records have been kept on the fisheries of the eight smaller river systems and the lagoons and estuaries Thus the usual statement that inland fish production constitutes about 20 of what the country produces should refer to fish production from the Volta Lake In practice the total inland fish contribution could more realistically be estimated at about 30-35 of national fish production This is a very considerable but understated contribution to national food security and nutrition
Fishing vessels The dominant fishing vessel on the Volta Lake is the canoe the majority of which are built from wooden planks On some other river systems while plank canoes predominate a small number are carved as dug-outs from single tree trunks There is some variety in sizes of the canoes depending on how many planks are used to build the boat and the size of tree trunk used in building a canoe The total number of canoes estimated on the Volta Lake during a survey in 2000 was 24035 On the tributary rivers of the Volta Lake and other river systems in the country the planked canoe is the main vessel used in fishing
18
Fishing gear There are about eleven main kinds of gear used for fishing on the Volta Lake They are Gill Nets Cast Nets Hook and Line Basket and wire mesh traps Winch net Beach seine Bamboo Nifa-nifa Wangara Spears and Atidzas On other rivers in the country Gill nets Cast nets Hook and Line and traps are the fishing gear used On both the lake and rivers the Gill net is the main gear
People Involved In the 2000 frame survey of the Volta Lake conducted by the Fisheries Directorate of Ghana the estimate of fishers on the Volta Lake was put at 71861 Fishers on the lake work in collaboration with a host of fishmongers or handlers who also function as wholesalers for individual fishing groups Assuming that the fisher population on the lake has increased by a modest 3 in the ten years from 1998 to 2010 a fisher population of about 93500 could be considered to be on the Volta Lake now If again it is estimated that number of fishers on rivers in the country were to be a tenth of those on the lake this would put the fisher population on inland waters (apart from the Volta Lake) at about 9350 fishers A very conservative estimate therefore puts the total number of individuals who are directly engaged in inland fishing at over 100000 This excludes all directly associated groups such as fish handlers processors and traders An estimate of secondary fisheries operators such as boat builders out-board motor operators and mechanics as well as bulk salt and fuel wood sellers and those engaged in buying selling and distributing fish would have to be considered in developing estimates for both direct and indirect employment in inland fisheries but the number can be assumed to lie between 125000 and 150000 people
Aquaculture Under Ghanarsquos legal framework aquaculture is defined as ldquoany activity designed to cultivate or farm fish and other aquatic living resourcesrdquo Currently only fin fishes are involved in aquaculture in Ghana
Current culture media and environment Currently fish culture takes place almost exclusively in fresh water in Ghana either in cages brush parks or dugouts Dug-outs are excavations made in floodplains in the savannah parts of the country were water scarcity has been a major hindrance to development in general and food security in particular Dug-outs get filled with flood waters and whatever the water carries during major wet periods of a year in the savannah areas Waters that fill Dug-outs invariably contain fish which are trapped in the Dug-out after the wet period These water bodies are managed until the end of the dry period and the fish are harvested before the next flood period Since the 1960rsquos various strategies to augment fish production from Dug-outs have been developed and tested These involve adding fingerlings of selected fish species to those which are lsquonaturally stockedrsquo in Dug-outs by floods Dug-outs are the major fish culture production approach in the savannah parts of the country which accounts for a little more than half the area of the country The Environment of fish culture Currently fish culture is taking place mainly in freshwater environments Brackish water fish culture and mari-culture activities which will bring lagoons estuaries and the sea into fish culture production have long term potential for development Fishes in culture Fishes being cultivated in Ghana In order of importance are Nile tilapia Oreochromis niloticus the African catfish Clarias gariepinus species of the catfish Heterobranchus and the Bony tongue Heterotis niloticus Scale of Culture Based on level of production fish culture operations can be categorized as follows
bull Large scale commercial where an enterprise produces up to 10000 tonnes per year
19
bull Medium scale commercial where a single enterprise produces between 50 and 500 tonnes bull Small scale commercial where an enterprise produces between one and 20 tonnes and bull Very small scale commercial with productions below 20 tonnes
Fish culture production Cultured fish contribution to national production was officially stated as 9000 tonnes for the year 2009 However informed opinion amongst fish farmers indicates that a figure of between 16000 and 20000 tonnes in 2010 would be closer to reality This statement is based on the facts that most producersrsquo published figures are underestimates several small to medium scale producers are not recorded in official lists and the recording of newly established fish farms has lagged actual establishment especially since 2009 Although cultured production up till 2009 may not have been significant considering a shortfall of about 460000 mt (as recorded in 2004) between captured fish production and national demand this reflected the fact that there were only two large scale commercial producers in the country each of which had had less than ten years of operation Anticipated growth in fish culture production within the next five years is expected to be dramatic as some of the critical challenges of the industry are resolved
CHALLENGES AND PROSPECTS Marine Fisheries The fishing sector is vital for food security and job creation to help alleviate rural poverty in Ghana However the levels of fisheries harvests are generally considered to be close to or to have exceeded the maximum sustained yield Future sustainability in the industry will depend upon the restriction of open access to fisheries and the introduction of management systems which allow fish stocks to recover and the establishment of consistent yields in both marine and inland waters Inland Fisheries Environmental conditions on the Volta Lake constitute the major environmental and social challenges for fisheries its sustainability and profitability In terms of future prospects success will depend heavily on implementation of the lsquoGhana Fisheries and Aquaculture Sector Development Planrsquo and the capacity of the system in Ghana to enforce the Fisheries Regulations passed by parliament in August 2010 Aspects of the Development plan that offers great prospects for the lakes fisheries include the provisions for eventually licensing boats (although the scale of this task should not be underestimated) and measures to involve communities in management of fisheries resources of the Lake
Aquaculture The main challenges facing aquaculture development in Ghana relate to bull The high cost of fish feed (significantly due to its importation from other countries) bull None availability of commercial fish hatcheries as enterprises bull Lack of a nation-wide distribution network for fish seed and cultured fish producers Most
sources of fingerlings are concentrated in one part of the country and since farms all over Ghana obtain their fingerlings individually transportation costs add significantly to overall production costs
bull Now emerging certification and monitoring to check the health and safety of aquaculture processes and products
bull The absence of adequate regulations regarding establishment of an aquaculture enterprise until August 2010 (In the absence of regulations only the large and medium scale commercial farms worked towards conforming to international performance Standards and operational regulations for certification of farms and their products still remain in a draft state)
bull Low national support for research to support expansion and systematic development of aquaculture
20
The prospects for development of aquaculture as an industry in Ghana are good since a number of practical policy and legal frameworks have been put in place to resolve the basic challenges to the industry listed above These include
bull Construction of the first local fish feed plant by an international fish feed company with the expectation of having initial products on the Ghanaian market during 2011
bull A lsquoLarge scale commercial fish farmrsquo with great capacity for fingerling production is shifting emphasis to fish seed production And several localized fish seed producers are expanding operations
bull Distribution strategies by cultured fish producers have started to emerge on a limited scale and are expected to evolve with increasing production as existing commercial farms expand and new ones join in
Now that regulations regarding establishment of aquaculture enterprises have been gazetted there is likely to be a positive response amongst fish farmers of all size categories New operational standards are being prepared which will introduce minimum standards for local certification This should set the stage for preparation of fish culture products and the broadening of choice for consumers while also qualifying Ghanaian producers to enter external markets
ENVIRONMENTAL CONDITIONS The coastal and marine environment a critical zone of influence for this study comprises a 550 km coastline a coastal belt ranging from 1 to 20 km in width and coastal waters extending to 200 nautical mile limit which was established in 1977(under the territorial waters and continental shelf act 1973 as amended by the territorial waters and continental shelf amendment decree 1977) The Coastal Belt The coastal belt accounts for only 65 of the land mass of Ghana but it is one of the most densely settled areas accounting for 25 of the population and80 of the industrial establishments in Ghana Historically the coastal zone was cultivated for coconut (copra) but this industry is in decline Vegetables and other agricultural produce are grown on better soils but the principal economic activities are fishing transportation salt production and sand and stone winning Tourism also offers great potential There is considerable expectation that the discovery of offshore oil and gas deposits will bring new wealth to parts of the coastal corridor However present plans to transfer crude products to tankers at sea and then export them directly will limit industrial activity to a support role A high percentage of industrial and municipal wastes is dumped at landfill sites within the coastal zone which creates pollution risks The coastal belt is generally a low-lying area less than 200 m above sea level Vegetation types reflect the rainfall gradient and consist of coastal shrub and Savannah to Winneba southern marginal forest to the east of Sekondi dry semi-deciduous and moist semi-deciduous forest to the east of Cape Three Points estuary and wet evergreen forest in the extreme south Soils are variable within this area ranging from fertile pockets river valleys to Sandy poorer quality soils close to the sea The Coast The coast line divides into three sections (Ly 1980)
bull West of Cape Three Points this area has a wide and flat beaches backed by coastal lagoons and
21
wave heights are generally low bull Between Cape three points and Tema the coast consists of a series of rock headlands enclosing
shallow bays together with sandbars or spits enclosing coastal lagoons The surf zone is a medium to high energy environment with wave heights often exceeding 1 m South-westerly prevailing winds give rise to longshore drift in an easterly direction
bull Between Tema and Aflao most of the shore is sandy although there are rocky outlets The coastal zone is important internationally in providing feeding roosting and nesting sites for thousands of migratory birds Environmental degradation is significant in Ghana and is recognized in the countryrsquos environmental action plan It contributes to rising poverty levels coupled with poor human health and inadequately planned urbanization which fuel a vicious cycle inhibiting human development The core issues include
bull Domestic sanitation bull Increased urbanization without appropriate infrastructure bull Wetlands and mangrove degradation bull Coastal erosion and bull General biodiversity loss
Briefly each of the above could directly or indirectly adversely influence fisheries and aquaculture separately or together For example in a recently completed study of water quality scenarios of the Volta Lake in relation to fish production as a component of a comprehensive study (The Challenge Program Project of Water amp Food) it was concluded among others that poor sanitation in highly populated fisheries communities adversely influenced water quality to the detriment of fish life and thus fish production With reference to aquaculture the same unsanitary conditions in highly populated shore communities adversely influenced water quality especially in terms of oxygen depletion when lake waters extend to the shore in high water periods This is a situation which has caused fish kills in cages because caged fish cannot escape lsquopollutedrsquo waters Degradation of wetlands and mangroves leads directly to a reduction in their capacities as spawning and nursery zones for both marine and inland water fishes which reduce fish production in both environments The situation outlined above is often contributed to by anthropogenic and industrial pollution due to urbanization without appropriate infrastructure Another issue linking human activity to a deteriorating environment is demonstrated by the encroachment of aquatic weeds on inland waters such as the Volta Lake Weed growth is accelerated by farming reservoir catchments which increases nutrient levels and the building of dams which reduce or cut off intrusion of sea water into rivers Currently as climatic change observable impacts such as floods seem to escape predictions The project could possibly contribute to mitigating against direct and indirect effects of climate change on fishing and aquaculture through investment into climate change orientation and education of fishers and fish farmers to mainly influence reasonable precautions they take Marine waters The continental shelf is relatively narrow projecting out to 25-35 km except in the area of Cape Coast to Salt Pond where it extends to almost 80 kms Sandy and rocky substrates which previously supported coral and seaweeds have been severely affected by former trawling activity which indiscriminately
22
dredges material from the seabed Coastal waters are enriched by freshwater discharges from the relatively small number of rivers and by two seasonal up-wellings which occur between late June and early October (the main upwelling) and January and March (the minor upwelling) The origin and driving mechanisms of these up-wellings are not fully understood and both their location and strength varies from year to year
Lake Volta and other inland water
Major environmental issues on the Volta Lake which might also be considered as challenges to sustainable fisheries on the major inland fisheries resource can be summarised as follows
bull The Volta Lake is known to be low in nutrients It therefore has low standing crops of phytoplankton and zoo plankton to support high fish production
bull The northern segment of the lake together with tributary rivers constitute the spawning and feeding grounds for majority of fish species in the lake during the wet season however these segments are intensely fished during the same period
bull The Volta Lake is divided into eight unequal strata with different distribution of boats per Km2 At the last estimation of carrying capacity in 2000 stratum V and II had the highest (527) and lowest(157) number of boatsKm2 respectively
bull The rate of siltation in the lake is considered to be increasing due to erosion associated with high rates of deforestation
bull A major challenge exists in getting fishers fishing communities and fishing entrepreneurs to understand and comply with fishing regulations aimed at conserving fish and fisheries resources
bull There is a lack of resources studies and research to support fisheries management of the Lake
bull High illiteracy exists amongst lake shore communities
bull Open access to the fish resources of the Lake has been in operation since its formation
bull Declining fish yields are occurring in the lake (468 Kgha in 1976 to 320 Kgha in 2003-MOFA) brought about by the constraints listed above
bull The commonly assumed estimate of potential fish production from the lake of around 75500 mtyr) is considered to be a serious underestimate since Stratum VII alone was estimated to produce 33800mtyr in 1996
bull The policy environment for aquaculture is currently strongly supportive of the industry and related enterprises
bull There is good quality and more than sufficient water to allow some kind of aquaculture to be developed in every region of the country with the Volta lake (about 8400 Km2) as the single most important water unit for fish culture Currently it appears that the free access to the fish resources of the lake has to some extent been applied to establishment of small scale caged fish culture enterprises a situation constituting environmental risk to investments of large scale commercial fish culture establishments in the lake
bull The Volta Lake is low in nutrients (Obeng 1964) resulting in a situation where higher fish yields could be sustained if greater quantities of fish feed were available
23
bull In Ghana the Nile tilapia O niloticus occurred naturally only in the Volta system Due to positive culture characteristics of the fish it has been moved into virtually all other river basins in the country The situation provides opportunities for hybridization of the Nile tilapia with other tilapia species native to the river basin into which the Nile tilapia has been moved
25
CHAPTER 4 POLICY AND LEGAL FRAMEWORK FOR ENVIRONMENTAL AND SOCIAL ISSUES
41 INTRODUCTION
Development and implementation of the Ghana Fisheries and Aquaculture Sector Development Plan and the World Bankrsquos supporting program need to be developed with full regard to existing international conventions national legislation policies and regulations This chapter highlights the main legislative and policy considerations for the protection of the environment natural resources fisheries and social and economic development It begins with reference to the World Bankrsquos safeguard framework and those of other donors This is followed by a section on the governance framework in Ghana
42 WORLD BANK AND OTHER DONORSrsquo SAFEGUARDS POLICIES
The World Bankrsquos safeguard policies exist to ensure that all projects which it finances are developed and implemented on environmentally and socially sound principles A range of different policies exist and these have been carefully considered to ensure that the Ghana Fisheries and Aquaculture Development Sector Development Plan complies with these safeguards All policies have been screened and those that have no bearing on the fisheries programme have been excluded from Table 41 below Table 41 lists policies which could have some applicability to the FASDP even if this interaction might be very slight It is important to stress that the comments in the third column of Table 41 relate to the entirety of the Fisheries and Aquaculture Sector Development Plan whose effects will continue to be experienced long after the World Bankrsquos financial support has been expended Most of the activities in the FASDP will have no effect in relation to safeguard objectives and where there are implications these are likely to occur at precise locations (for example at fish landing sites) rather than throughout the industry Where potential interactions have been noted the necessary mitigating measures are incorporated in the Draft Process Framework
Table 41 World Bank Safeguard Policies in Context
Safeguard Policy
Safeguard Policy Objective Brief Description and relevance to FASDP
OP 401 Environmental Assessment
This policy aims to ensure that Bank-financed projects are environmentally sound and sustainable and that the decision-making process is improved through appropriate analysis of actions and mitigation of their likely environmental impacts This policy is triggered if a project is likely to carry potentially adverse environmental risks and impacts on its area of influence OP 401 covers impacts on the natural environment (air water and land)
The majority of actions planned under FASDP will be beneficial to the marine environment and to inland waters However new construction activities could have impacts and depending on the project and the nature of impacts a range of instruments can be used to ameliorate and mitigate adverse effects while enhancing beneficial effects These include EIA environmental audit risk assessment and environmental management plans (EMP) The need for EIA and EMP is considered in this report
26
OP 404 Natural Habitats
This policy recognizes that conservation of natural habitats is essential to safeguard their unique biodiversity and to maintain environmental services and goods for human society and for long-term sustainable development The Bank therefore supports the protection management and restoration of natural habitats in its project financing as well as policy dialogue and economic and sectoral work Natural habitats comprise many types of terrestrial freshwater coastal and marine ecosystems They include areas lightly modified by human activities but retaining their ecological functions and most native species
This policy is triggered by any project (including any sub-project under a sector investment or financial intermediary) with the potential to cause significant conversion (loss) or degradation of natural habitats whether directly (through construction) or indirectly (through human activities induced by the project) This policy is applicable to the Ghana Fisheries Programme because the project focuses on the integrated management of natural habitats However by screening all proposals under the ESMF any sub-projects that might impact these habitats will not be funded
OP 409 Pest Management
The objective of this project is to (i) promote the use of biological or environmental control and reduce reliance on synthetic chemical pesticides and (ii) strengthen the capacity of the countryrsquos regulatory framework and institutions to promote and support safe effective and environmentally sound pest management
The policy is triggered if (i) procurement of pesticides or pesticide application equipment is envisaged either directly through the project or indirectly through on-lending co-financing or government counterpart funding (ii) the project supports an activity requiring the use of pesticides that may have negative effects on the environment The only instance in which this policy might be triggered by the Ghana Fisheries Programme is if aquatic herbicides or antibiotics were to be used in connection with aquaculture This is most unlikely but can be monitored through the implementation programme
OP 411 Physical Cultural Resources
The policy objective is to assist countries in avoiding or mitigating adverse impacts of development projects on physical cultural resources For the purposes of this policy ldquophysical cultural resourcesrdquo are defined as movable or immovable objects sites structures groups of structures natural features and landscapes that have
Under the Ghana Fisheries Programme construction and rehabilitation activities that could have negative impacts on cultural property will be avoided In the case of discovery of remains national procedures will be applied
27
archaeological paleontological historical architectural religious aesthetic or other cultural significance
OP 412 Involuntary Resettlement
The objective of this policy is to (i) avoid or minimize involuntary resettlement where feasible while exploring all viable alternative project designs (ii) to assist displaced persons in raising their former living standards income-earning capacity and production levels or at least in restoring them (iii) encourage community participation in planning and implementing resettlement and (iv) provide assistance to affected people regardless of the legality of land tenure
The policy covers not only physical relocation but any loss of land or other assets resulting in (i) relocation or loss of shelter (ii) loss of assets or access to assets (iii) loss of income sources or means of livelihood whether or not the affected people must move to another location The activities of the Ghana Fisheries Programme are likely to result in loss of assets or access to assets and loss of income sources or means of livelihood for some groups and individuals The potential for such losses will be carefully scrutinised and compensated for through the National Process Framework and Resettlement Policy Framework described in this report and appropriate procedures will be followed where necessary
Other donors and aid agencies including International and National NGOs play an active role within the fisheries sector in Ghana and their safeguards standards will be observed through operation of the Environmental and Social Safeguards Management Plan
28
43 THE GOVERNANCE FRAMEWORK IN GHANA
The Ministry of Food and Agriculture (MOFA) Preparation of Fisheries laws and policies fall under the responsibilities of the Minister of Food and Agriculture who in turn delegates functions including implementation to a semi-autonomous body the Fisheries Commission
The Fisheries Commission (FC) was established under the Fisheries Commission Act (625 2002) It oversees management regulation and utilisation of the fisheries resources of Ghana drawing on powers set out in the Fisheries Law (PNDC 256 1991) Fisheries Act 625 provided for the establishment of a more robust Fisheries Commission (FC) which is an amalgamation of the erstwhile FC and Department of Fisheries
Ten individuals constitute the Board which is led by a chairman (appointed by the President of Ghana in consultation with the Council of State) supported by three members drawn from the ministries of transport defence and environment There are three representatives from the following parastatal organizations - the Ghana Marine Fishing Officers Association Water Research Institute and Ghana Irrigation Development Authority- and two representatives (one from the artisanal and one from the industrial sections )of the National Fisheries Association of Ghana Finally the tenth member is a person with requisite knowledge of the fishing industry or natural resources renewal management
The day to day work of the Fisheries Commission is undertaken by the Department of Fisheries (DOF) which serves as the implementation secretariat of the Fisheries Commission as stipulated by the Fisheries Act 625 of 2002 Specific tasks that are undertaken by the Department of Fisheries include
bull preparing fishery resource management plans bull developing regulations for the fishing industry bull organizing monitoring surveillance and enforcement for the national fishery resources and
ensuring compliance with national fisheries law and institutionalizing co-management concepts
The MCS Division of the DoF (established under the Fisheries Sub sector Capacity Building project) works in conjunction with the Ghana Navy and undertakes sea patrols to exclude industrial fishing vessels from the 30-metre depth IEZ reserved for artisanal fisheries The MCS also conducts inspection of industrial vessels at the fishing ports of Tema and Takoradi for
bull valid fishing licences bull legality of fishing gear bull skipperrsquos certificate bull log book and crew composition
The MCS undertakes similar functions for inland fisheries on Lake Volta
The Ministry of Local Government and Rural Development (MLGRD) is responsible for managing fishers fish processors and fishery resources at district and sub-district levels which it undertakes through the District Assemblies In 2002 the District Assemblies in collaboration with DoF were mandated to facilitate fishery resource management by
bull helping to form and sustain Community Based Fisheries Management Committees (CBFMCs) bull cooperating with the DoF MCS units bull providing legal and financial support to the CBFMCs and bull approving levies proposed by the CBFMCs
29
Community-Based Fisheries Management Committees are charged with the responsibility of enforcing national fisheries laws at community level as well as initiating and enforcing their own by-laws
44 THE LEGAL FRAMEWORK
441 International Conventions
Ghana has ratified a number of international conventions and treaties which have an important bearing on the state of its marine and inland waters and the condition of the fisheries These are listed in Box 1 below
Box 1 International Conventions treaties and agreements to which Ghana is a signatory 1 International Convention for the Prevention of Pollution of the sea by Oil 21 October 1962 2 Convention on the Africa Migratory Locust 25 May 1962 3 Treaty Banning Nuclear Weapon Tests in the Atmosphere in Outer Space and Under Water 5th August 1963 4 International Convention for the Conservation of Atlantic Tunas 4 May 1966 5 Africa Convention on the Conservation of Nature and Natural Resources 15 September 1968 6 International Convention on Civil Liability for Oil Pollution Damage 29 November 1969 7 International Convention Relating to Intervention on the High Seas in Cases of Oil Pollution Causalities 8 Convention on Wetlands of International Importance Especially as Waterfowl Habitats 2 February 1971 9 Treaty and Prohibition of the Emplacement of Nuclear Weapons of Mass Destruction on the Seabed and the Ocean Floor and in the Subsoil Thereof 11 January 1971 10 International Convention on the Establishment of an International Fund for Compensation of Oil Pollution Damage 18th December 1971 11 Convention Concerning the Protection of World Cultural and Natural Heritage 16 November 1972 12 Convention on International Trade on Endangered Species of Wild Fauna and For a 3 March 1973 13 Convention on the Military or Any other Hostile Use of the Environmental Modification Techniques 10 December 1976 14 Convention on the Conservation of Migratory Species of Wild Animals 23 June 1979 15 Convention for the Cooperation in the Protection and Development of the Marine and Coastal Environment of the West and Central African Region1981(Abidjan Convention) 16 United Nation Convention on the Law of the Sea 10 December 1982 17 Montreal Protocol on Substances that Deplete the Ozone Layer 24 July 1989 18 Convention to Combat Drought and Desertification 19 Framework Convention on Climate Change June 1992 20 Convention on Biological Diversity1992 442 Environmental-Related Conventions Environmentally related conventions ratified by Ghana include
bull International Convention for the Prevention of Pollution of the sea by Oil 21 October 1962
bull Convention on the Africa Migratory Locust 25 May 1962 Treaty Banning Nuclear Weapon Tests in the Atmosphere in Outer Space and Under Water 5th August 1963
bull International Convention for the Conservation of Atlantic Tunas 4 May 1966 bull Africa Convention on the Conservation of Nature and Natural Resources 15 September 1968 bull 992256International Convention on Civil Liability for Oil Pollution Damage 29 November
1969 bull International Convention Relating to Intervention on the High Seas in Cases of Oil
30
Pollution Causalities bull Convention on Wetlands of International Importance Especially as Waterfowl Habitats
2 February 1971 bull Treaty and Prohibition of the Emplacement of Nuclear Weapons of Mass Destruction
on the Seabed and the Ocean Floor and in the Subsoil Thereof 11 January 1971 bull International Convention on the Establishment of an International Fund for
Compensation of Oil Pollution Damage 18th December 1971 bull Convention Concerning the Protection of World Cultural and Natural Heritage 16
November 1972 bull Convention on International Trade on Endangered Species of Wild Fauna and For a 3
March 1973 bull Convention on the Military or Any other Hostile Use of the Environmental
Modification Techniques 10 December 1976 bull Convention on the Conservation of Migratory Species of Wild Animals 23 June 1979 bull Convention for the Cooperation in the Protection and Development of the Marine and
Coastal Environment of the West and Central African Region1981(Abidjan Convention)
bull United Nation Convention on the Law of the Sea 10 December 1982 bull Montreal Protocol on Substances that Deplete the Ozone Layer 24 July 1989 bull Convention to Combat Drought and Desertification bull Framework Convention on Climate Change June 1992 bull Convention on Biological Diversity1992
443 National Legislation
The principal national legislation that affects fisheries in Ghana is listed below
1 Fisheries Regulation 1984 LI 1294 2 Fisheries (Amendment) Regulation 1977 3 Maritime Zones (Delimitation) Law 1986 4 PNDC Law 256 of 1991 5 Fisheries Commission Act of 1993 and 6 Fisheries Act 625 of 2002 7 Fisheries Regulations passed in 2010 LI 1968
Other laws that have relevance to the fisheries sector include
1 Wild Animals Preservation Act 1961 (Act 43) 2 Volta River Development Act 1961 (Act 46) 3 Ghana Water and Sewerage Corporation Act 1965 (Act 310) 4 Oil in Navigable Waters Act 1964 (Act 235) 5 Irrigation Development Authority Decree 1977 (SMCD 85) 6 Minerals and Mining Law 1986 (PNDCL 153) 7 Environmental Protection Agency Act 1994 (Act 490) 8 Ghana Highway Authority Act 1997 (Act 540) 9 Timber Resources Management Act 1998 (Act 547) and 10 Minerals and Mining Act 2006 (Act 703
31
434 Policies A number of Environmental related Policies exist in Ghana however there is no specific policy on the coastal zone These include
bull The National Environment Policy bull National Wetlands Policy bull Agricultural Policy bull Tourism Development Policy bull Land Management Policy bull National Health Policy bull Energy Policy bull Minerals Policy bull Wildlife Conservation Policy
The main thrust and orientation of national policies on the protection management and development of the marine and coastal environment focuses on the following three major areas
bull Integrated coastal zone management and sustainable development bull Marine environmental protection both from land-based activities and from sea-based
activities and bull Sustainable use and conservation of marine living resources (both of the high seas and
under national jurisdiction) Specific plans have been developed to ensure the realization of prudent management of the marine and coastal environment These include
bull Coastal Zone Management Indicative Plan 1990 bull National Environmental Action Plan 1994 bull Draft Integrated Coastal Zone Plan 1998 bull Coastal Zone Profile of Ghana 1998 bull National Oil Spill Contingency Plan with specific reference to the marine environment
2002 bull Environmental sensitivity map of the coastal areas of Ghana 1999 and 2004
Despite the existence of these plans active integration and coordination has been lacking in practice at local level 434 Regulations Though several legislations exist on coastal protection and sustainable development there is no omnibus legislation on the environment Legislation relating to the area include the following
bull Beaches Obstruction Ordinance 1897 (Cap 240) bull The Mineral and Mining Law 1986 (PNDC 153) bull Rivers Ordinance 1903 (Cap 226) bull Land Planning and Soil Conservation Ordinance No 32 of 1953 as Amended by the bull Land Planning and Soil Conservation (Amendment) Act 1957 (No 35 of 1957) bull Maritime Zones (Delimitation) Law 1986 (PNDCL 159) urban planning and
32
bull development bull Town and Country Planning Ordinance (Cap 84) bull Wild Animals Preservation Act Act 235 1964 bull The Towns Ordinance (Cap 86) bull National Building Regulations 1996 (LI 1630) bull Volta River Development Act 1961 bull Fisheries Act 2002 Act 625 bull Fisheries Law 1991 (PNDC 256) bull Fisheries (Amended) Regulations 1977 and 1984
The sustainable use and conservation of marine resources is encouraged through legislation regulations education and awareness creation programmes as well as the enforcement of existing regulations and legislation The legal framework for coastal zones issues and management in the country are contained in the following documents
bull The 1992 constitution bull EPA Act 1994 (Act 490) bull Environmental Assessment Regulations 1999 (LI 1652) bull Local Government Act 1993 (Act 462) bull Environmental Standards and Guidelines bull
In addition there are other specific legal frameworks which include a) The legal framework for Ecosystem Protection which are
bull Wild Animals Preservation Act 1961 (Act 43) bull Wildlife Conservation Regulations 1971 (LI685) bull Wild Reserves Regulations 1971 (LI 740) bull The Wetland Management (Ramsar sites) Regulation 1999 bull Oil in Navigable Waters Act 1964 (Act 235)
b) The legal framework for Fisheries Resources which are bull Fisheries Law 1971 (PNDCL 256) bull Fisheries Act 2000
c) The legal framework for Oil and Gas Industry bull Petroleum (Exploration and production) Law 1984 (PNDCL 84) bull Mineral (Offshore) Regulations 1963 (LI 257) bull Mineral (Oil and Gas) Regulations 1963 (LI 256) bull Oil and Mining Regulations 1957 (LI 221)
d) The legal framework for Tourism Promotion (including coastal tourism) bull Ghana investment Promotion Centre Act 1994 (Act 478) bull Companies Code 1963 (Act 179) bull Free Zone Act 1995 (Act 504) bull Ghana Tourism Board bull Ghana Commission on Culture
44 ACTIVITIES RELATING TO FISHERIES INTERESTS
33
Over the years several activities have been undertaken which are of relevance to protection of the marine environment and fisheries These include
bull Ghana Environmental Resource Management Project in Coastal Wetlands Management Component
bull Gulf of Guinea Large Marine Ecosystem Project bull Fisheries Sub-sector Capacity Building Project bull Establishment of a Protected Wetland Ecosystem on the coast bull Development and Implementation of Oil Spill Contingency Plan bull Monitoring of fish stock levels and associated oceanographic parameters bull Institution of a programme of Monitoring Compliance and Surveillance of the marine
environment bull Development of industrial pollution standards bull Development of University course on Coastal Zone Management bull Increased public education on sound coastal and marine environmental practices
45 RELEVANT INSTITUTIONS With regards to protection management and development of the marine and coastal environment a number of ministries and agencies have been identified as potential stakeholders Those shown with an asterisk are likely to have a particularly active role
bull Ministry of Environment and Science bull The Environmental Protection Agency bull Ministry of Tourism bull Ministry of Local Government and Rural Development bull Ministry of Ports bull District Assemblies bull Ghana Ports and Harbours Authority bull Hydrological Services Department bull Ministry of Food and Agriculture bull Ghana Tourist Board bull Ghana Investment Promotion Centre bull Fisheries Commission Ministry of trade Industries and PSI bull Ministry of Lands and Natural Resources Forestry and Mines bull Ministry of Energy bull Ministry of Health bull Ministry of Education Youth and Sports bull Ministry of Defence bull Ghana Navy bull Ministry of Works and Housing bull Ministry of Women and Childrenrsquos Affairs bull Ministry of Roads and Transport bull National Development Planning Commission bull Council for Scientific and Industrial Research bull Universities and Research Institutions bull Ghana Meteorological Agency bull Town and Country Planning Department bull Water Resources Commission
34
bull Ghana National Petroleum Corporation bull Volta River Authority bull Geological Survey Department bull Forestry Commission (Forestry and Wildlife Division) bull Traditional Rulers and their analogous ministry and laws
Non-Governmental Organisations including Resource Development amp Environmental Oriented Development Organisation
bull Friends of the Earth bull Green Earth bull Wildlife Society bull Recerca e Cooperazione bull Centre for African Wetlands bull And many others
46 PARTNERSHIPS Few formal partnerships exist However support for coastal conservation activities has been received from the private sector as well as from Government Regional and sub-regional collaboration efforts occur at various levels although the level of practical intervention is sometimes limited The science and technology unit of ECOWAS is engaged on issues relating to the management of the Gulf of Guinea In addition a bilateral arrangement exists between Ghana and Cote drsquoIvoire for the management of and datasharing on Sardinella stocks which migrate between the two countries The NEPAD framework among the coastal states of Africa is also developing an interest in marine and coastal management 461 Technical and financial support Ghana receives technical support in the form of training research and project implementation from national bilateral and multi-lateral sources Financing of activities in the sector is primarily supported from the national budget However donor support from both bilateral and multilateral sources has also been obtained for specific programmes such as the World Bank sponsored Fisheries Sub-sector Capacity Building Project UNOPS sponsored Environmental Sensitivity Map for Coastal Areas The Ghana Coastal Wetland Project of the World Bank UNEPrsquos WACAF Programmes and The Darwin Marine Biodiversity of West Africa Project by DFID implemented by the University of Ghana 47 ACTIVITIES Activities undertaken in the country with importance to the marine and coastal area are outlined in the following sections 471 Environment-related activities
bull Ecological Baseline studies of Korle Lagoon (1990-2000) This was carried out to satisfy EIA requirement and as a result pollution status of the lagoon was established
bull Lower Volta Mangrove Project (1996-1998) The objective is to ensure sustainable management of mangrove stands and as such baseline information was documented
bull Save the Seashore Birds Project (1985-1995) This was to protect the seashore birds and as a result conservation awareness of seashore birds was achieved
bull Ghana coastal wetlands management project (1996-1999) In this management of the five coastal wetlands designated as Ramsar Site was put in place
bull Darwin Marine Biodiversity of West Africa Project It is a training project in marine biodiversity assessment
35
472 Social-related activities bull A considerable amount of attention is currently being given to the potential impact of oil-related
development in coastal regions following the publication of Environmental and Social Impact Assessments and Management Plans relating to the Jubilee Oil Field discoveries
473 Coastal area management bull Climate and vulnerability and adaptation assessment on water resources agriculture and the
coastal zone Projects (1997-1999) The projects assessed the vulnerability of the coastal zone to climate change
bull Coastal area management plan for Princess Town (1998-2000) which aimed at providing a plan for the management of Princess Town
bull Keta Sea Defence Project Work (2000-2004) The project aimed at protecting the Keta and its environs from the episodes of erosion faced in the area and also to ensure improvement in environmental and socio-economic conditions at Keta and its immediate surroundings
474 Regional Programmes bull Gulf of Guinea Large Marine Ecosystems Project (1996-1999) The project developed an
effective approach to prevent and control pollution in the Gulf of Guinea and conserve its biodiversity As a result regional institutional capacities were strengthened and also a coastal zone management profile and plans produced
bull UNEP WACAF Projects 1 amp 2 This aims at institutionalising and coordination of national contingency plans monitoring of pollution in the marine environment and control of coastal erosion
475 Other major programmes Other recent programmes and activities in the marine and coastal environments have included
bull Ghana Environmental Resources Management Project in Coastal Wetlands bull Fisheries sub-sector Capacity Building Project bull Establishment of a Protected Wetland Ecosystem on the coast bull Development and Implementation of Oil Spill Contingency Plan bull
48 ONGOING PROJECTS Ghana is currently implementing several projects in the marine and coastal area Some of these projects are linked to developmental projects for which impact assessments are required under the Environmental Assessment Regulations of 1999 Some of the projects are large scale in nature with extensive baseline and monitoring studies like the Keta Sea Defence Project and the West Africa Gas Pipeline project Others are projects being implemented under the auspices of the United Nations agencies and non-governmental organisations include
bull Combating Living Resource Depletion and Coastal Area Degradation in the Guinea Current LME through Ecosystem-based Regional Actions
bull Amansuri Conservation and Integrated Development Project (ACID) bull Danida Water and Sanitation Sector Programme II Support to Integrated Water Resources
Management (IWRM) Component (2004-2008)The Densu Basin aspect of the IWRM component
bull Reduction of Environmental Impact from coastal tourism
bull Bui Hydro Power Project
bull Sea Defence Project at Atorkor
bull Sea Defence Projects in selected towns in the Western Region of Ghana
36
49 CONCLUDING REMARKS
This chapter has highlighted the wide range of conventions laws policies regulations and activities affecting the inland and coastal regions and inland freshwater and marine environment of Ghana It will be important to keep all of these processes and procedures under review as the Fisheries and Aquaculture Sector Development Plan is taken forward to the implementation stage
The main responsibility for ensuring delivery of the Fisheries and Aquaculture Sector Development Programme will rest with the Fisheries Department of the Ministry of Food and Agriculture and the Fisheries Commission supported by the MCS Division and Ghana Navy However a key part of the programme is the development of local co-management arrangements and the Ministry of Local Government and Rural Development and individual District Assemblies will play a key role in helping to form and sustain Community Based Fisheries Management Committees
Over time a significant number of fishermen and individual fish processors are likely to leave the sector as harvesting landing and processing of the catch becomes more efficient Management of these changes especially where disadvantaged and vulnerable sections of the community are affected will need substantial support and investment and a high degree of coordination amongst government ministries and agencies NGOs and international partners to ensure that development assistance is effectively targeted
37
CHAPTER 5 WORLD BANK SAFEGUARD ISSUES
51 INTRODUCTION
The World Bankrsquos proposed funding support to the Government of Ghana covers an initial five yearsrsquo period which could potentially be extended at a later date As the Government of the Republic of Ghana notes in the draft FASDP ldquoimproving the management of the countryrsquos fisheries and ensuring that the impacts on individuals and communities are properly addressed will take 20 or more years to effectrdquo It has therefore been judged important in this report to distinguish between changes that might occur as a direct result of the World Bankrsquos financial assistance thereby triggering the Bankrsquos environmental and social safeguards and changes that could result from longer term adjustments to fisheries and other sectors of Ghanarsquos economy as a result of wider influences by Government other donors and world-wide factors (for example international progress in world trade agreements)
The aim in this chapter is to identify changes which are likely to fall within the purview of the World Banks reputational risks and responsibilities under the first five years of the Fisheries and Aquaculture Sector Development Plan (FASDP) It should be clearly understood that the views expressed are those of the consultancy team and it will be for the World Bankrsquos internal advisors to decide what formal recommendations are made to the World Bank Board
Trends that may emerge in later stages of the implementation of FASDP ndash subsequent to the initial five year period - are discussed in chapter 6
52 THE CURRENT SITUATION
The general status of Ghanarsquos fisheries has been described in Chapters 3 while the legal and policy context has been set out in Chapter 4 The World Bankrsquos investment is being planned specifically to support government policy with the aim of providing a more efficient and better regulated fisheries sector Currently open access is leading to progressive deterioration in fish stocks and lower economic returns Based on many international examples of successful intervention the current proposals (see Chapter 2) are to provide support to introduce formal licensing of all vessels and proper monitoring and control over the seasonal timing and location of fishing activity use of gear and approved nets and self regulation through co-management structures under which the Government and fishing communities will work together to achieve recovery of fish stocks higher income levels for fishers and better returns on catches by reducing post harvest losses and improving processing and marketing operations
53 ANTICIPATED OUTCOMES
It is expected that the proposed reforms and changes will eventually lead to significant improvement in the marine environment restoration of fisheries and enhanced incomes In this respect the provision of grants and loans from the World Bank will bring about major benefits to the economy livelihoods and the environment in the longer term The question that has to be addressed however is - are there likely to be any short term adverse environmental or social consequences from the Bankrsquos own investment strategy Answers are considered in relation to each of the planned components sub-components and activities which are summarised in Table 51 A colour coding and numbering system has been adopted to distinguish those activities that are seen as particularly relevant from the standpoint of the environmental and social assessment Elements highlighted in green are those likely to have positive and beneficial effects on the environment and social conditions those highlighted in orange red have potentially negative or adverse consequences if not handled properly
38
Component 1 Good Governance and Sustainable Management of the Fisheries
Sub-Component 11 seeks to develop the capacity rules procedures and practices that will lead to better governance As such these procedural interventions will have no direct effect on the environment or social conditions of fishing communities However it will be important to ensure that the drafting agencies (government departments and consultants) give due attention to environmental and social objectives during this phase of work Three specific areas are highlighted including undertaking a socio-economic impact assessment with mitigation measures as part of the plan for fishing capacity reduction reviewing the economic and social implications of subsidies and fish import tariffs in the fisheries sector and developing the policy for the development and operation of community-based management networks built around defined fisheries management units
In developing regulations and guidelines it will be important to consider how less able individuals and vulnerable sectors are going to adapt to new systems For example the new regulations on licensing canoes including completion of registration forms the display of registration numbers on vessels and demonstration of basic competence in health and safety standards may prove taxing demands for owners and crew lacking any formal education Similarly legal instruments that are used to remove fuel subsidies or other benefits will need to be carefully explained A socio-economic impact assessment is proposed in the draft PAD to be accompanied by appropriate mitigation measures This assessment should consider amongst other things
bull whether support should be offered and if so under what conditions to any company community or individual who fails to secure a license for a particular class of vessel
bull how the transfer or sale of licenses will be regulated in the wider public interest to ensure transparent processes and avoid the creation of monopolistic and oligopolistic elites
bull who wins and who loses from any planned changes to subsidies and fish import tariff adjustments
bull how the performance of community-based management networks will be judged bull what action will be taken to mitigate the loss of any traditional fishing grounds that become the
subject of marine protected area development or are subject to exclusion zones to protect oil drilling and production platforms
Sub-Component 12 introduces the concept of fishing rights This is to be initiated through a series of four pilot stakeholder-based fishery initiatives and the rolling out of licensing procedures Discussions with stakeholders have made it very clear that the credibility of the entire fisheries policy and programme could be challenged if these pilots do not show positive and constructive ways of moving forward with fisheries reform There is a great deal of distrust for new procedures amongst the fishing communities based on the knowledge that many previous initiatives have failed It is therefore essential that the pilots are led by a strong implementation team are adequately financed and include a credible transparent and inclusive process for debate discussion and consultation Co-operation from the selected communities will be more likely to be achieved if they can see early results in terms of income generating activities
Sub-Component 13 is targeted at adjusting fishing effort and capacity to more sustainable levels and supporting alternative livelihood opportunities These activities are critical in giving effect to the policy decisions that have already been taken to reduce the size of the industrial and semi-industrial fishing fleet and to strengthen the role of the canoe sector Specific measures are proposed for compensating crew members who lose their jobs and for providing training to young men who are willing to transfer
39
out of the fishing sector The scale of this task should not be under-estimated however since there are currently few alternative employment opportunities in the coastal belt for manual workers with low education and skill levels which typify the status of many young fishermen The concept of creating some additional employment with conservation of the coastal littoral and marine ecosystems is strongly supported since this can be linked with development of tourism
Sub-Component 14 is another element that is strongly focused on delivering improved livelihoods with its emphasis on social marketing communication and transparency The focus on stakeholder participation is particularly welcome and should lead to positive response providing it is backed with direct financial support to participating communities
Component 2 - Reduction of Illegal Fishing
There is no Sub-Component 21 within the Ghana Fisheries Programme
Sub-Component 22 aims to develop monitoring control and surveillance (MCS) systems These measures are largely procedural and apart from the relatively small team that will be recruited to operationalise the systems it will have minimal effects on either the environment or social conditions One element that is highlighted in Table 51 relates to provision of facilities and training for participatory coastal surveillance of small-scale fisheries This should have direct and strongly positive benefits for participants and the communities who are enrolled in the training programmes
Component 3 increasing the contribution of the marine fish resources to the local economies
Sub-Component 31 will support the development of basic infrastructure at nine marine fish landing sites and two inland sites The scale of physical construction will be restricted to repair and minor extension of roads and jetties wharves and construction of net mending screens and storage sheds These activities are unlikely to have any significant adverse environmental impacts and should lead to positive social effects
Sub-Component 32 will underpin efforts to improve fish product trade infrastructure information and systems Introduction of new technology for smoking and curing fish and the extension of existing ice preparation plants will start to have positive beneficial effects within the selected communities
Sub-Component 33 provides a modest level of support to marine and inland aquaculture development Aquaculture development should include finalization establishment and enforcement of current draft operational standards to cater for environmental friendliness of fish culture industry for its own survival The main focus will be on developing policy and legal frameworks together with support for stock improvement These measures will have some impact on affected communities in the short term but are clearly aimed at longer term benefits
40
Component 4 Coordination Monitoring and Evaluation and Program Management
Sub-Components 41 and 42 are directed specifically at strengthening the capacity of the Governmentrsquos institutions for national implementation and regional co-ordination As such they will have no direct environmental or social impacts
54 SUMMARY AND CONCLUSIONS
This review of potential environmental and social safeguard issues under the World Bankrsquos targeted programme concludes that there are unlikely to be any significant adverse environmental or social effects as a result of the planned investments
The only possible exception relates to the effectiveness of measures that are put in place under Sub-Component 12 to support pilot stakeholder-based fishery initiatives It is of paramount importance that these pilots are successful and win the confidence of all participants since failure to achieve positive results could set back the entire fisheries programme For this reason it is essential that planning of the pilot initiatives is linked closely with measures for supporting alternative livelihoods and strengthening processing and marketing initiatives under Sub-Components 13 and 14
A number of the planned interventions may have longer term consequences as policies regulations and bye-laws are put into effect but these will be addressed in subsequent work by the Government of Ghana (see Chapter 6)
Table 51 Elements of the World Bank Programme and assessment of potential environmental and social risks
Description of Component Sub-Component and Activities
Measure of Likely Effects
Large (3)
Moderate (2)
Small (1)
None
Beneficial
3
2
1
Adverse
3
2
1
Component 1 Good Governance amp Sustainable Management of the Fisheries
Sub-Component 11 Developing the Capacity Rules Procedures amp Practices for Good Governance of the Fisheries
Reviewing developing programmes and projects designed to support the Fisheries and Aquaculture Development Sector Plan (FASDEP)
Developing an operational policy to enable implementation of the Aquaculture and Fisheries
Plan for fishing capacity reduction (including socio-economic impact assessment and mitigation) 3 2
Commercial vessel and fishing activity licensing plan including allocation criteria rules for transfer of licenses
41
Sector Development Plan and timetable and schedule of license fees
Compliance strategy and plan
Regulations for the management of fisheries including the identification and specification of fisheries management units (ie stocks species areas)
Recommendations for environmental and social safeguards arising from the review of the economic and social implications of subsidies and fish import tariffs in the fisheries sector
3
Policy for the development and operation of community-based management networks built around defined fisheries management units
3
Policy on adaptation strategies for climate change and marine protected area development
2 2
Review of the Ghana Tuna Industry to identify policy or infrastructure needs that threaten Ghanarsquos hub status
Strengthening capture fisheries management systems and capability
Development of fisheries and aquaculture management systems and processes and training
Strengthening fisheries information systems
Installation and operation of fisheries lsquodashboardrsquo database and information collection
Sub-Component 12 Introducing Fishing Rights ($15 M GEF)
Developing 4 pilot Stakeholder-Based Fisheries Management initiatives around defined fisheries units (ie local management initiatives tied to defined fisheries resources including demand-side governance initiatives)
3 2
Introducing and administering a licensing regime (registry establishment training stakeholder education) 2 2
Sub-Component 13 Adjusting Fishing Effort and Capacity to more Sustainable Levels and Supporting Alternative Livelihood Opportunities where Needed
Vessel decommissioning Decommissioning of 60 to 80 industrial trawlers in an environmentally friendly manner
2
Developing alternative livelihoods for crew of decommissioned industrialsemi-industrial
Skills training and small business development training and support for young (18-30 yrs) industrialsemi-industrial crew members willing to transition out of the sector
3
42
vessels
Alternative livelihood development to incentivize voluntary capacity reduction in canoe sector
Alternative livelihoods fund and CDD support to targeted fishing communities
3 2
Marine Resource Conservation
Would include confirming conservation priorities and management regimes and possible provision of support for alternative livelihood options (funded under 133) associated with conservation of coastal littoral and marine ecosystems as well as de facto protected areas associated with the development of oil and gas extraction
3
Sub-Component 14 Social Marketing Communication and Transparency)
Communications stakeholder consultations and awareness raising programs to support fisheries development
3
Component 2 Reduction of Illegal Fishing
Sub-Component 21 does not apply to Ghana
Sub-Component 22 Monitoring Control and Surveillance (MCS) Systems
Developing compliance systems and capability
Development of judicial and policy capacity (training)
Compliance risk assessmentstrategy systems and process development
Enforcement Unit establishment (dedicated facility)
Coastal surveillance stations 2
Facilities and training for participatory coastal surveillance of small-scale fisheries
3
Training for surveillance officers
Operation of aerial and water patrols (vessel leases aerial patrols operational costs patrol vehicles)
Observer program
Compliance education (stakeholder training signage) 1
Upgrademaintenance of the Vessel Monitoring System (VMS)
43
Component 3 Increasing the Contribution of the Marine Fish Resources to the Local Economies
Sub-Component 31 Fish Landing Site Clusters
Product diversificationvalue chain development
9 marine landing sites (basic infrastructure) at Axim Dixcove Fete Jamestown Moree Mumford Senya-Beraku Teshi and Winneba
3 1
2 inland fish landing sites (improved access and berthing infrastructure) at Abotoase and Dzemeni
3 1
2 ports developed (technical studies for 1 new port at Axim and additional berthing space in existing port of Elmina)
3 2
Sub-Component 32 Fish Product Trade Infrastructure Information and Systems
Export certification center development
Fish processing technology improvements 1 1
Technical assistance training and goods to support the National Fisheries Advisory Group
Sub-Component 33 Marine and Inland Aquaculture Development
Developing aquaculture policy and legal framework
Improving genetic quality of Tilapia fingerlings and breedstock
Catalyzing aquaculture development 2
Component 4 Coordination Monitoring and Evaluation and Program Management
Sub-Component 41 National Implementation
Technical assistance for Secretariat to the Fisheries Commission to implement the Project
Sub-Component 42 Regional Coordination
Technical assistance for Regional Coordination Unit at the CSRP support to Fisheries Information Systems (lsquoDashboardrsquo)
45
CHAPTER 6 ENVIRONMENTAL AND SOCIAL ASSESSMENT OF DRAFT FISHERIES AND AQUACULTURE SECTOR DEVELOPMENT PLAN (FASDP)
61 INTRODUCTION
This chapter examines environmental and social issues which need to be considered as part of the overall structural and economic adjustments in Ghanarsquos fisheries sector in the longer term (ie 1-15 years) The assessment deliberately focuses on the longer term because it will take a number of years before current plans start to have their full effect However the same temporal considerations apply to measures that are designed to avoid or mitigate potentially harmful effects so it will be important to start planning remedial actions as part of the joint Government of Ghana and World Bank fisheries programme
611 Key sectors and activities The fishing industry is divided first into marine capture and inland capture fisheries and then aquaculture For each of these three sectors activities are then broken down as follows Marine Capture Fisheries CATEGORY ACTIVITY Stock Management Research Surveillance reef building Harvesting Vessels Gear Skills capacity Marketing Sellers Buyers Processing Fresh fish Sun dried Smoking Freezing Consumers By market sector Support Sectors Boat Canoe Building fuel supply net making kiln construction
refrigeration transport cold store management Legal Enforcement Financing Investment in all elements Infrastructure Harbour wharf processing plant construction
Inland Capture Fisheries CATEGORY ACTIVITY Stock Management Research Surveillance Harvesting Vessels Gear Skills capacity Marketing Sellers Buyers Processing Fresh fish Sun dried Smoking Freezing Support Sectors Boat Canoe Building fuel supply net making kiln construction
refrigeration transport cold store management Legal Enforcement Financing Investment in all elements Infrastructure Harbour wharf processing plant construction
46
Aquaculture and Mariculture CATEGORY ACTIVITY Stock Management Research Surveillance Rearing Roe fingerling production cage -pond rearing Harvesting Vessels Gear Skills capacity Marketing Sellers Buyers Processing Fresh fish Sun dried Smoking Freezing Support Sectors Boat Canoe Building fuel supply cage construction kiln construction
refrigeration transport cold store management Legal Enforcement Financing Investment in all elements Infrastructure Harbour wharf processing plant construction
612 Evaluation Criteria The environmental and social assessment has been undertaken using a matrix (See Annex 114) which analyses the key sectors and activities of the fishing industry and the changes that are envisaged against a set of evaluation criteria Evaluation Criteria are broken down into environmental and social issues distinguishing between beneficial and adverse effects Table 61 below shows the relationship between the groups of criteria Table 61 List of Evaluation Criteria
Environment Social
Positive Adverse Positive Adverse
bull Sea bed rejuvenated
bull Fish stocks recovered
bull Biodiversity enhanced
bull Sea bed degraded
bull Fish stocks reduced
bull Biodiversity reduced
bull Increased harvest (catch volume)
bull Increased catch value
bull Reduced costs of inputs
bull Increased profit
bull Enhanced livelihoods
bull Increased job opportunities
bull Increased local economic multiplier
bull Reduced harvest (catch volume)
bull Reduced catch value
bull Increased costs of inputs
bull Reduced profit
bull Reduced livelihoods
bull Reduced job opportunities
bull Reduced local economic multiplier
The assessment process has involved systematically considering each sectoractivity against the evaluation criteria and recording either positive or negative results by drawing on the judgement of the consultancy specialists The findings are discussed in the paragraphs that follow and are reflected in Table 81 forming part of the Draft Environmental and Social Management Plan
62 DETAILED ASSESSMENT OF THE MARINE AND AQUACULTURE SECTORS
47
TunaIndustrial fleet streamlined and catch per vessel improved At present industrial trawlers have to travel increasing distances to fishing grounds and while the level of catch is remaining broadly static costs are increasing against available economic returns A major shortcoming is lack of investment in re-equipping the aging fishing fleet Many of the 90 vessels that make up this sector are increasingly unseaworthy and need to be replaced with modern trawlers and gear The plan is to buy out owners of substandard vessels by offering compensation at market value based on a full commercial survey Vessels remaining in the fleet will be required to meet exacting standards By reducing the number of old and inefficient boats this will allow each of the remaining vessels to catch a higher proportion of fish The aim is to ensure that Ghana is equipped with the latest vessels and technology in order to preserve the countryrsquos position as the hub of the West African tuna fishing and processing industry (see also the section on canneries below) The effect of these measures on the environment will remain broadly neutral since the same number of fish will be caught Providing other policies and increased surveillance are successful in preventing trawling in inland waters the smaller fleet will have to fish in deep oceanic waters This could potentially transfer some environmental effects on fish populations to other parts of the migratory cycle However this would become part of the international effort through fishing quotas to regulate overall catches Reduction in the size of the industrial fleet will mean that fewer men are needed to crew and service the vessels However in practice many men who work in this sector have only part time work and since a significant percentage of boats no longer put to sea the number of crewmen who will be displaced could be in the range of 1000-30003
It will be important to set up support services for those losing their jobs including retraining and welfare assistance where necessary
Decommissioning will necessitate the sale of seaworthy vessels and their removal from Ghanaian waters Other boats will need to be broken up and scrapped This process requires heavy duty specialized equipment and can release significant quantities of waste oil other toxic chemicals including refrigerants and asbestos used in pipe and engine room cladding Measures will need to be taken to ensure that proper environmental and health safety precautions are taken that decommissioning takes place in properly equipped boatyards and that all waste products are disposed of without environmental risk Cannery sector optimized The Fisheries and Aquaculture Sector Development Plan seeks to maintain the port of Tema as the centre of the Tuna canning industry in Ghana At present a proportion of Ghanarsquos tuna catch is diverted to neighbouring countries due to constraints on processing capacity These limitations include poor port infrastructure ageing equipment and delays in handling catch for some operators due to preferential treatment of vessels that are part-owned by the existing canneries Options for improvement include encouraging upgrading of the capacity of one or more existing canneries or promoting more competition in the processing sector and improving the infrastructure Providing modern building designs and construction techniques are employed and a full environmental assessment is undertaken in accordance with Ghanarsquos EIA regulations there should be no significant environmental or social risks associated with these development possibilities The potential economic benefit resulting from encouraging investment in this sector is very high
Industrial fishing excluded from inshore waters A major longer-term intention under the new fisheries plan (FASDP) is to ensure that existing regulations that restrict industrial and semi-industrial vessels from trawling in inshore waters are properly enforced This requires provision of surveillance
3 Based on an average crew of 20
48
equipment fast patrol vessels capacity building and training and increased staffing within Government agencies together with a full programme of awareness raising training and financial support to local bodies providing self-governance under new co-management services Restriction of industrial trawling in coastal waters will greatly ease pressures on fish stocks and reduce environmental damage to the sea bed In time this should lead to healthier fish population with more fish to be caught by the canoe industry as a result However the task of policing and enforcing regulations will not be easy and will take a number of years to bring into full effect Reduction in fishing activity by inshore trawlers will displace a number of crew members and have a short-term impact on dependent families until these individuals are either absorbed into the canoe fleet or find alternative employment There will therefore be a need to assist genuinely deserving cases where crew members (and their families dependents) need to transfer to other sectors of the economy These measures will only be required in the short term since the anticipated improvement in fish stocks will lead to improved economic performance in the canoe sector within which the bulk of employment exists
Expansion of deep water fisheries The fisheries plan notes that there may be a potential for exploitation or increased exploitation of some deep sea fish resources However the status and population dynamics of some affected species is not well known so any such activities should be scientifically monitored through research and enforced by MCS
Tema Secondi Port infrastructure improvements (equipmentbuildings) Under present conditions the transfer of fish from commercial and industrial vessels to canneries is often delayed by the time taken to offload crates and manouvre within the port area where there are conflicting activities There are also difficulties that arise when vessels owned by the canneries are given priority for landing leaving other boats waiting for many hours which can result in quality deterioration At this stage no details are available about the precise improvements that could be introduced and this will need to be investigated as the fisheries plan is advanced Any environmental effects from infrastructure improvements would be contained within the existing port areas and should be largely positive in reducing fuel (energy) costs and increasing overall efficiency It will however be important to carry out an environmental review of specific development proposals at the design stage especially if these involve plans for any dredging or for altering facilities for discharging waste and disposing of bilge water Both of these activities can have damaging effects on the sea bed (The first through dispersal of silt and sediment and the second through release of potential contaminants) Socio-economic effects from the infrastructure improvements should also be beneficial by removing delays increasing efficiency and reducing waste However there could be some slight reduction in manpower requirements leading to the need for skills retraining Regulating the catch (eg Fishing for selected species reducing juvenile catch to improve value of catch in inshore waters) The fundamental aim of the fisheries plan is to reduce the harmful effects on fish stocks and low economic returns from fish catches by phasing out open access for all and introducing regulation of fishing activity This is to be achieved through close cooperation between the Fisheries Commission Monitoring and Surveillance Unit as well as marine fisheries management division and individual fishing communities working together under a co-management framework The practical details will need to be worked out through each individual co-management group and initially the World Bank is offering to assist in the establishment of four pilots These bodies will test exactly what is required to increase fishersrsquo awareness to build capacity in self regulation and agree on appropriate measures
49
From discussion with stakeholders it is clear that while the broad principles are accepted the majority of the fishing community simply do not believe that the new regulations will be enforced because they have witnessed the failure of so many previous efforts to introduce firm management A major issue for the planned programme is therefore how to change this critical mindset without which very little progress is likely to be made in practice It will be necessary to demonstrate through the pilots that by regulating fishing activity direct benefits will accrue to those participating fishing communities Unfortunately efforts to eliminate harmful practices are unlikely to result in an immediate gain in fish stocks Instead catches are likely to fall in the short term It will therefore be essential to introduce other forms of incentive to cushion short term losses Such measures might include the purchase of new nets and gear for sale at subsidized price to local cooperatives the introduction of cash incentives for canoes demonstrating best practice in the use of gear and nets preservation of the catch using ice and landing and marketing fish of the required size and quality As restriction of open access starts to take effect there should be positive environmental gains in terms of improving fish stocks and less damage of the sea bed On the other hand both fishers and fish processors will feel the adverse temporary effect of reduced catches These social and local economic impacts will need to be monitored closely and assistance provided to help foster alternative livelihoods Cephalopus (Octopus) harvesting encouraged in inshore waters Although most fish species are currently exploited to unacceptably high levels within coastal waters there is a specific opportunity to increase the number of octopus caught by pot fishing This fishery could be developed by both the semi-industrial and canoe sectors Taking octopus in pots would have no adverse physical impacts on the sea bed and could allow very slight expansion in fish species that are preyed on by octopus At the same time it is important to note that there is only limited information on species composition and functioning of selected marine habitats including those of the octopus and more research should be undertaken on this and other species that could be selected for expanded fishing activity There would be clear socio-economic benefits arising from the creation of this new fishery Focusing fish landing at specific landing sites (to improve opportunities for subsequent marketing processing) Plans are already being developed for the enhancement of landing and processing facilities at a number of existing locations along the coast These locations include the construction of harbours at Jamestown and Elmina and development of landing sites at Teshie Ada Axim Dixcove Winneba Mumford SenyaBeraku Gomoa Fetteh Moree Keta Dzemeni and Tapa Abotoase Two sets of issues need to be considered in relation to these improvements all of which affect existing fish landing and processing sites The first is the nature of the physical works and infrastructure and it s potential effect on the marine and terrestrial environment The second is the socio-economic impact Both Elmina and Jamestown are long established fishing ports where the catch is landed either directly onto the beach or shallow wharves It is understood that the primary aim of the improvements will be to increase the area of permanent wharves to make it easier for fish to be offloaded to reduce the time taken in transferring stock to processing plants and to introduce modern technology In the case of other smaller landing sites the scale of improvements will be quite modest involving improvement to existing short stretches of access road the erection of stores for nets and other gear and provision of covered areas to provide shade for net-mending With all proposals for physical infrastructure development there will be a need to consider possible
50
environmental implications Due to the existing nature of these sites there are no major industrial or other commercial processes in the vicinity which could give rise to cumulative impacts including contamination of fish products The scale of plant needed for ice-making and storage and commercial smokeries is commensurate with the artisanal nature of the fishing activity itself and would not give rise to any significant environmental effects on air or water quality Harbour works could potentially involve some small scale dredging (for example the removal of accumulated silt) Where dredging is required it will be important to identify disposal areas (either at sea or on land) where silt can be deposited without damage to sensitive habitats In terms of economic and social impacts it is not clear at this stage who are likely to be the major investors from the private sector although it may be assumed that existing operators who have access to finance will be the main beneficiaries Over time as landing marketing and processing become more efficient it is possible that individuals in the traditional fish smoking sector will lose a significant proportion of their trade as the product switches to fresh or frozen fish sales for transfer to the major urban markets and the beach price for fish rises The draft Ghana fisheries and aquaculture sector development Plan notes in annex 2 that proposed facilities associated with the ports and landing sites may not have support from fish mammies or at least formidable commercial advocates able to resist any opposition from that quarter Inspection of major fish landing areas like Elmina and Sekondi indicates that the existing social and commercial structure of support activities to fish harvesting is very complex and involves almost every member of the community including children and the elderly Such activities include net mending boatbuilding metalworking (for cooking pots stoves and grills supplies (ropes weights tar paint wood) fuel supplies ice crates transport etc Leaders of the fishing community confirmed that in principle the improvements of facilities is welcomed provided that safeguards are in place for those who may lose part or all of their current trading activity through rationalisation Stabilise fleet capacity at a sustainable level Fishery experts consider that there would be significant benefits in reducing the number of canoes from the present 10000-12000 to around 8000-9000 which correlates with the number operating in the mid 1990rsquos when catches were at optimum levels At the same time the Fisheries and Aquaculture Plan stresses that the canoe sector will remain at the heart of the Ghana fishing industry and this has strong political enforcement Consequently there is unlikely to be any enforced reduction in the number of canoes holding licenses and owners of all existing canoes will be able to register their vessels The ability of canoe owners to pay annual licence fees should rise as the overall measures to increase efficiency and improve catches take effect However many people anticipate that over time as the annual cost of holding licenses rises less efficient fishers will sell their licenses (and hence their rights to fish) There may therefore be a de facto reduction in the size of the canoe fleet Even if numbers do not decrease the fleet could be stabilized at its present size by taking a decision not to grant new licences The draft plan discusses the fact that under existing law (section 53) there is a requirement for licenses to be issued on demand (presumably to ensure that Ghanaians are not barred from subsistence fishing) It is argued in the plan that this is a misconception since canoe fishing is largely a commercial activity and it is concluded that lsquoit is therefore essential that the number of canoe licenses can be controlled in future and the legal basis for these controls must be reviewed as a matter of priorityrsquo Decisions of this nature will require the full support of local co-management groups if they are to be effective but committees could easily come under pressure to make exceptions as the coastal population continues to rise and families without alternative livelihoods start lobbying for assistance
51
Accusations of preferential treatment of certain individuals by committees (or committee officials) - possibly linked with suggestions of bribery and corruption -could cause a lot of social tension and start to undermine community trust in the need to work together to improve fisheries management It is therefore most important that the detailed proposals for co-management address this risk and include proposals for mitigating individual hardship of the less advantaged ndash for example by offering voluntary retirement with some form of incentive Influencing marketing to maximise value and reduce post harvest losses (marketing cooperatives strong market structures etc) FAO has estimated that physical post harvest losses in Ghana amount to between 3 and 17 of smoked fish production and 16-20 of gillnet landings The plan notes that introduction of lsquonew generationrsquo small scale fish smokers should be introduced to replace the traditional Chorkor model This would improve fish product quality by eliminating charring of fish over open flames and also protecting operatorsrsquo eyes from the damaging effect of smoke and particles The other major improvement in post harvest value and profits would arise from greater use of ice throughout the supply chain Developing Aquaculture A distinction needs to be made between aquaculture development in ponds and dugouts which are self-contained and fish rearing in cages within open water In the case of farm ponds the commercial rearing of fish is little different to other forms of intensive livestock rearing Providing there is no direct connection to rivers and streams there is little likelihood of interaction between farmed and wild stocks which could spread fish infections and parasites In the case of fish farms in open water (rivers and lakes) there are well known risks of the spread of disease which can arise if overstocking occurs Intensive feeding of large numbers of fish in a confined area can lead to significant deterioration in water quality through the build up of nutrients from wood and waste It is also possible for antibiotics and growth hormones to be dispersed beyond the area of farm cages Genetic modification of farmed fish can also affect the local fish population through escapes All of these issues are capable of being managed and mitigated through good initial planning and design and subsequent maintenance and supervision It will therefore be necessary to develop additional regulations and guidelines specifically for the aquaculture sector 63 SUMMARY OF ENVIRONMENTAL RISKS AND OPPORTUNITIES Review of the full range of governance and development activities suggests that there are no high levels of risk to the marine or littoral environment Successful implementation of the Policy and plan should in fact result in very significant environmental gains Over a timespan of 5-20 years five activities in particular should result in significant improvements in the condition of the sea bed in coastal waters (to a depth of 30 metres) reestablishment of benthic flora and niche habitats increased fish stock and enriched biodiversity These interlinked activities are bull The exclusion of industrial vessels and trawling within coastal waters bull Regulation of fish catches through zonation seasonal control of fishing and standards for vessels
gear bull Stabilisation of the fishing fleet within sustainable harvesting yields bull The adoption of management plans formulated and agreed with full cooperation of local
communities bull The introduction of fishing rights through co-management agreements and bull Well planned consultation and information dissemination throughout the fisheries sector
52
Three components of the development plan have been identified where minor to moderate risk to the physical and biological environment could arise if proper design and implementation standards are not adhered to These relate to bull A potential risk of over-exploitation of new catch species in deep water off the continental shelf if
such development is not accompanied by through research to establish the sustainable yield of target species
bull Strictly localized effects on the physical environment from construction of landing wharves or jetties and other harbour facilities and
bull Infrastructure development at the existing ports of Tema and Takoradi All of these risks are capable of being fully managed by improved governance in the fishing sector and EIA procedures that are well-established in Ghana 64 SUMMARY OF SOCIO-ECONOMIC RISKS AND OPPORTUNITIES Implementation of the Plan Project will bring about substantial change in the fisheries sector and over time increased revenue reduction of post[harvest losses and added value to fish products will bring major economic returns At the same time there will be some individuals who do not participate in direct gains and whose livelihoods could be adversely affected if appropriate safeguarding measures are not put in place The level and extent of these socio-economic risks will be determined by 1 the level of commitment that is entered into by Government and its development partners to
deliver incentives to vulnerable and disadvantaged groups and 2 the speed with which the sector is transformed Rapid change could cause significant
displacement of less-efficient operators especially within the semi-industrial and canoe sector which would have serious ramifications for dependent communities However these effects can be marginalized if the development programme is carefully phased to ensure that alternative livelihood and employment incentives are available
The main risks to local livelihoods relate to the potential for bull loss of employment for crews of unseaworthy obsolete vessels ( from all sectors including
industrial semi-industrial and canoes) that are withdrawn from the fishing fleet because they no longer comply with license regulations
bull the inability of vulnerable and disadvantaged groups including artisanal fishers vendors and individual fish processors in small fishing villages to adjust to new market conditions at selected landing sites
53
CHAPTER 7 ASSESSMENT OF POLICY OPTIONS
71 INTRODUCTION
In order to place the significance of the environmental and social safeguards assessment in context this chapter examines the possible consequences of different policy responses to the existing challenges that face the fisheries sector in Ghana These different policy responses range from a continuation of the status ndashquo effectively a ldquodo-nothingrdquo option (A) to full-scale commitment by all stakeholders to achieving a sustainable fisheries future the ldquoOptimum Solutionrdquo option (C) Various less sustainable outcomes lie in between these two ends of a continuum of policy choices and these are represented by the ldquoWeak Solutionrdquo option (B) 72 OPTION A ndash DO NOTHING Background research and discussion with stakeholders indicates that practical capacity to deliver on clearly stated national goals for sustainable fisheries livelihoods and the reduction of poverty is weak This situation exists despite the fact that Ghana has a strong legal framework for management of its fisheries including the Law Policies and Regulations There is inertia and strong resistance on the part of the majority of players to accept that it is largely their own actions which are responsible for present conditions This in turn leads to the attitude that it is only the lsquoGovernmentrsquo that must act by providing increased subsidies and cushioning the industry against further deterioration in catches Unfortunately there is overwhelming evidence from around the world that where fish stocks are exploited beyond their natural capacity to regenerate this can lead to sudden and near-total collapse Ghana has historically been one of the strongest fisheries in West Africa but the signs are ominous that current levels of exploitation are leading to progressive decreases in annual catches for most species in both marine and inland waters As fishing effort intensifies with an increasing number of all types of vessel using illegal methods and inappropriate gear the distinction between the traditional lsquopeak season and lean season (linked to migration patterns breeding cycles and upwelling) is becoming blurred This is clearly illustrated by a statement from one of Elminarsquos fish mammies ldquowe use to smoke the herring in the peak but now the fishers bring them all the yearrdquo Use of monofilament nets light dynamite and chemicals to obtain fish in the lean season is aggravating a situation where too many boats are chasing too few fish Many fishers blame the reduction of catch on global warming for increasing water temperature the emergent oil and gas industry for restricting access to traditional fishing grounds and industry and urban development for increasing pollution leading to deterioration in water quality Each of these assertions warrants careful consideration but the industry is generally in denial when it comes to the primary fact ndash too many fish including juveniles are caught to allow regeneration of the stock In addition weak governance and lack of resources to ensure implementation of policy result in a situation where the law can be ignored with impunity If collective failure to recognize the seriousness of the current position and lack of commitment to taking hard decisions continues the omens for the future are not good Within a period of 10-15 years fish catches could fall by 50 or more from their present level Impacts on each species would vary and catches of some fish with regional or global migration patterns could remain viable (although this depends on the international conservation effort) On the other hand stocks of fish that provide the mainstay of local food resources herring and sardine could be decimated
54
Complete collapse of all fish species is unlikely but it is possible to envisage a situation where catches might fall below 300000 tonnes a year by 2025 (a reduction of more than 25 from present levels) The most serious consequences would be felt as a result of the social and local economic impact on fishing communities Perhaps 30000 men representing the crews of 3000 canoes and semi industrial boats and 15000 women engaged in marketing and processing would lose their present livelihoods Population migration away from the coast could follow and severe social pressures and local economic hardship This is clearly a ldquoworst caserdquo scenario and if conditions were to worsen gradually it might be possible to intervene but the fact has to be accepted that fish stocks are dynamic and subject to rapid decline (as in the case of the North Sea Herring and Atlantic Cod) 73 OPTION B THE lsquoWEAKrsquo SOLUTION The bleak future painted in Option A is unlikely to arise if the present policy and draft fisheries development plan is followed since these are specifically directed to addressing the major challenges However realization of the aims is dependent upon delivery across a wide range of initiatives by multiple stakeholders The following paragraphs illustrate some of the ways in which delivery of policy objectives might be thwarted These may be summarized as
bull Commitment to good governance and institutional reform bull Political resolve to implement unpopular measures bull Availability of adequate technical and financial resources bull Inertia to necessary changes in fishing practice
Good Governance and Institutional Reform Fundamental reforms are required to fully equip the national fisheries management effort at government level This includes introduction of change management clarification of responsibilities for senior staff rationalization of financial management systems provision of equipment expansion of staff numbers additional training and capacity building As an illustration of the extent of the effort required reference can be made to just one topic area the issue of monitoring control and surveillance At present the Fisheries Commissionrsquos MCS Unit has only 10 employees to oversee implementation of the fisheries regulations throughout Ghana This number will be increased as other institutions are engaged in joint monitoring initiatives but it is obvious that staff numbers and capacity will need to be expanded if regulations on fishing activities are to be affected Enforcement is only one part of the equation however Much greater emphasis will need to be placed on voluntary controls and self-policing at community level through Co-management schemes
Failure to press ahead with governance and institutional reform could delay the process of introducing and registering licenses which represents a crucial first step in moving from open access to managed access in the fisheries sector Given the urgency for action the five years allowed in the current plan for completing the registration process seems very generous Political resolve to implement unpopular measures Stakeholder meetings have confirmed the significance of party political influence as a constraint on achieving progress in the reform of the fisheries sector The offer of incentives like subsidies or the promise of new facilities and equipment are regularly employed by individual politicians to garner votes whether or not these form part of party manifestos Examples have been quoted to the consultants where enabling regulations that might restrict fishing access and prove unpopular amongst the fishing community are quietly ignored and officers may be discouraged from pursuing breaches of the law where the offender has political influence These issues arise with governments of all political
55
persuasions and can apply at all levels from District Assemblies through to regional and national committees
A serious issue with fisheries sector reform is that once actions have been taken to conserve fish stocks it may be years before the full benefits are felt and the results are evident in terms of increased catches This makes it harder for governments to institute unpopular reforms ndash even though these are in the best interests of the nation fishing communities and individuals Fishermen and their families are used to seeing an instant lsquosame day returnrsquo on their catch and are less willing or able than stakeholders in other economic sectors to wait for gradual improvements There is an urgent need to establish cross-party support for the fisheries sector in Ghana and to seek agreements between the main political parties to support established policy and regulations where these are in the interests of delivering sustainable fish stocks Availability of Technical and Financial Resources The process of moving from complete open access to restricted use rights for both marine and inland capture fisheries will take many years to complete Progress will be heavily influenced by the level of political will availability of technical assistance and financial support Existing subsidies (pre-mix fuel and import tariffs) are seen as a deterrent to the encouragement of more efficient business practices However in order to reduce dependencies on these forms of government aid there is also a need to underwrite new forms of economic enterprise by giving help to start-up businesses developing training centres and promoting alternative livelihoods for those individuals who are either displaced or voluntarily give up work in the fisheries sector Inertia to Change Traditional fishing practices are quite literally a way of life for many Ghanaians and have been handed down from generation to generation These traditions are closely interlinked with cultural practices and power and influence resides in specific families with hereditary authority In order to change attitudes and gain acceptance of new approaches to fishing there is a need for a major awareness building and communications strategy targeting in particular the traditional leaders of the fishing industry Without such a plan it will be difficult to break down the internal resistance and inertia towards change The constraints that have been outlined above in relation to the lsquoweakrsquo option are very real and in combination they present a serious barrier to progress It will require real political commitment on the part of Government and strong financial support from international partners to break down these barriers 74 OPTION C THE lsquoOPTIMUMrsquo SOLUTION
The new Draft Fisheries and Aquaculture Plan together with the Act and Policies provide a solid foundation for revitalising the fisheries sector in Ghana However for the reasons discussed in relation to options A and B above there are a number of impediments that need to be overcome In addition to the measures in Option B an ldquoOptimumrdquo solution would also include
A coherent mix of Incentives (carrots) and Regulation (sticks) A top priority in developing existing strategies and plans will be to ensure that measures are in place to offer encouragement and practical assistance to fishers to convert to more sustainable practices while at the same time introducing effective enforcement There are some real challenges with both of these goals
56
New forms of incentive need to be developed to convince boat owners and their crews that it is worth their while to drop illegal methods (dynamiting use of monofilament nets etc) and to reduce the level of fishing effort (through close seasons introduction of restricted zones etc) Without these incentives it is highly unlikely that there will be significant take-up of the fisheries stock management and conservation message Special attention needs to be given to the role of chief fishermen and local community councils in developing effective local policing since it is impractical to rely on a national MCS team to regulate canoe activity in either the marine or inland capture fisheries The national MCS team will have its own responsibilities for policing local and international waters in relation to industrial and semi-industrial sized vessels Integrated Coastal Development The long term success of the fisheries strategy depends upon reducing fishing effort to a level at which catches become both sustainable and profitable for those who remain in the business This in turn requires that those displaced from the industry are able to find gainful employment and livelihoods in other sectors of the economy The fisheries industry is often seen as a separate economic sector which attracts its own funding and support but in order for the necessary reforms to take place these attitudes will need to change A new approach is required to lsquointegrated coastal developmentrsquo following the lessons from integrated rural development Many fishing inland and marine fishing communities are almost wholly dependent on fishing with less than 10 of the local economy being devoted to other industries Reform of the fishing sector therefore requires that as much ndash if not more ndash effort is devoted by government and its international partners to building up complementary economic activities in construction transportation manufacturing food processing environmental conservation and tourism There is a need to explore new state industry partnerships to establish appropriate economic development agencies and to coordinate activities between relevant state institutions ministries and departments under the current decentralisation initiatives with district assemblies taking a prominent role If initiatives of this sort are taken forward it will make the task much easier in persuading conservatively ndashminded fishing communities that they need to simultaneously develop their own entrepreneurial flair and impose their own discipline
57
Chapter 8 DRAFT ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK (ESMF) 81 INTRODUCTION Previous chapters of this report have described the principal environmental and social impacts that are likely to arise from reform in the fisheries sector This chapter sets out the Framework (ESMF) for an Environmental and Social Management Plan (ESMP)The first step has been to outline specific objectives to be achieved through implementation of the ESMF These objectives relate specifically to the issues described in earlier chapters Subsequent sections of the chapter detail the measures which are required to respond to specific areas of environmental and social impact through mitigation and amelioration works They also describe the types and level of environmental monitoring required together with the institutional aspects which need to be improved in order to support the fisheries sector 82 STRATEGY AND OBJECTIVES The basic aim of the environmental and social management plan is to set out guidelines for participatory programs under which members of local fishing communities and civil society in general can become involved in the design and implementation of local fishery co-management maintaining sustainable local livelihoods and achieving local monitoring of fishery efforts The basic principle for future fisheries management is that both marine and inland waters will be demarcated as territories for use rights to fisheries (TURFs) The principal goal of government policy in the fisheries sector is to ensure that the fisheries industry plays an increasingly important role in supporting the growth of the economy as outlined in the Ghana poverty reduction strategy (GPRS II) and the Republic of Ghana fisheries and aquaculture policy This goal will be supported by implementation of the fisheries and aquaculture sector development plan over the next five years In this timescale the aim will be to bull improve management of fisheries the conservation of aquatic resources and protection of the
natural environment bull promote value addition in the fisheries sector and the improvement of livelihoods in fisheries
communities bull encourage sustainable development of aquaculture bull improve the services provided to the fisheries sector by the fisheries commission and supporting
institutions The overall consequences of this strategy and the investments that are being made by the government and its aid partners will be stabilisation of fish stocks and sustainable catch levels a strengthening of the national economy and creation of a more robust fisheries industry with consequent benefits for fishing communities Impact assessment confirms that the result will be significant benefits for the marine environment and local economy However depending on the rate of transition from an open access to a fully regulated market a number of adverse effects could arise unless appropriate mitigation measures are put in place Specific issues which require attention in this plan are listed below bull potential risks of environmental degradation through development of new fishing targets in
deep water
58
bull localised environmental impacts at construction sites bull loss of resources for individual operators due to restricted or controlled access to fishing
grounds bull displacement of labour from crews of vessels that are withdrawn from the industrial and semi-
industrial fleet bull Decommissioning of obsolete industrial vessels may not necessarily lead to recovery of fish
stocks Catch Per Unit Effort (CPUE) may increase This could lead to loss of livelihoods to crew members and the owners of the decommissioned vessels it could increase catch for the few vessels remaining in the system
bull increase production costs due to idling time in closed seasons for fishing bull exclusion of some groups and individuals seeking entrance to the industry following completion
of licensing bull concentration of processing and marketing at selected landing sites leaving Fish Mammies and
their dependents in other smaller fishing communities at an economic disadvantage bull displacement of traditional canoe building and other ancillary support industries by more
efficient and modern methods of construction and the inability of some workers in these trades to train and re-skill in the use of modern materials
bull lack of employment opportunities in alternative sectors The ESMF will set out specific actions to address these concerns through a coordinated set of interlinked proposals as follows 1) Preparation of local management plans and close surveillance of all new fishing enterprises in
deep waters
2) Preparation of environmental protection clauses to be included in all contracts and agreements for physical development work
3) Regular inspection by environmental protection officers of construction work at harbours and landing sites
4) Establishment of community management plans to provide support to those groups and individuals who are adversely affected by any of the measures listed above
5) Creation of community liaison groups to actively support community development alternative livelihoods and conversion to new areas of economic activity for those Fisher families or individual fishers who are adversely impacted
6) Introduction of skills training centres and business advice for small and medium enterprise development
7) Establishment of a coastal development agency drawing on the resources of the ministry of local government agriculture and tourism (others to be added) to coordinate integrated projects and initiatives for economic development linked with the existing coastal zone management plans
8) Creation of a liaison group between the government of Ghana and its international development partners to ensure that investment in the fisheries sector is targeted in the most effective way to deliver plan objectives and avoid duplication of effort
59
83 COMPONENTS OF THE ESMF The following paragraphs provide a summary of the draft ESMF 831 Local Management Plans these plans will be prepared for discrete zones of influence around specified fishing settlements Each plan will contain the same standard list of relevant activities that are to be monitored 832 Environmental Protection In relation to construction activity a checklist will be prepared identifying precisely what level of environmental scrutiny is required for specific types of development This checklist will be prepared by the Fisheries Commission with the support and advice of the Environmental Protection Agency 833 Small-Scale Project Development and Livelihood Restoration a list of potential micro-projects will be prepared by the Fisheries Commission which are regarded as suitable for support funding Demand for these micro-projects will be determined at the local level (ie in villages and fishing communities) Applications for funding of micro-projects will be submitted to the community liaison group for vetting and recommendation based on pre-established eligibility criteria Recommended projects will be referred for formal approval at national level (or through the Coastal Development Agency) 84 POTENTIAL PROJECT IMPACTS ON ASSETS AND LIVELIHOODS The project will have some adverse impacts on assets and livelihoods Therefore provisions will be made under the ESMF to minimize all such impacts including those of socio- economic significance and on any environmentally sensitive sites Provisions are also made in the RPF to accommodate all potential situations including cases that may entail actual displacement and livelihood restoration assistance in accordance with the Governmentrsquos policy and World Bank Policy on Involuntary Resettlement OP412 (see Chapters 9 and 10) The potential social and environmental impacts associated with the project (see Chapters 5 and 6) are summarised in Table 81 and the approach to related mitigation measures is defined in section 85 and Table 82 below
Table 81 Potential Environmental impacts and Social issues
Type of Activity Description Environmental Significance
Social Significance
Decommissioning of obsolete industrial vessels
Scrapping of vessels may release toxic waste (contaminated oils asbestos pipe wrapping and insulation etc)
Contamination of landfill dumps
Related health hazards
Laying off of work force Recovery of fish stocks in areas currently over-fished by trawling
Decommissioning of excessovercapacity would result in loss of livelihoods for crew members
60
Plan for fishing capacity reduction
introduction of licensing system for canoes and enforcement of licensing system for semi industrial vessels
Reduced catch from the decline in the use of prohibited fishing methods (activities) as stipulated in the Fisheries Regulation 2010 (LI1968) eg use of light dynamite etc
Reduction in fishing capacity should lead to significant recovery of fish stocks with long term benefits for all
Short term reduction in fishing effort and increased regulation may prejudice vulnerable sectors (illiterate elderly fishers) Capping on new entrants may remove the safety net opportunity offered by fisheries to would-be fishers who may be without alternative livelihoods
Harbour development and landing site improvements
Construction of access road improvements Erection of fish processing and ice making plant The Project could give rise to a small level of physical displacement for some sectors of individual communities
Removal of shelters homes Displacement of boat repair and trading sites for local community
Possible non-voluntary resettlement including vulnerable groups (women children and the elderly)
Adaptation Strategies to climate change
Introduction over time of regulations relating to fishing activity in rivers lakes estuaries lagoons and lsquoareas of upwelling affected by climate change
Measures to combat tackle rising temperature and other climate induced changes should ameliorate environmental impacts
Both beneficial and adverse effects may result from changes in climate (eg faster growth rates from higher water temperature spread of invasive species)
Establishment of exclusion zones ndash oil production and marine protection areas
Restrictions on fishing in oil production areas and marine protection areas
Positive ndash recovery of fish stocks but also potential risks of pollution from oil leaks and human waste
Temporary loss of livelihood for those fishers displaced from lsquotraditionalrsquo fishing grounds
Development of Co-Management System
Creation of 4 pilot Stakeholder ndashbased Fisheries Management Initiatives
Demonstration of practical benefits for the marine environment resulting from elimination of damaging practices
Greater social cohesion and sense of purpose established
61
Type of Activity Description Environmental Significance
Social Significance
Support for PAPs Establishment of enterprise training programmes
Development of criteria for defining Project Affected Persons (PAP) Development of skills training schemes enterprise allowances alternative livelihoods fund
Major benefits for PAPs ndash but scope for misinterpretation mismanagement of programme at local level Jobs created under social significance should be familiar to the fishers ie things they will be willing to do
Developing Compliance Systems
Establishment of enforcement unit and development of facilities and training for participatory coastal surveillance of small-scale fisheries
This component will greatly improve controls over environmentally unfriendly damaging activities
A number of new jobs should be created under this programme
Improvements in fish processing technology
Development of more efficient fish processing plant
This measure should reduce significantly the proportion of fish lost or degraded post harvest Improved fish processing technology will also reduce wood used from the forest as firewood for fish smoking
Potential displacement of vulnerable groups (women children and the elderly)who currently participate in fish drying curing using basic equipment
Construction of fish ponds
Expanding areas of dug-outs and other farm ponds
Small scale impacts on vegetation stream flow
Displacement of existing land users
Catalysing aquaculture development
Encouragement of larger fish farming enterprises Installation of fish cage aquaculture
Localised deterioration in water quality increased nutrients leading to eutrophication potential spread of fish parasites disease
Potential competition with free capture fisheries displacing vulnerable groups in existing fishing villages
62
85 PROPOSED MITIGATION MEASURES AND COST ESTIMATES Mitigation measures The potential environmental and social impacts to be addressed within the context of preparing this Environmental and Social Management Framework are generalized as shown in Table 82 below It is not possible at this time to prepare specific mitigation measures It is expected though that environmental and social assessment studies will be carried out within specific localities as and when required The framework for compensationresettlement (See Chapters 9 and 10) will then be applied incorporating (1) specific institutional arrangements (2) resettlementcompensation eligibility criteria (3) implementation procedures (4) financial responsibilities and (5) monitoring and evaluation plan Livelihood restoration measures Furthermore the livelihood restoration measures will consider issues such as
(1) income levels of affected persons
(2) other non-monetary sources of livelihood
(3) constraints and opportunities for income generation
(4) number of persons not able to revert to previous occupation and
(5) existing skills of affected persons
Table 82 Proposed mitigation measures for some potential impacts
Type of Impact Description of mitigation measures
1 Decommissioning of obsolete industrial vessels
a) A register will be prepared of all industrial vessels that are due to be decommissioned recording the owner and location of each vessel b) A system will be introduced for tracking progress on decommissioning including the means of disposal and measures taken to dispose of all potentially toxic or hazardous materials c) Persons who lose their job or livelihood as a result of a decision to decommission any particular vessel will be entitled to benefit from the skills training schemes enterprise allowances alternative livelihoods fund being developed
2 Plan for fishing capacity reduction
a) A full Social and Environmental Impact Assessment will be carried out on the Plan for fishing capacity reduction and appropriate measures for ameliorating and mitigating adverse effects on affected sectors of the community and PAPs will be incorporated in a revised edition of this Fisheries Environmental and Social Management Framework
63
3 Harbour development and landing site improvements
a) All harbour development proposals will be subject to Environmental and Social Impact Assessment (ESSA) in accordance with EPA Regulations b) Proposals for improvement of individual landing sites will be assessed in accordance with the checklist (832) and submitted to EPA for a ruling on the level of environmental assessment that is required which will depend on the nature of the intended works
4 Adaptation Strategies to climate change
a) An adaptation Strategy shall include proposals for mitigating any impacts on the environment or social welfare of local communities
b) Any strategy for responding to potential effects of climate change on the fisheries sector will be submitted to EPA for review to determine whether an SEA or EIA is required
5 Establishment of exclusion zones ndash oil production and marine protection areas
a) Proposals for restricting access of fishing vessels to oil production areas and marine production areas shall be subject to an Environmental and Social Assessment which shall be submitted for approval to EPA b) In the event that restrictions are likely to adversely affect fishersrsquo livelihoods the provisions set out in 7 below will apply
6 Development of Co-Management System
a) Development of co-management systems will require full cooperation and engagement of all stakeholders In the unlikely event that the provisions of any scheme are challenged by local communities there shall be a right of appeal to the Minister of Food and Agriculture and the Fisheries Commission acting jointly
7 Support for PAPs
Establishment of enterprise training programmes
a) Identification of vulnerable people including women children and the elderly and identification of the cause and impacts of their vulnerability shall be established through direct interviews and procedures to be developed as part of 6 above b) A high priority within the Fisheries and Aquaculture Sector Development Plansrsquo first five year programme will be the development of specific proposals for the establishment of skills training programmes and the establishment of enterprise allowances and an alternative livelihoods fund c) The measures outlined in 7b) above will be targeted specifically at PAPs and vulnerable sectors of the community
8 Developing Compliance Systems
a) All proposals for securing compliance with fisheries regulations shall be subject to review by a fisheries stakeholder committee to be established by the Fisheries Commission with the remit of ensuring that the measures themselves and penalties for failure to comply are commensurate with the ability of offenders to make restitution and do not unfairly penalize vulnerable sectors of the community
9 Improvements in fish processing technology
a) All plans and proposals for the introduction of new fish processing technology shall be published and shall include a statement on the likely impact of the project on existing processors within the local community
64
b) Any members of the public who consider they are unfairly disadvantaged by proposals for the introduction of new technology may apply to the local co-management committee to determine whether or not they fall within the category of PAP (see 6 and 7 above)
10 Construction of fish ponds Proposals for the construction of new fish ponds shall be assessed in accordance with the checklist (see section 832)
11 Catalysing aquaculture development
a) All proposals for aquaculture development shall be in accordance with the provisions laid down in Local Management Plans applying to specific TURFs
65
