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E971 THE UNITED REPUBLIC OF TANZANIA Ministry of Education And Culture SECONDARY EDUCATION DEVELOPMENT PROGRAM (SEDP) ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK (ESMF) May 8, 2004 FILE COPY Public Disclosure Authorized Public Disclosure Authorized Public Disclosure Authorized Public Disclosure Authorized Public Disclosure Authorized Public Disclosure Authorized Public Disclosure Authorized Public Disclosure Authorized

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E971THE UNITED REPUBLIC OF TANZANIA

Ministry of Education And Culture

SECONDARY EDUCATION DEVELOPMENT PROGRAM(SEDP)

ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK(ESMF)

May 8, 2004

FILE COPY

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TABLE OF CONTENTS

EXECUTIVE SUMMARY ................................................................ i

The National Environment Management Council (NEMC) .................... .................. iiiThe Regions ....................................................... iii

The Districts ........................................................ iii

The School Boards ....................................................... iii

1. INTRODUCTION .1

2. DESCRIPTION OF THE PROGRAM .2

3. BASELINE DATA .6

The Bio-Physical Environmental Features .6The Key Social Environmental Features .8Characteristics of Poverty .9

4. DESCRIPTION OF THE WORLD BANK'S SAFEGUARD POLICIES .11

Environmental Assessment (OP4.01, BP 4.01, GP 4.01) .12

Involuntary Resettlement (OP/BP 4.12) .13

5. DESCRIPTION OF THE ADMINISTRATIVE, POLICY, LEGISLATIVE ANDREGULATORY FRAMEWORK ............................................................... 15

Administrative Structure for the Education and Training Sector .............................. 15The School Calendar ........................................................ 15

The Policy Framework for the Education and Training Sector ................................. 15

The Policy Framework for Decentralization by Devolution ...................................... 16The Legislative and Regulatory Framework for Education and Training ................. 17

The Legislative and Regulatory Framework for Decentralization ............................. 18Management and Administration Framework for the Environment .......................... 18

The Office of the Vice President ........................................................ 18

The National Environment Management Council (NEMC) ............................... 19Environmental Units ........................................................ 19District Environment Unit ....................................................... 19

The EIA Process in Tanzania ........................................................ 20

Extent of public participation ....................................................... 21Policy Framework for the Management of the Environment ..................................... 21Legislative Framework for the Management of the Environment ............................. 22Act Or Policy Key Elements Implementing Authority .............................................. 23International Conventions ........................................................ 25Membership of International River Basin Commissions ........................................... 25

6. DETERMINATION OF POTENTIAL ENVIRONMENTAL AND SOCIALIMPACTS ............................................................... 26

Potential Environmental Concerns and Impacts ....................................................... 26Generic Environmental Concerns ....................................................... 26Positive Environmental Impacts of the SEDP .................................................... 32Potential Adverse Environmental Impacts from the SEDP ................................ 32

Potential Social Concerns and Impacts ....................................................... 32

Positive Social Impacts from the SEDP ....................................................... 33

Potential Adverse Social Impacts from the IRCBP ............................................ 34

7. INSTITUTIONAL ASSESSMENT AND FRAMEWORK FOR ENVIRONMENTALAND SOCIAL MANAGEMENT ...................... ................................................ 35

Institutional Roles and Responsibilities .............................................................. 35The Ministry of Education and the Presidents Office - Regional Administrationand Local Government .............................................................. 35The National Environment Management Council (NEMC) ............................... 35Local Government Authorities .............................................................. 35The School Boards .............................................................. 36

Capacity Assessment to Perform these Roles ..................................................... 36

Training Needs .............................................................. 37Training Needs .............................................................. 38

_ Proposed Training Program .............................................................. 38

8. ENVIRONMENTAL AND SOCIAL PLANNING, REVIEW AND CLEARINGPROCESS FOR THE SECONDARY SCHOOLS CONSTRUCTION PROGRAMFUNDED UNDER THE SEDP ....................................................................... 39

Environmental and Social Management Process ....................................................... 39

9. MONITORING PLAN .45

Monitoring Roles and Responsibilities (refer to Fig. 8.1) .46School Boards (SB's) .46The Local Government Authorities (LGAs) .47The National Environment Management Council (NEMC) .47The Ministry of Education and Culture (MOEC) .48Monitoring Plan (Table 9.1) .48Costs for Implementing the Monitoring Plan .51

10. STAKEHOLDER CONSULTATIONS .52

ANNEXES ....................................................................... 53

Annex 1.0 World Bank Environmental and Social Safeguard Policies Summary ..... 54Annex 2.0 Environmental And Social Screening Form ............................................. 57Annex 3.0 Typical Checklist to Identify Impacts and Mitigation Measures ofConstruction and/or Rehabilitation of Tanzania Second Education DevelopmentProgram (SEDP) .............................................................. 63Annex 4.0 Environmental Mitigation Plan for SEDP ................................................ 65Annex 5.0 Environmentally Sensitive Areas ( ESA's) and Ecosystems .................... 66Annex 6.0 Environmental And Social Appraisal Form ............................................. 67

EXECUTIVE SUMMARY

1. Education is one of the priority sectors specified in the Tanzania DevelopmentVision 2025 and the PRS. Within this context, the government is deepening acomprehensive Education Sector Development Program (ESDP). The ESDP has definedthe following general priorities:

* Priority in spending on basic education;* Improvement in equitable access to quality secondary education;* Demand-driven and market-oriented post-secondary and higher education; and

* Institutional development to improve sector management and strengthenimplementation capacity.

2. As part of the ESDP, the Government of Tanzania has prepared the SecondaryEducation Development Program (SEDP). The Objective of the SEDP is to promoteeconomic and social development and reduce poverty through human resourcedevelopment at the secondary level, especially for disadvantaged groups. The specificobjectives of the SEDP are:

* To increase the proportion of the relevant age group completing secondaryeducation, especially underserved groups.

* To improve learning outcomes of secondary students, especially at the lowerlevel.

* To enable the public, including local authorities and private sectors to managesecondary education effectively.

3. To achieve these objectives, the program is structured into specifically linked sub-

component activities per specific objectives as follows:

* Objective 1: Increase the proportion of the relevant age group completingsecondary education, especially underserved groups.(indicator: achievement of targeted enrollment completion ratios by age group forlower and upper secondary).

* Objective 2: Improve learning outcomes of students, especially at lowersecondary level.(indicator: raised educational attainment of students as shown by continuousassessments and performance on public examinations).

* Objective 3: Enable the public administration to manage secondaryeducation effectively.

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(indicators: authority devolved and exercised well at Regional, Local GovernmentAuthorities (LGAs) and school levels; better central policy development and

standards setting for cost-effective delivery of quality of secondary education, and

improved oversight).

4. Under Component 1 (Objective 1), financing will be made available for the

construction of new secondary schools and the expansion and rehabilitation of existing

secondary schools, inter alia.

5. However, since the exact locations for these new schools were not identified at

the time the SEDP was being prepared, the Laws of the United Republic in Tanzania and

Operational Policy 4.01 of the Bank require the Government of Tanzania to prepare an

Environment and Social Management Framework (ESMF) which is to establish a

mechanism to determine and assess future potential environmental and social impacts of

all program activities to be financed under SEDP. This will help to set out mitigation,

monitoring and institutional measures to be taken during implementation and operation of

the program activities to eliminate adverse environmental and social impacts, offset them,

or reduce them to acceptable levels.

6. The Government will disclose this document in country as a separate and stand

alone document so that it is accessible by the general public, local communities, potential

project-affected groups, local NGO's and all other stakeholders as well as at the World

Bank Infoshop.

7. The key highlights in this ESMF are as follows:

* Detailed and comprehensive environmental and social baseline data which will

provide the environmental and social management process with key baselineinformation when identifying adverse impacts. The information contains data on

Tanzania's bio-physical environmental features such as its ecosystems, geology,hydrology in terms of ground and surface water resources, major and sensitivewetlands, flora and fauna. On social baselines the report discusses the main

features of Tanzania's demographics, public health features and poverty.

* Table 5.1 presents a summary of the requirements of the World Bank OP 4.01

Environmental Assessment and OD 4.12 Involuntary Resettlement.

* The administrative, policy, legislative and regulatory framework in Tanzania for

Education in particular and for environmental management in general is presentedin chapter 6.0.

* Generic potential adverse environmental and social concerns and impacts from

anticipated program activities with root and immediate causes is presented indetail in Section 7.0

* The roles and responsibilities of key institutions and players for the purposes of

this ESMF are discussed in 8.0.

.1.

8. Implementation of the SEDP will be coordinated by the Ministry of Educationand Culture in accordance with the ESDP structure.

THE NATIONAL ENVIRONMENT MANAGEMENT COUNCIL (NEMC)

9. The NEMC is responsible for ensuring that all development projects andprograms in Tanzania comply with all relevant environmental laws. This ESMFrecognizes that the NEMC has a significant role to play in the SEDP. This role would beto provide on the ground ESMF performance reviews/audits both for enforcementpurposes, but more importantly to reinforce capacity for the ESMF implementation at alllevels. The NEMC would also provide periodic monitoring to ensure no adversecumulative impacts from the school construction program at the national level and will

provide oversight and technical assistance to the Local Government Authorities when

required.

The Regions

10. The main role of the Regions in this ESMF would be limited to coordinating theplanning activities of their Local Government Authorities by consolidating the DistrictSecondary School Development Plans (DSSDP's) into Regional ones (RSSDP) before

they are submitted to the MOEC for approval for funding.

THE DISTRICTS

11. The Local Government Authorities would be required to review and clear the

environmental and social management process, required of the School Boards, prior to

funding the construction program.

12. The Local Government Authorities would be responsible for carrying out the

following: (i) ensuring the districts school construction program comply with Tanzania'senvironmental laws and requirements, and the World Bank's triggered Safeguard Policies(ii) receiving, reviewing and commenting, where necessary and clearing of School

Boards completed environmental and social screening forms and checklists (iii) carrying

out a regular and intrusive monitoring regime during the planning, implementation,construction, operations and maintenance stages of the schools (iv) for preparing periodic

monitoring reports on the school construction program at all stages of operations and tosend these reports on a regular basis to the MOEC as part of other SEDP reports (v) to

comply with (consistent with national laws) the directives of the government (vi) toissue directives to the School Boards consistent with national laws on environmentalrequirements.

THE SCHOOL BOARDS

13. The School Boards will be responsible (i) for complying with all national lawsregarding the environment and with all social/poverty guidelines, parameters and targetsset by the program, and of all triggered World Bank Safeguards policies, (ii) toimplement their school construction program consistent with the provisions of thisESMF, implementing, inter alia, all appropriate mitigation measures identified in their

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completed environmental and social screening form and checklist into the constructionplanning cycle, technical and engineering designs and drawings, and civil workscontracts, etc. (iv) to ensure that these mitigation measures are complied with duringconstruction and post construction (i.e. operations) stages of their activities, by selfmonitoring of their activities and by periodically reporting to the Local GovernmentAuthorities (v) to maintain a budget to implement the appropriate maintenanceprocedures and practices for the operation of their school, to ensure relevant mitigationmeasures identified in the environmental and social screening form and checklist areimplemented and sustained in the sub school construction program and (vi) to complywith any directives that may be issued from time to time from the government.

14. The Environmental and Social Management Process contains the following keysteps;

Step 1: School Boards (SB's) will screen their own development activities toidentify adverse environmental and social impacts using the screeningform in Annex 2 and the checklist in Annex 3.

Step 2: Then the SB's will introduce into the sub project design the requiredmeasures to mitigate impacts identified from use of the screening formand checklist before submission of the sub project design to theirrespective Local Government Authorities for review and subsequentenvironmental and social clearance.

Step 3: The Local Government Authorities will review and clear the sub projectsby ensuring sub project designs have identified environmental and socialimpacts, mitigated these impacts and have monitoring plans andinstitutional measures to be taken during implementation and operation.

ESMF implementation will be integrated into SEDP activities to be financed throughDevelopment Grants at the school level and monitoring, supervision and capacitybuilding at regional and central levels.

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1. INTRODUCTION

1.1 Part of the SEDP resources will be used to finance the construction of newsecondary schools and the expansion/rehabilitation of existing secondary schools, interalia.

1.2 However, since the exact locations for these new schools were not identified atthe time the SEDP was being prepared, the Laws of the United Republic in Tanzania and

Operational Policy 4.01 of the Bank require the Government of Tanzania to prepare anEnvironmental and Social Management Framework (ESMF) in order to establish amechanism to determine and assess future potential environmental and social impacts ofall program activities to be financed under SEDP. This will help to set out mitigation,monitoring and institutional measures to be taken during implementation and operation ofthe program activities to eliminate adverse environmental and social impacts, offset them,or reduce them to acceptable levels.

1.3 Furthermore, the GoT is also required to prepare a Resettlement PolicyFramework (RPF) to address the needs of those who might be affected when a schoolconstruction/rehabilitation causes the involuntary taking of land and other assets resultingin: ( a) relocation or loss of shelter, (b) loss of assets or access to assets (c) loss of incomesources or means of livelihoods, whether or not the affected person must move to anotherlocation. The RPF has been prepared as a stand alone and separate document.

1.4 The GoT is further required to disclose both documents (the ESMF and the RPF)in-country as two separate and stand alone documents so that they are accessible by thegeneral public, local communities, potential project-affected groups, local NGO's and allother stakeholders as well as at the Infoshop of the World Bank.

1.5 Since the location of the schools, which are to be decided using the results of aschool survey exercise, and requests from local communities through their LocalGovernment Authorities, and Regions, has not yet been decided, each location that issubsequently identified and approved by the Local Government Authorities would besubjected to environmental and social planning prior to approval.

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2. DESCRIPTION OF THE PROGRAM

2.1 The Development Objective of the Secondary Education Development Program(SEDP) is to promote economic and social development and reduce poverty throughhuman resource development at the secondary level, especially for disadvantaged groups.

2.2 The specific objectives of the SEDP are:

* To increase the proportion of the relevant age group completing secondaryeducation, especially underserved groups.

* To improve learning outcomes of secondary students, especially at the lowerlevel.

* To enable the public, including local authorities and private sectors to managesecondary education effectively.

2.3 To achieve these objectives, the program is structured into specifically linked sub-component activities per specific objectives as follows:

* Objective 1: Increase the proportion of the relevant age group completingsecondary education, especially underserved groups.(indicator: achievement of targeted enrollment completion ratios by age group forlower and upper secondary).

Sub-Obiective la: Increase enrollments.

1. Provide development grants to rehabilitate and expand existing public schools(government schools, assisted schools and community schools), and constructionof new community schools in underserved areas as determined by school mappingand other indicators. In this context existing underutilized training institutionscould be converted to secondary schools.

2. Provide incentives for expansion of private (non-public) schools that meetagreed criteria.

3. Provide incentives for expansion through development and capitation grants,indexed for disadvantaged groups, to subsidize non-salary recurrent expenditures,textbooks and equipment.

4. Expand the output of trained secondary teachers, including as necessary anemergency program for lower secondary teachers.

5. Provide trained teachers with incentives to work in underserved areas.

6. Expand access to secondary school equivalency programs for youth and adultsunable to take complete secondary education previously.

7. Experiment with appropriate ICT and distance learning technologies toaccommodate children in remote and underserved areas.

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Sub-Objective Ib: Improve equitable access and output in secondary educationamong geographical areas, income groups and between genders.

1. Identify underserved areas through school mapping and other indicators (to bedefined) as a basis for financial assistance.

2. Provide targeted scholarships for low-income groups through means testing,including for females at upper secondary level where they are under-represented.

3. Develop and adopt specific anti-dropout programs (e.g. parental awareness) forvulnerable groups (e.g. parental awareness campaigns, targeted scholarships, extrateaching support).

Sub-Objective Ic: Reduce the cost per student on households and the publicsector by public recurrent costs per student (economizing on capital andrecurrent expenses).

1. Adhere to minimum school and class sizes to maximize use of capacity (in part,through school mapping that will facilitate well situated sites to encourage dayschooling at lower costs).

2. Rationalize teacher deployment - increasing students per teacher and teacherworkloads.

3. Reduce the number of subjects taught in lower and upper secondary toconcentrate on core subjects.

4. Reduce the unit costs of textbooks through appropriate methods, such ascompetitive selection and procurement.

Objective 2: Improve learning outcomes of students, especially at lowersecondary level.(indicator: raised educational attainment of students as shown by continuousassessments and performance on public examinations).

1. Increase the teaching abilities of the teacher force and improve classroomteaching practices. Steps include:* Improve pre-service teacher training at both diploma and graduate levels,

through a program that focuses on pedagogical effectiveness and contentmastery.

* Achieve better school-based professional development of teachers byinstalling a system of recurrent in-service training for teachers, with prioritygiven to language, mathematics and sciences, and techniques for teachingweak learners, continuous student assessment, promoting active participationof learners and effective use of classroom time on task. This would includereform of the system of school inspection to support quality assurance.

* Use appropriate types of distance teaching and ICT (CDs, videodisks, e-learning) for teacher training and upgrading teacher qualifications.

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2. Revise curricula, improve the design of core subjects, update the content of thesyllabuses and improve learning through active learning, practical work, problemsolving, individual projects and teamwork.

3. Improve the quality and availability of other inputs, including textbooks,laboratories and libraries. Develop, procure, and distribute textbooks andteaching materials.

4. Reform examinations and assessments through better design and evaluation oftests, and better training of test developers and moderators.

5. Experiment with establishment of community e-learning centers in selectedsecondary schools (e.g. sponsorship of participation in Africa's SchoolNet).

Objective 3: Enable the public administration to manage secondaryeducation effectively.(indicators: authority devolved and exercised well at district and school levels;better central policy development and standards setting for cost-effective deliveryof quality of secondary education, and improved oversight).

1. Enhance accountability of educational management to stakeholders by devolvingauthority to lower levels in the system (from central to district and schools). Stepsinclude:

* Adopt policy change adopted for devolution, and adapt the regulatoryframework.

* Undertake organizational development tasks at various levels, includingoversight.

* Design new financial management system for financial flows and devolvedbudget funds.

2. Build management capacity for the new roles and functions. Steps will include:

* Analyzing training needs of current management staff, including schoolheads.

* Designing and implementing management development programs forheadmasters and school boards at institutional level, inspectors, intermediateand central level managers, including networking arrangements for sharing ofexperiences among colleagues. Within the overall program, give priority totraining for school heads as the lead force for school improvements.

3. Develop capacity for schools and districts to prepare secondary educationdevelopment plans.

4. Design and implementation of performance-based contracts for schoolheadmasters with accompanying reward structure.

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5. Strengthen EMIS and monitoring and evaluation capacities in MOEC, particularlyon costs, expenditures and key indicators.

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3. BASELINE DATA

THE BIO-PHYSICAL ENVIRONMENTAL FEATURES

3.1 The United Republic of Tanzania lies between 29°30'E and 40°30'E, and 1°00'Sand 1 1148'S. It is a land of contrasts, being the home of Africa's highest mountain(Kilimanjaro, at 5,895 m and its lowest point (the floor of Lake Tanganyika, which is1,470 m deep). Located on the east coast of Africa, it covers an area of approximately945,000 km , of which the Zanzibar Islands cover 2,400 km2. The islands of Mafia,Pemba and Zanzibar are included in this area. Of this area 61,495 km2 is covered by theinland waters of the Great Lakes (Victoria, Malawi and Tanganyika). The country isbordered by Uganda to the north for 396km, Rwanda and Burundi to the north-west for217km and 451km respectively, the Democratic Republic of Congo (DRC) to the westfor 459km (a water border on lake Tanganyika), Zambia and Malawi to the south-westfor about 338km and 475km respectively , Mozambique to the south for 756km, andKenya to the northeast for 769km. The Indian Ocean, whose shores are characterized bycoral reefs and small islands, lies to the east. The continental shelf within the 200-mdepth contour varies from 4-60 km from the shore.

3.2 Tanzania experiences a variety of climatic conditions, ranging from the alpinedeserts on the top slopes of Mount Kilimanjaro that are permanently covered by snow, tothe tropical coastal areas that are under the influence of two monsoon winds. The north-east monsoon wind which blows southwards from December to March brings the hottestweather, while the southeast monsoon winds which blow northwards from March toSeptember bring intermittent rains. The main rainy season on the coast is from March toMay (the 'long rains') with a second season between October and December (the 'shortrains'). Mean annual rainfall varies from 400 mm in the central regions to over 2,500 mmin the highlands and the western side of Lake Victoria. Mean annual temperatures areinfluenced by altitude, ranging from 21 °C in high mountain areas to 29 °C at sea level.

3.3 Except for the coastal belt and islands, most of the country is part of the CentralAfrican Plateau (1,000-1,500 m above sea level) characterized by gently sloping plainsand plateaux, broken by scattered hills and low-lying wetlands. The Central AfricanPlateau is deeply incised by two arms of the Rift Valley: the eastern arm, which includesLakes Natron and Manyara, and the deeper western arm, which contains LakeTanganyika. Both arms of the Rift converge in the south of the country near the northernend of Lake Nyasa( Malawi).

3.4 There are seven agro-ecological zones of Tanzania based on climate, physicalgeography, soils, vegetation, land use and tsetse fly occurrence, which are the mainphysical factors that influence opportunities and constraints for crop and livestockproduction.

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3.5 Tanzania shares three major lakes (Malawi, Tanganyika and Victoria) with othercountries in the region. Other lakes in the country include Burigi, Eyasi, Magadi,Masoko, Manyara, Natron and Rukwa.

3.6 Tanzania also has many permanent and seasonal rivers. Main rivers include thePangani, Rufiji, Ruvu and Ruvuma.

3.7 Tanzania's wetlands cover about 10% of the country. They are classified asmarine and coastal wetlands, inland wetland systems, rivers and inland flood plains, andartificial wetlands. The marine and coastal wetlands include the mangrove estuaryswamps, coral reefs, seaweed and grasses, and intertidal mudflats. The inland wetlandsinclude the Rift Valley lakes (Balangida, Eyasi, Manyara, Natron, Nyasa, Rukwa, andTanganyika), some depression swamps (Bahi and Wambere) and Lake Victoria. Theshores of the Rift Valley lakes provide a habitat for birds, while Lake Natron serves asthe largest flamingo breeding ground in Africa. The soda lakes (Eyasi, Manyara, Natronand Ngorongoro) are their feeding grounds. The waters of these lakes and the adjacentland are often inhabited by wildlife, which is a major tourist attraction in Tanzania.

3.8 Some swamps are important breeding sites for fish. Lake Tanganyika is home toabout 217 endemic fish species, while Lake Malawi has the most diverse fish speciespopulation (over 600 species). Both lakes are world-famous for their diversity ofaquarium fish. Lake Tanganyika is important nationally for sardine, while Lake Victoriahas a naturally rich and diverse indigenous fish fauna (178-208 species). However, theintroduction of Nile perch has led to the disappearance of several indigenous species.

3.9 The flora of Tanzania is extremely diverse, with over 12,700 plant species - afigure comprising more than one-third of the total plant species in Africa (UNEP 1998).This high diversity of plants is not evenly distributed throughout the country, they arefound in six specific ecological zones, namely -

* Moist Forest Mosaic;* Coastal Forests and Thickets;* Afromontane;* Acacia-Savannah Grassland;* Acacia-Commiphora Thornbush, and* Brachystegia-Julbernardia-Savannah Woodland.

3.10 Proportionately, Tanzania has a much bigger land surface area devoted toresource conservation (29%) than most countries. The hierarchical protected-area systemconsists of national parks (12), game reserves (28), the Ngorongoro Conservation Area(1), and game-controlled areas (38), comprising a total of 240,000 km2. In addition to thewildlife-protected areas, there are 540 forest reserves covering 132,000 km2 , equivalentto 15% of the total woodland and forest area in Tanzania. There is also the Mafia IslandMarine Park.

3.11 Amphibians show high diversity and wide distribution, with high endemism incoastal forests and in the mountain forests of the Eastern Arc Mountains. Tanzania has

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293 reptile species, which have a wide distribution range and are not greatly threatenedby habitat change. The number of bird species found in Tanzania is 1,065. Of these, 25are endemic, and all but 3 species are limited to forest habitats. Some 302 species ofterrestrial mammals occur in Tanzania. The keystone species of critical importanceinclude chimpanzee, colobus and mangabey monkeys, elephant, and a dwindlingpopulation of black rhinoceros. The larger carnivores include lion, leopard, cheetah andthe African wild dog. There are over 30 antelope species, and the giraffe populations arethe most numerous in Africa. Tanzania also has a rich menagerie of small mammalspecies, including bats (97species), shrews (32 species) and rodents (100 species).

3.12 Of the 302 species of terrestrial mammals, 13 species (4%) and 5 subspecies areendemic to Tanzania and Kenya, and one subspecies is endemic to Tanzania and Uganda.Tanzania also has high numbers and a great species diversity of millipedes, terrestrialmolluscs and butterflies. The marine environment has more than 7,805 invertebratespecies, while about 789 species of freshwater invertebrates (mostly aquatic insects) areknown in Tanzania.

THE KEY SOCIAL ENVIRONMENTAL FEATURES

3.13 According to the latest estimates, the population of Tanzania is estimated at 36million people with a 1.72% growth rate and is made up of mostly around 130 Bantutribes.

3.14 Despite its potential and rich resource endowment, Tanzania is one of the poorestcountries in the world with a per capita GNP of about US$240 in 1999. The economydepends heavily on agriculture, which accounts for about half of GDP, provides 85% ofexports, and employs about 80% of the work force. Official estimates suggest that overhalf of its 36 million population is poor and 36% is very poor. Poverty is essentially arural phenomenon, with almost 61% of the rural population is poor compared to 39% ofthe urban population. Income distribution is uneven. In the 1998 rural survey the lowestquintile accounted for only 7% of mean expenditures.

3.15 Agriculture is the primary economic activity for the 90% of the population livingin the rural areas. The severe degradation of land, forests and water resources that supportagriculture has become an obstacle to the revival of the rural economy.

3.16 The health status in Tanzania needs to be improved. Life expectancy at birth is 47years (decline due to AIDS) compared to 50 years average in SSA , and infant mortalityof 85 per 1000 live births compared to 92 for SSA. The incidence of HIV/AIDS is high,with 10.0% of the population aged between 15-49, seropositive. In the 1990's HIVinfection rates increased significantly among this group and was higher among women.Infection rates are four times higher among young girls compared to boys. Water andsanitation services are deficient, with access to improved water source estimated to beabout 49% of population. Communicable diseases (HIV/AIDS, persistent malaria, ARI2

' SSA - Sub-Saharan Africa2 ARI - Acute Respiratory Infection

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and diarrhea), malnutrition and poor quality health care have been major factors in poorsurvival indicators.

3.17 The illiteracy rate( % of population age 15+) is 25%. The Gross primaryenrollment ( % of school-age population) is 67% for men and 66% for women.

3.18 The age structure is as follows:

* 0-14 years: 44.3% ( male 7,988,898; female 7,938,979)* 15-64 years: 53.1% ( male 9,429,959; female 9,634,102)* 65 years and over; 2.6% ( male 405,803, female 524,713)

Median age: total: 17.5years, male: 17.2 years and female: 17.7 yearsIn Tanzania, there are two official languages, Swahili and English.

CHARACTERISTICS OF POVERTY

3.19 Based on the results of the in-country consultations with local communities, localand central governments and civil society members, during the preparation of this ESMF,the following characteristics of poverty were derived:

Who are the Poor?

* Rural households.* Female headed households, other households with less than two adult-members,

elderly and handicapped persons.* Large households.* Urban households.

The groups are not mutually exclusive.

Why are they poor?

* Rural Householdso Low agricultural productivity, declining soil fertility and environmental

degradation.o Lack of access to land, land fragmentation, insecurity of land tenure.o Lack of access to markets, absence of rural commercial activity and

alternative income earning opportunities.o Poor quality education, lack of access to education, high cost of education.o Poor health services and health standards and rise in hiv/aids incidence,

impacting negatively on productivity.o Poor nutritional intake.o Lack of access to low cost capital or micro-credit or micro-grants.O Lack of access to affordable and sustainable household energy sources.o Vulnerability.

* Female-headed householdso Shortage of household labor.

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o Declining soil fertility.o Many women have to take care of unemployed/unemployable husbands,

dependant parents, dependent orphans.O Low education attainment, poor access to land, paid employment and

credit.o Poor social services, e.g. Water, health, education etc.

Urban Pooro Rapid increase in urban population.o No employment opportunities particularly among poorly educated young

people.o Poor basic social services and infrastructure.O Lack of housing.O Lack of land.O High food prices due to low agricultural productivity, high transport costs

and restrictions on petty trade.* Where are the poor?

o Poverty continues to be essentially a rural phenomenon.

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4. DESCRIPTION OF THE WORLD BANK'SSAFEGUARD POLICIES

4.1 This ESMF has been designed so that all investments under the SEDP willcomply with all the Environmental laws of the United Republic of Tanzania and theEnvironmental and Social Safeguard Policies of the World Bank . In this chapter, theBank's safeguards policies and their applicability is discussed and in the subsequentchapter those of the URT are presented.

4.2 The World Bank Safeguard Policies are;* Environmental Assessment (OP4.01, BP 4.01, GP 4.01)

* Natural Habitats (OP 4.04, BP 4.04, GP 4.04)

* Forestry (OP 4.36, GP 4.36)

* Pest Management (OP 4.09)

* Cultural Property (OPN 11.03)

* Indigenous Peoples (OD 4.20)

* Involuntary Resettlement (OP/BP 4.12)

* Safety of Dams (OP 4.37, BP 4.37)

* Projects on International Waters (OP 7.50, BP 7.50, GP 7.50)

* Projects in Disputed Areas (OP 7.60, BP 7.60, GP 7.60)

4.3 In preparing this ESMF, a consideration of the type of future investments plannedvis-a-vis the baseline data presented in Chapter 4 against the requirements of the BankSafeguard policies, has led to the determination that only the following Bank policies arelikely to apply.

* OP 4.01 Environmental Assessment* OP 4.12 Involuntary Resettlement

4.4 Notwithstanding, since the exact location of the investments (schools) was notknown at the time of preparation of the SEDP, and since the geographic coverage isexpected to be country wide, other bank policies may apply and not all policies selectedabove may apply simultaneously.

4.5 Therefore, a complete description of the bank safeguards and their triggers forapplicability can be found on the World Bank's official web site www.worldbank.org andsummarized in Annex 2.0, to be used as part of the Environmental and SocialManagement process presented in chapter 9. of this ESMF.

4.6 The provisions of both OP 4.01 and OP 4.12 apply to all components under theprogram, whether or not they are directly funded in whole or in part by the Bank.

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Therefore, even though part of the school construction program under the SEDP may befinanced with resources from other donors (non World Bank Group), government fundsor other sources within this program, the EA process and the RPF remain mandatory forthe implementation of these activities, even though they may not be financed by theBank.

ENVIRONMENTAL ASSESSMENT (OP4.01, BP 4.01, GP 4.01)

4.7 This policy requires environmental assessment (EA) of projects proposed forBank financing to help ensure that they are environmentally sound and sustainable, andthus to improve decision making. The EA is a process whose breadth, depth, and type ofanalysis depend on the nature, scale, and potential environmental impact of the programinvestments/activities under the SEDP. The EA process takes into account the naturalenvironment (air, water, and land); human health and safety; social aspects (involuntaryresettlement, indigenous peoples, and cultural property) and trans-boundary and globalenvironmental aspects.

4.8 The environmental and social impacts of the SEDP will come from the secondaryschool construction program/activities of the schools and any otherconstruction/rehabilitation type activities that the SEDP will be financing. However,since the location of these schools will not be identified before appraisal of the project,the EA process calls for the GoT to prepare an Environmental and Social ManagementFramework (ESMF) report which will establish a mechanism to determine and assessfuture potential environmental and social impacts of the construction activities under theproposed SEDP, and then to set out mitigation, monitoring and institutional measures tobe taken during implementation and operation of the school construction program, toeliminate adverse environmental and social impacts, offset them, or reduce them toacceptable levels.

4.9 OP 4.01 further requires that the ESMF report must be disclosed as a separate andstand alone document by the Government of Tanzania and the World Bank as a conditionfor bank Appraisal of the SEDP. The disclosure should be both in Tanzania where it canbe accessed by the general public and local communities and at the Infoshop of the WorldBank and the date for disclosure must precede the date for appraisal of the program.

4.10 The policy further calls for the SEDP as a whole to be environmentally screenedto determine the extent and type of the EA process. The SEDP has thus been screenedand assigned an EA Category B. This category of projects is defined as follows.

Category B projects are likely to have potential adverse environmentalimpacts on human populations or environmentally important areas -including wetlands, forests, grasslands, and other natural habitats - and areless adverse than those of category A projects. These impacts are sitespecific, few if any of them are irreversible, and in most cases mitigationmeasures can be designed more readily than for category A projects. TheEA process for category B projects examines the potential negative andpositive environmental impacts and recommends any measures needed to

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prevent, minimize, mitigate, or compensate for adverse impacts andimprove environmental performance.

4.11 Therefore, this ESMF sets out to establish the EA process to be undertaken forimplementation of project activities in the proposed SEDP when they are being identifiedand implemented.

4.12 This process requires the School Management Board to use the screening formand checklist contained in Annexes 3.0 and 4.0 respectively, to identify potential adverseimpacts of their s¢hool construction program and thereby determine the correspondingmitigation measures to incorporate into their planned activities. Section 9.0 sets therelevant process and requirements for environmental and social management.

INVOLUNTARY RESETTLEMENT (OP/BP 4.12)

4.13 Significant efforts are to be made in the design and screening stages of thesecondary schools construction program financed under the SEDP, to avoid impacts onpeople, land, propqrty, including peoples access to natural and other economic resources,as far as possible. Notwithstanding, land acquisition, compensation and resettlement ofpeople seem inevitable for some selected school sites. This social issue is of crucialconcern to the Government of Tanzania and the Bank, as its impact on poverty, if leftunmitigated, is negative, immediate and widespread. Thus, OP 4.12 will be triggered inthose cases. Thus a Resettlement Policy Framework (RPF) has been prepared by thegovernment and approved by the Bank in compliance with OP 4.12. The RPF sets theguidelines for the Resettlement and Compensation Plans (RAPs) that would have to beprepared when any program investment triggers this policy. The RAPs would be preparedby the School Boards and would have to be submitted to their respective DistrictEnvironmental Coordinator for approval. The RAPs would also have to be approved bythe Bank as a condition for that particular school construction to be financed.

4.14 This policy would be triggered when a program activity, in this case a schoolconstruction/rehabilitation causes the involuntary taking of land and other assets resultingin: (a) relocation or loss of shelter, (b) loss of assets or access to assets (c) loss of incomesources or means qf livelihood, whether or not the affected persons must move to anotherlocation.

4.15 The World Bank Safeguard policy OP 4.12, in most cases, is not triggeredbecause people are being affected by physical displacement. It is triggered because theprogram activity causes land acquisition, whereby a physical piece of land is needed andpeople may be affccted because they are cultivating on that land, they may have buildingson the land, they maybe using the land for water and grazing of animals or they mayotherwise access the land economically, spiritually or any other way which may not bepossible during and after the school construction program is implemented. Therefore,people are in most cases compensated for their loss (of land, property or access) either inkind or in cash of which the former is preferred.

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4.16 The resettlement policy applies to all displaced persons regardless of the totalnumber affected, the severity of the impact and whether or not they have legal title to theland. Particular attention should be paid to the needs of vulnerable groups among thosedisplaced. The policy also requires that the implementation of the resettlement plans are apre-requisite for the implementation/start of the construction to ensure that displacementor restriction of access does not occur before necessary measures for resettlement andcompensation are in place. For chosen sites involving land acquisition, it is furtherrequired that these measures include provision of compensation and of other assistancerequired for relo ation, prior to displacement, and preparation and provision ofresettlement sites with adequate facilities, where required. In particular, the taking of landand related assets may take place only after compensation has been paid, and whereapplicable, resettle ent sites, new homes , related infrastructure and moving allowanceshave been provided to displaced persons. For program activities requiring relocation orloss of shelter, the policy further requires that measures to assist the displaced persons areimplemented in ac ordance with the project resettlement plans of action. The policy aimsto have the displaced persons perceive the process to be fair and transparent.

4.17 Where ther.e is a conflict between the Laws of Tanzania and the Bank OP4. 12, thelatter must take pr cedence if the Bank is to fund this project.

4.18 Finally, O 4.12 also requires the RPF to be disclosed both in Tanzania and at theinfoshop of the Bank before appraisal.

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5. DESCR PTION OF THE ADMINISTRATIVE, POLICY,LEGISL TIVE AND REGULATORY FRAMEWORK

ADMINISTRA IVE STRUCTURE FOR THE EDUCATION AND TRAINING SECTOR

5.1 The United Republic of Tanzania is made of mainland Tanzania and the IndianOcean islands of Zanzibar. Under the constitution Zanzibar enjoys a certain degree ofautonomy under the union, for governance of certain sectors, such as education.

* The SEI P will only operate in mainland Tanzania.

* Admini tratively, the URT is divided into Regions, Districts, Divisions,Wards and Villages. The Village being the smallest administrative area and is

closest to the communities.

* The Miiiistry of Education and Culture (MoEC) has overall responsibility forthe Mar agement and Administration of Education and Training in mainlandTanzani a.

* In purst ance of its mandate, the MoEC has divided the 21 regions in mainlandTanzania into eight zones (zones 1 to 8).

* The Per manent Secretary is the executive responsible for overall managementof educ ation in the MOEC. The Chief Education Officer is the TechnicalHead.

* The Te zhnical Head specifically for Secondary Education is the Director ofSecondary Education (DSE) who is assisted by an Assistant Director ofSecond ary Education.

* The administrative head in the regions is the Regional Education Officer(RE ) and for the Districts, it is the District Education Officer (DEO).

THE SCHOOL CALENDAR

* 1st Term: 3rd M leek January to 1st Week June

* 2 nd Term: 1st X Teek July to Ist Week December

THE POLI Y FRAMEWORK FOR THE EDUCATION AND TRAINING SECTOR

5.2 In 1995, tle Ministry of Education and Culture prepared an Education andTraining Policy th; t emphasized liberalizing the education sector in step with the rest ofthe economy and increasing the accountability of service providers to clients. TheEducation Sector Country Status Report, Education Sector PER and MTEF haveidentified the critic al constraints on the provision and further development of educationas well as the bro der education sector issues. Furthermore, with the overall objective ofproducing more and better qualified graduates to support the development efforts ofTanzania with much strengthened labor force, the Government's sector policies are being

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refined and finalize d based on extensive consultations with technical working groupscomprising all stake holders.

5.3 Education is one of the priority sectors specified in the Government of Tanzania'sVision 2025, TAS and PRSP. Within this context, the government is deepening acomprehensive Edi ication Sector Development Program (ESDP). Close collaborationwith all stakehold rs characterizes the process. The ESDP has defined the followinggeneral priorities:

* Priority in s ending on basic education;

* Improveme tin equitable access to quality secondary education;

* Demand-dri ven and market-oriented post-secondary and higher education; and

* Institutional development to improve sector management and strengthenimplementa ion capacity.

5.4 The primary education sub-sector has been the focus of the development plan forthe first phase of t he ESDP not only because of its essential role in providing a solidfoundation for the development of other sub-sectors, but also because it absorbs nearlytwo-thirds of the p iblic resources allocated to the education sector. The government ofTanzania started the implementation of a comprehensive Primary EducationDevelopment Plan PEDP) in school year 2002. PEDP is a program with the objectives ofimproving educatic n quality, expanding school access, and increasing school retention atthe primary level.

5.5 During pro ,essing of the PEDP the government deferred work on a SecondaryEducation Master lan (SEMP) and an earlier rationalization project for post primaryeducation and train ng. With the PEDP now underway, the Government has committed toput more effort and resources into the further development of post-primary education andtraining. The seco d stage of the comprehensive ESDP therefore centers on generalsecondary educatio , and hence the SEDP.

THE POL CY FRAMEWORK FOR DECENTRALIZATION BY DEVOLUTION

5.6 In 1998, th Prime Ministers office decided to make changes in the legislationwhich will enable the government to: (a) proceed with the implementation of the localgovernment reforn1 n according to the government's visions and objectives for astrengthened local government system; (b) co-ordinate and give direction to the work onsector reforms so lhat they are consistent with objectives for the civil service and localgovermnent refor ; and (c) to fulfill government commitments.

5.7 This policy paper on Local Government Reform is based on recommendationsfrom the National onference on a shared vision for local government in Tanzania, May1996; the local ( overnment Reform Agenda of November 1996; discussions and

recommendations with the Association of Local Authorities in Tanzania (ALAT),representatives fro local authorities, sector ministries and other central governmentorgans in various f r fora.

5.8 The Tanza nia local government system is based on political devolution anddecentralization of functions and finances within the framework of a unitary state. Local

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governments will be holistic, i.e. multi-sectoral, government units with a legal status(body corporate) operating on the basis of discretionary, but general powers under thelegal framework c onstituted by the national legislation. Local governments have theresponsibility for social development and public provision within their jurisdiction,facilitation of maii]itenance of law and order and issues of national importance such aseducation, health, water, roads and agriculture. Local governments have constitutedunitary governance systems all over the country based on elected councils andcommittees and a irofessional administration.

5.9 Decentralization of government thus includes four main policy areas;

A. Political decentralization is a devolution of powers and the setting of the rulesfor coui cils and committees, etc.

B. Financi d decentralization is based on a definition of the principles of financialdiscreti nary powers of local councils, i.e powers to levy local taxes and theobligati n of central government to supply local governments with adequateuncond tional grants and other forms of grants.

C. Admini trative decentralization involves de-linking local authority staff fromtheir re ;pective ministries and procedures for establishment of a local payroll.Local governments will thus have and recruit their own personnel, makingthem a countable to their local councils.

D. Change central-local relations: The role of central government vis-a- vislocal c uncils will be changed into a system of inter-governmental relationswith ce ntral government having the over-riding powers within the frameworkof the constitution. Line ministries will change their role and functions intobecomi g, (i) policy making bodies, (ii) supportive and capacity buildingbodies, (iii) monitoring and quality assurance bodies within the localgovern nent legislation framework, and (iv) regulatory bodies ( legal controland auc it).

5.10 The Minister responsible for local government will co-ordinate central-localrelations and in p, irticular all initiatives from sectoral ministries on matters relating tolocal government.

THE LEGIS LATIVE AND REGULATORY FRAMEWORK FOR EDUCATION AND

TRAINING

5.11 The princi pal legislation is the National Education Act No. 25, 1978. An

amendment act, E, ucation (Amendment) Act, 1995 also exists. The National EducationAct, 1978 makes provision for the following:

* Central Ad inistration of National Schools

* Local Administration of National Schools

* Duties and Powers of the Minister

* Establishment and Registration of Schools

* Managemerit and Control of Schools

* Provisions relating to Teachers

* Appeals

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* General Pro isions

THE LEGISLA IVE AND REGULATORY FRAMEWORK FOR DECENTRALIZATION

5.12 The principal legislation for decentralization by devolution are the following;

* The Local GCovernment ( District Authorities) Act, No. 7 of 1982

* The Local C ovemment ( Urban Authorities) Act, No. 8 of 1982

* The Local C overnment Finances Act, No. 9 of 1982

* The Local C overnment Negotiating Machinery Act, No. 11 of 1982

* The Local C ovenmment Services Act, No. 10 of 1982

* The Urban j uthorities (Rating) Act, No. 2 of 1983

* The Local Authorities Elections Act, No. 4 of 1979

* The Local Covernment Authorities (Decoration of Building) Act, No. 9 of 1968

* The Region L Administration Act, No. 19 of 1997

MANAGEMEN!r AND ADMINISTRATION FRAMEWORK FOR THE ENVIRONMENT

5.13 With regar Is to the management of the bio-physical environment throughoutTanzania, the overC 1 responsibility lies with the Office of the Vice President. There is

also a cross-sectorsl technical committee composed of members from various sectors .The members of th¶ Technical Review Committee (TRC) are:

* The Ministr y responsible for Environment (Vice President's Office)

* Ministry res ponsible for forestry, fisheries, wildlife and tourism

* Ministry res ponsible for Urban and Rural Planning

* Ministry res ponsible for Agriculture

* Ministry reE ponsible for Water

* Ministry re, ponsible for Works and Communication

* Ministry re, ponsible for Industry and Trade

* Institute of Resource Assessment - University of Dar es Salaam

* National Er vironment Management Council (NEMC)

* NEMC is the secretariat to the TRC.

The Office of the Vice President

5.14 The vision 9 f the Ministry of Environment of the Office of the Vice President is"to attain sustainabl.e human development, eradication of poverty, security and equitableuse of resources or a sustainable basis to meet the basic needs of the present and futuregenerations withou It degrading the environment or risking health or safety and alsomaintain the union between the mainland Tanzania and Zanzibar".

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5.15 The mission of the Vice-President's office is "to formulate policies and strategies

on poverty eradicat on, protection of environment and non-governmental organizations as

well as co-ordinate Ill issues pertaining to the mainland Tanzania and Zanzibar".

5.16 The Office of the Vice President (VP's office) is the ministry responsible for

policy, planning an implementation oversight on issues relating to the Environment in

Tanzania. The VP' office is therefore responsible for overall policy guidance and advice

on the development of strategic environmental vision, including formulation, analysis and

appraisal of broad environmental policy, as well as formulation and review of broad

environmental goal,, in conformity with such vision. The VP's office provides a basis for

a broad political 1 gitimacy for the administration of strategic policy decisions on a

routine and continu us basis for coordinated environmental management.

The National Envlronment Management Council (NEMC)

5.17 The Nation'l Environment Management Council (NEMC) is a semi autonomous

body answerably to the Minister in-charge of environment in the Vice President's Office.

5.18 NEMC has an advisory role in the VP's office and is responsible for enforcing

pollution control ind performs the technical arbitration role in the undertaking of

Environmental Imp act Assessment.

5.19 NEMC has prepared a comprehensive EIA procedure and guidelines dated March2002.

Environmental U its

5.20 Environme Ital units at sectoral and district level are the collaborating partners in

the EIA process. The linkages between NEMC and the sectoral and district

environmental units are legally binding to ensure clear lines of command to facilitate

effective implemenltation. The roles and responsibilities of these units shall be the

following:

5.21 Sectoral Environmental Units

* with assist ce from NEMC to develop sectoral guidelines within the frameworkof the natio al EIA guidelines;

* to issues E A registration forms to proponents and provide relevant informationon policies and other administrative requirements; and

* to assist the general EIA process administration at sectoral level.

District Environ ent Unit

* To issue E A registration forms to proponents and provide relevant informationon policy, 1 gal and other administrative requirements at the district level;

* To co-ordir ate EIA process at district level; and

* To link and liaise with the ENMC on all undertakings within the district.

5.22 The compo 3ition of the District Environmental Unit:

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* District Pla iaing Officer - as coordinator of the planning process.

* District N tural Resources Officer - manages the development of naturalresources/f restry, wildlife, bee keeping, fisheries etc).

* District Ag ricultural and Livestock Development Officer - responsible for land-use and ma lagement.

* District Wa ter Engineer.

* District He lth Officer.

* Co-opted members ( depending on nature of project).

THE EIA PROCESS IN TANZANIA

5.23 The EIA p ocess in Tanzania is presented in the "General Environmental ImpactAssessment Guide ines and Procedure", prepared by NEMC (revised March 2002), whichcontains five volun es as follows:

* Volume 1: rhe main document that elaborates the proposed EIA procedure.

* Volume 2: Screening and scoping guidelines.

* Volume 3: Guidelines on report-writing.

* Volume 4: Guidelines for EIA review and monitoring.

* Volume 5: A checklist of environmental characteristics (i.e physical, ecological,land use, cl ltural and socio-economic characteristics).

5.24 The EIA pr ocedure involves the following:

* Registering a project: The proponent is required to register the project with theNEMC.

* Screening: The project is classified to determine the level at which theenvironmei tal assessment should be carried out.

* Conducting an EIA: This involves the three main stages of the EIA process(scoping, preparing terms of reference and preparing an environmental impactstatement). It is at this stage that the decision is made whether to conduct the EIAor not.

* Reviewing the EIA: A Technical Review Committee established by the NEMCreviews the EIA and decides whether the EIA is acceptable or not.

* Issuing the relevant permits: If the EIA is approved, the NEMC issues thenecessary onvironmental permit that confirms the EIA has been satisfactorilycompleted nd the project may proceed.

* Decision-r aking: A decision is made as to whether a proposal is approved or not;a record of decision explains how environmental issues were taken intoconsiderati n.

* Monitoring project implementation: The proponent prepares and executes anappropriate monitoring program (i.e. an environmental management program).

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* Auditing the completed project: The NEMC undertakes periodic and independentaudits of th project. Depending on its findings, it will issue an EnvironmentalAuditing Rc port.

* Decommiss foning the project upon its completion: A decommissioning report isprepared at he end of the project life. This report outlines therestoration/ ehabilitation activities to be carried out by the proponent and islodged with the NEMC .

EXTENT OF PUBLIC PARTICIPATION

5.25 Public parti ipation is required during the scoping stages and while fulfilling theterms of reference for the impact assessment of the EIA process. The proponent isresponsible for ide ntifying interested and affected parties and ensuring that all partiesconcerned are gi- en adequate opportunity to participate in the process. A publicinformation program is initiated, and public notices are issued during the scoping andEIA stages.

5.26 Whenever a strong public concern over the proposed project is indicated andimpacts are exten ive and far-reaching, the NEMC is required to organize a publichearing. The results of the public hearing should be taken into account when a decision istaken whether or n t a permit is to be issued.

POLICY F RAMEWORK FOR THE MANAGEMENT OF THE ENVIRONMENT

5.27 Tanzania p lblished its National Environmental Policy (NEP) in December 1997and the National Conservation Strategy for Sustainable Development, the NationalEnvironmental Ac on Plan (NEAP) and specific sectoral policies such as those on land,mining, energy, w ter, agriculture, population and fisheries. The NEP recognizes the EIAprocess as a mea Is of ensuring that natural resources are soundly managed, and ofavoiding exploitati n in ways that would cause irreparable damage and social costs.

5.28 The NEP s eeks to provide the framework for making the fundamental changesthat are needed in order to incorporate environmental considerations into the mainstreamof decision makin g. The NEP seeks to provide guidance and planning strategies indetermining how actions should be prioritized, and provides for the monitoring andregular review of policies, plans and programs. It further provides for sectoral and cross-sectoral policy an lysis, so that compatibility among sectors and interest groups can beachieved and the synergies between them exploited. The overall objectives of the NEPare, therefore, the f llowing:

* To ensure t he sustainability, security and equitable use of resources in meeting thebasic needs of present and future generations without degrading the environmentor risking h ealth and safety.

* To prevent and control the degradation of land, water, vegetation, and air, whichconstitute o ur life support systems.

* To conse e and enhance our natural and man-made heritage, including thebiological diversity of Tanzania's unique ecosystems.

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. To improve the condition and productivity of degraded areas, as well as rural andurban settlements, in order that all Tanzanians may live in safe, healthy,productive arnd aesthetically pleasing surroundings.

* To raise pul lic awareness and understanding of the essential links between theenvironmen, and development, and to promote individual and communityparticipatior. in environmental action.

* To promote international cooperation on the environment agenda, and expandparticipatiorv and contribution to relevant bilateral, sub regional, regional, andglobal orga izations and programs, including the implementation of treaties.

LEGISLATIVE FRAMEWORK FOR THE MANAGEMENT OF THE ENVIRONMENT

5.29 Under Article 27 of the Constitution, the public is called upon to ensure that thenatural resources of the country are managed properly:

(1) Every person is obliged to safeguard and protect the natural resources of theUnited Republic, State property and all property jointly owned by the people

(2) All perscons shall by law be required to safeguard State and communalproperty, to combat allforms of misappropriation and wastage and to run theeconomy of the nation assiduously, with the attitude ofpeople who are masters ofthe fate of their nation.

5.30 Tanzania h as completed a draft framework legislation on environmentalmanagement whicl . is due to be tabled for its first reading in the 2004 parliamentarysession.

5.31 Table 5.1 ;hows the various policies and laws that relate to environmentalmanagement.

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Table 5.1: Exist ng Key Policies And Laws Relating To Environmental Management

Ac Or Policy Key Elements Implementing Authority

Act Key Elements Implementing AuthorityNational Environmenta The Act provides for the National EnvironmentalManagement Council ( 'EMC) establishment of the NEMC, as Management CouncilAct, No. 19 of 1983 well as all functions and other

matters related and incidental toits establishment.

Wildlife Conservation ct, The Act protects wildlife and Ministry of Tourism Natural

No. 12 of 1974, as ame ded vegetation by restricting the Resources and Tourismutilization of wildlife to license-holders. The use of sensitivewildlife habitats is restrictedduring certain times of the year orfor specified periods.

Fisheries Act, No. 6 of 1970 The Act limits annual catches. Division of Fisheries,Specific regulations were Ministry of Natural Resources

Fisheries Act No. 22 0 f 2003 introduced in 1973 and 1982, and Tourism

putting limitations on methods offish harvesting, includingoutlawing of dynamiting andpoisoning.

Water Utilization and Control The Act establishes temporary Ministry of Water and Livestock

Act, No. 42 of 1974 standards for public use, as well Developmentas effluent discharge standards.

Urban Water Supply The Act gives the National Urban National Urban Water Authority,

Act, No. 7 of 1981 Water Authority powers to Ministry of Water and Livestockmonitor and control surface water Developmentand groundwater pollution andspecifies punitive measures forviolators of this act.

Mining Act, No. 17 of 1980, as The Act sets out government Ministry of Energy and Minerals

amended policy on all forms of mining andis supported by variousregulations covering claims,prospecting rights, mining rightsand royalties. Mining licenseapplicants are required to submitplans for environmentalprotection. Each industry isrequired to establish realisticresource recovery standards andto adhere to them. Mining plansare required to be presentedbefore operations begin.

Forestry Policy of 199 The revised Policy continues to Division of Forestry,recognize the important role of Ministry of Natural Resourcesforests in the maintenance of the and Tourismenvironment, the provision offorestry products and theprotection of watersheds andbiodiversity.

Land Act, No. 4 of 1999 Private Group Property is given Ministry of Lands and Human

either through Granted Rights in SettlementGeneral and Reserved Land(Land Act, Section 19) or throughCustomary Rights in Village

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Act Key Elements Implementing AuthorityLands (Village Land Act, Section22). Provision is also made forholding land by joint occupancyor occupancy in common(Land Act, Part XIII).

Village Land Act, No. of 1999 The Act requires each village to Ministry of Lands and Humanidentify and register all Settlement

communal land, and obtain theapproval of all members of thevillage for identification andregistration (Village Assembly,Section 13). A Register ofCommunal Land (Section 13(6))is to be maintained by eachVillage Land Council, and landcannot be allocated toindividuals, families, or groupsfor private ownership (Section12(1 )(a)).

Local (District and Ur an) Local Authorities are empowered Local Authorities

Authorities Act, No. 7 f 1982 to make by-laws regarding theprotection of soil, agriculture,water supplies and other naturalresources. The Act containsprovisions to protect humanhealth and regulate pollutionproblems.

Merchant Shipping Ac of 1967 Atmospheric pollution isaddressed only minimally inTanzanian legislation. The Actprohibits the emission of darksmoke from ships for more thanfive minutes in any hour withinthe limits of a port.

Town and Country Pla ining The Ordinance was intended to National Land Use Planning

Ordinance, establish a land-use planning Commissionscheme for designated areas. TheNational Land Use PlanningCommission was established toadvise Government on landconservation and development.

Public Health, Sewera e and The Ordinance prohibits the Ministry of Health and Social

Drainage Ordinance, discharge of certain substances WelfareChapter 336 into sewers. Violation of the

Ordinance is an offence, andpenalties may be imposed onoffenders.

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INTERNATIONAL CONVENTIONS

5.32 Tanzania is a party to many international agreements on Biodiversity, ClimateChange, Desertific ation, Endangered Species, Ozone layer protection, Marine LifeConservation, etc. xamples are:

* Basel Con ention on the Control of Transboundary Movements of HazardousWastes and their Disposal (1989)

* Convention Concerning the Protection of the World Cultural and NaturalHeritage, P ris (1972)

* Developme: t, Production and Stockpiling of Bacteriological ( Biological) andToxin Wea ons, and their Destruction, London (1972)

* Convention on Biological Diversity (1992)

* Convention on International Trade in Endangered Species of Wild Fauna andFlora (CITE S) (1973)

* Convention on the Ban of the Import into Africa and the Control ofTransbound ary Movement and Management of Hazardous Wastes Within Africa,Bamako,M ali (1991)

* UN Conve ltion to Combat Desertification in Countries Experiencing SeriousDrought an /or Desertification particularly in Africa (1994)

* Lusaka Ag eement on Co-operative Enforcement Operations Directed at illegalTrade in W ld Fauna and Flora (1994)

* Montreal P otocol on Substances that Deplete the Ozone Layer (1987)

* Phyto-sanit ry Convention for Africa, Kinshasa (1967)

* UN Conve tion on the Law of the Sea (1982)

* UN Frame; ork Convention on Climate Change (1992)

* Vienna Cor vention for the Protection of the Ozone Layer.

MEMB ERSHIP OF INTERNATIONAL RIVER BASIN COMMISSIONS.

Tanzania is a n ember of the Nile Basin Commission

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6. DETERN INATION OF POTENTIAL ENVIRONMENTALAND SOCIAL IMPACTS

PO ENTIAL ENVIRONMENTAL CONCERNS AND IMPACTS

Generic Environmen al Concerns

6.1 The National Environment Policy (NEP) identifies the following as the criticalenvironmental problen s facing Tanzania today:

* Land Degradat on* Lack of accessi ble, good quality water for both urban and rural inhabitants

* Environmental Pollution, e.g Water Contamination* Loss of Biodiv rsity, Habitat and Wetlands* Deterioration o IAquatic Systems* Deforestation

6.2 The Tables 6.1 to 6.7, presents the root and immediate causes for these environmental

problems and discusse s the impacts and their severity, providing the background against whichany potential adverse impacts on the environment from the activities of the SEDP can be

determined and analyz .d.

Table 6.1

Land Degradation: From s il erosion, soil exhaustion and overgrazing. A problem throughout Tanzania.

Particularly around the steep hills in Mwanza, Mara, and Kagera region; lakeshores

Immediate Cause s Root Causes Impacts Severity

* Massive continued loss of * Population pressure and * Loss of top soil and HIGHvegetative cover due to poverty leading to reduction of soil fertilitydeforestation and loss o other unsustainable land use leading to decrease inland cover, deterioratio i of practices. agricultural productioncatchment buffer zones * Topography (uneven relief, and food security.

* Inappropriate agricultu al high stream flow velocities) * Reduction of vegetativepractices leading to dec reased and rainfall patterns (floods, cover and loss of habitatssoil quality and erosion such as droughts, climate and biodiversity.

use of marginal lands, variability) * Water quality degradationovergrazing and free gr wing. * Lack of land use policies from high sediment loads,

* Lack of soil and water and improper land use siltation of shallow lakes,conservation measures ed/or management; weak wetlands, reservoirs, andabandonment and poor extension service on soil valley bottoms and othermaintenance of anti-erc sion conservation often low lying landsworks. connected with prevalent downstream.

* Bush fires and slash an I bum land tenure system. * Degradation of river beds

practices. * High livestock density and river bank erosion;* Lack of awareness of land- desertification and wind

water interaction erosion (northern arid* Lack of systematic regions), sheet and rill

implementation of EIA for erosion and gullyinfrastructure projects due to formation (after heavylack of financial and human rainfall) in highlands.resources. * Landslides and flooding

leading to destruction ofinfrastructure ( houses,means of communication,communal facilities, etc.)

26

Table 6.2

River Bank and Lakeshot e Degradation. For e.g. at River estuaries into lakes.

* Poor land use and agricu ural * Lack of or insufficient * Destruction of vegetative MODERATEpractices such as dry se n national land use plans, laws cover especially lake shore

cultivation near banks an and regulations, and/or buffer zones.

destruction of vegetative over enforcement of existing * Erosion, landslides, and

to increase arable land ar a; high laws. downstream sedimentation

animal density. * Population pressure and leading to change in river

* Drop in water levels and drying rapid growth of urban course.

up of waterways. centers. * Adverse effects on

* Increased urban develop nent * Expansion of farm lands and riverine aquatic life and

and construction and ind strial inadequate agricultural lake ecosystems.activities near river bank ; practices near river bankspoorly planned tourism c nters. and shores, including

overgrazing.* Land subsistence; relief and

morphological structure ofsoil.

* Climatic variability andconditions; seasonal floodsand intermittent increase inlake levels.

Table 6.3

Minin: For instance, Mara, Mwanza, parts of Shinyanga, and Kagera regions

Immediate Causes Root Causes Impacts Severity

* Use of toxic chemicals a d * Inadequate policy guidance, * Water and air pollution. HIGH in

lack of containment and lack of or insufficient * Soil degradation and certain

treatment facilities (esp. safeguards ( EIA, anti- erosion of sites and locations

mercury use in gold min ng). pollution/environmental adjacent river banks;

* Lack of adequate site legislation. deforestation and

rehabilitation. * No regulation/enforcement landslides leading to river

* Inadequate mining pract ces. of private mining siltation.* High demand for const iction entrepreneurs. * Adverse impact on flora

materials and indiscrimi late * Lack of (government) and fauna.clearing of vegetation. planning and oversight

27

Table 6.4Water Contamination: Poll ition. Point source pollution localized around urban/growth centers. Non point sources

generally are a regional proble n mostly from agricultural sources.

Immediate Causes Root Causes Impacts Severity

* Discharge of run-off of u treated . Weak policies, laws and * Degradation of MODERATEwater from urban and ind strial regulations for environmental water quality,

sources containing dissol ed protections ( e.g. EIA); rendering waternutrients, industrial pollut nts, insufficient enforcement and unsuitable for

agricultural chemicals/ferl ilizers; monitoring especially in domestic,lack of recycling of waste matter; respect to industrial facilities; agricultural,uncontrolled dumping of waste. low budgetary provision for industrial and other

• Non-point source pollutio i from enforcement of existing uses.

agriculture due to improp r and regulations, lack of sufficient * Adverse impacts onhigh application rates of a gro- human resources. water dependentchemicals. . Point Sources: Inadequate flora and fauna, loss

* Degradation of vegetative cover funding of investments, high of habitats and bio-especially wetlands, in ba ins capital costs, high operation diversity, nutrientwhich could act as filters. and maintenance costs, discharges leading

inadequate containment and to increasedtreatment of wastes and lack eutrophication. .of sanitary facilities. . Pollution of lakes

. Non-point sources: and tributaries,Unsustainable land use resulting in

practices in combination with contamination oflack of security of land drinking water.tenure. * Lack of adequate

. Inadequate zoning liquid and solid

regulations and/or waste disposalenforcement; inadequate systems andenvironmental and land use accumulation ofplanning. refuse.

* Low environmental . Decrease inawareness and sense of value environmentalor environmental protection. quality,

disappearance ofnatural habitats andproliferation of

I water hyacinth.

28

Table 6.5Deforestation:

Immediate Causes Root Causes Impacts Severity

. Land use conversion d e to * Poverty and population . Decreasing HIGHincreasing need for ara le pressure leading to vegetation/forest cover;

land and grazing areas; unsustainable pressure on loss of density and

burning practices for la d resources; absence of diversity.

clearing and shifting alternative livelihoodscultivation. and weak capacity to * Deterioration of

increase unit agricultural watershed: high run-off

* Uncontrolled logging f r production. associated withfuelwood and charcoal increased erosionproduction for * Insufficient energy leading to loss of fertiledomestic/household en -rgy alternatives to fuelwood. soils and sedimentationconsumption, construc ion and siltationmaterial and local indu try * Insufficient awareness downstream.fuel needs. and knowledge of

sustainable land use * Energy crisis associated* Unsustainable and inef icient practices and effects of with price increases due

resource use (e.g. deforestation. to decreased availabilityovergrazing, extensive of fuelwood and

cultivation on steep hil . Land tenure system charcoal.

slopes and uncontrolle leading to allocation and

logging). use of marginal lands and * Large scale habitatlack of incentives for destruction and loss of

* Lack of local sustainable land use wildlife in terms ofplanting/replanting. practices. numbers and

biodiversity;

* Human migration and . Drought and overall arid progressiveresettlement due to climate and topography. disappearance ofincreasing numbers of National Parks.returnees and other waaffected groups, encro ching * Variability in climateinto forested areas. and rainfall patterns.

29

Table 6.7

Water Contamination: Sal itation Aspects

. Lack of water supply s stems . Lack of environmental . Pollution of drinking SEVEREand/or other reliable dr nking regulations and laws, water sourceswater source; drinking ater monitoring and enforcement (ground and surfacecontamination with fec l and general waste water) and high

matter leading to spread of management strategies. dissolved nutrientpathogens. loads resulting in

Rapid growth of urban increasing. Lack of or insufficient centers and lack of financial eutrophication and

sewerage or alternative resource base to build spread of infectious

sanitation systems ;lea s and needed water supply and diseases ( diarrhea,insufficient maintenanc e of sanitation infrastructure, malaria, bilharzias,

existing facilities; lack of combined with lack of dysentery, and

urban storm water sewe rs and planning for urban intestinal worms).

solid waste disposal fac ilities. expansion and requiredinfrastructure. . Risks to public health

* Insufficient sanitation End due to poor sanitationhygiene training in . High capital costs for conditions, especiallyconjunction with wides pread investments; high operation during rainy seasonpoor sanitary condition s. and maintenance costs. and floods.

. Increased breeding gro nd . Previous low priority given . Increased absencefor mosquitoes in wate weed to sanitation by government from work due to

infested areas and irrig ition and agencies, lack of sickness; increase in

canals. awareness of connection malnutrition and

between sanitation and safe death rates especiallydrinking water; need for among vulnerablebetter hygiene education. groups such as small

children, the* Poverty and poor health displaced and the

condition of large parts of elderly.

the population.

30

Table 6.7

Loss of Biodiversitv and Habitats.

Immediate Causes Root Causes Impacts Severity

Species loss and decline of ecosyste vs and * Population pressure and poverty Species loss and decline of SEVERE

unique habitats. combined with high reliance on ecosystems and unique

. Poaching and illegal trade in N aluable primary natural resources and habitats.

species as well as intensive and income from agriculture. * Disappearance of unique

unsustainable resource use an, land * Low financial and staff capacity in animal and plant species,

management, such as deforest ition, management of protected areas and especially endemic ones;

wetlands conversion, expansion of associated lack of control and decline of speciesagriculture (crops and livesto k farming, monitoring; poor enforcement of diversity.

overfishing, uncontrolled burr ing and laws protecting gazeted forests and * Decrease in numbers of

forest fires). game sanctuaries; lack of financial large mammals with

. Lack of altemative income so rces resources for development and negative impact on

especially in areas or resettlen ent. implementation of effective and tourism and associated

Loss of agrodiversity. relevant programs. decrease in revenue.

* Expansion of hybrid/high yiel ing crop * Weak agricultural extension services. . Decrease in forest cover

and livestock varieties leadinE to decrease * Lack of awareness of biodiversity constituting decrease in

of genetic diversity of domest c/national concems and benefits from food, fuel timber and

species. conservation. shelter.

. Introduction of exotic species * Lack of regulations to prevent Loss of agrodiversity.introduction of exotic species. . Loss of genetic base

* Inadequate and unregulated land use (cattle breeds, crops,practices; insufficient integrated vegetables/fruits); loss ofprograms for people living in benefits from localprotected areas. variety qualities

(tolerance productivity,resilience); dependencyon exotic seeds andbreeds/importedvarieties.

Wetlands Degradation; e.g. Simi u River, Lake Victoria Shores, banks of Kagera River/swamps

* Reclamation of wetlands to e pand . Lack of wetland protection and . Decrease and SEVERE

agricultural production. management regulations and degradation of wetland

* Deforestation, erosion and se imentation. measures and/or lack of areas ( reclamation,

* Overuse of natural resources implementation . siltation, flood damage;

(overfishing/hunting/over- * Poverty and population pressures; water weed infestation)

grazing,farming practices) shortage of land; inadequate land use * Decreased benefits from

* Pollution from industrial, agr cultural and policies functioning wetlands,

domestic sources. * Lack of awareness of wetlands e.g. less groundwater re-function and value, cultural habits. charge, decreased

buffering of floods, lossof filter function toabsorb and degradepollutants and associateddecrease in waterquality; decreasingability to act as sedimenttrap; destruction ofhabitats and loss ofbiodiversity.

31

Positive Environment a1 Impacts of the SEDP

6.3 Overall, the SE DP is likely to have a positive impact on the environment in Tanzania, in

the short, medium and ong term, for the following reasons;

* The implement tion of this ESMF will increase in Tanzania the practice of subjectingdevelopment p ojects (especially education projects) to an environmental managementprocess, in the prevailing situation where a national environmental policy and regulatoryframework are weakly enforced. The ESMF offers the opportunity to identify potentialprogram impac s, mitigate them verifiably through monitoring while building capacityfor environme ntal management within institutions, local governments and localcommunities.

* The ESMF off rs the opportunity to mainstream into the secondary education schoolcurriculum, E ironmental Education. To support this initiative, the SIDA ( SwedenInternational evelopment Agency) has developed an Environmental EducationHandbook for he Education Sector. This handbook is available from the office of theSenior Progra Officer for the Education and Social Sector, in Embassy of Sweden inTanzania. Cont Ct details are www.swedem-dar.com or hans.person(g,sida.se

* The SEDP will significantly increase the enrolment rate at the secondary education levelby increasing the number of classroom/places in the public, private, andcommunity/rel gious/NGO schools system throughout the country, thereby significantlymeeting the ov rwhelming demand for secondary education in Tanzania.

* The SEDP wil pose no direct risks to biodiversity, natural habitats and wetlands, as itwill not fund a tivities in protected areas, national parks or wetlands.

Potential Adverse En vironmental Impacts from the SEDP

* Poor planning esulting in poor choice of location of schools, that ultimately lead to landdegradation an soil erosion, water (surface and ground) contamination, degradation ofnatural habitats and wetland ecosystems.

* During constr ction - poor performance of civil works contractors ( and theirsupervisors) le ding to unsuccessful incorporation of incorporated mitigation measures.

* Poor impleme tation of maintenance plan during operational phases of the public serviceinfrastructure/s hool financed under this project, due to lack of funds, negligence of staffor failure in the monitoring this stage.

Potential Social Con erns and Impacts

6.4 The main soci l issues in Tanzania today are:

* Acute Poverts - poverty is wide spread in Tanzania. Despite its potential and richresource endo ment, Tanzania is one of the poorest countries in the world with a percapita GNP3 of about US$240 in 1999. Official estimates suggest that over half of its3 1million pop lation is poor and 36% is very poor.

3World Bank Source32

* The Tragedy f HIV/AIDS - Life expectancy in Tanzania has declined to 48years asresult of the ai s epidemic. HIV/AIDS affects both education coverage and quality. Itdampens the de mand for education as affected households have fewer resources to spendon education e ther because of reduced income due to morbidity of income earners ordiversion of sc rce resources for health care. Children in these households are often takenout of school tc care for ill parents or have to work to make up for lost household income,and an increasi ng number are becoming orphans. At the same time, the epidemic affectsthe supply of e lucational services at all levels through increased mortality, morbidity andabsenteeism an ong teachers and education personnel.

* The Crisis in Education - An exceedingly small proportion of the Tanzanian age groupcompletes seco ndary education. At most 5% of the age group competes lower secondaryand 1.5% com .letes upper secondary. As a result, less than 5% of the labor force hasobtained secor dary education. The main cause is restricted initial access and lowretention. Onl y about one in four or five primary school completers proceeds to lowersecondary educ ation in Tanzania.

Low coverage of secondary education reflects constraints on supply and demand forsecondary sch ol places.The pressure to expand secondary school places is likely to rise rapidly in the comingyears as an in creasing number of students complete their primary school education,especially witl the introduction of free primary education that has raised the grossenrollment rate in primary education to 100% in 2002 compared to 77% in 2000.

* Gender Issues - Women are often poorer than men, own less land and livestock andhave fewer ye irs of schooling. There is roughly gender equality in access to primaryschools, thoug i imbalances exist in completion rates and access to secondary schools.Gender imbala nces are rooted and sustained by traditional and cultural values. In 1990,the Governmer t established the Ministry of Women Affairs and Children with a view topromote gender equality. A gender committee has been created to ensure that sectoralinvestments respond to the priority needs of both men and women. The new landlegislation has represented an encouraging step towards securing the right of women toown, dispose o fand inherit land4 .

Positive Social Impa ts from the SEDP.

6.5 Overall, the SE DP is likely to have a positive impact on the social issues in Tanzania, inthe short, medium and long term , for the following reasons;

* The SEDP un er the three overall objectives of the program will address the followingfive main issues:

(a) Los access and completion of secondary education.

(b) Ine luity of access and throughput among geographical areas, income groupsand between genders.

(c) High per student cost on households and the public sector in secondaryedu -ation.

(d) Lov; quality of secondary education in terms of learning outcomes.

4 See the Resettlement Pol iy Framework for this project for more information on land regulation.

33

(e) Ineff ctive organization and management of delivery of secondary education.

* The SEDP in th first phase will , instead of channeling additional resources through the

same/normal ce tral organizational structures and procedures, will change incentives (i.e.

normative finan ing of capitation grants) and accountabilities for results ( i.e. devolution

of authority to I wer levels). This will ensure a participatory process in planning and will

raise incomes at lower levels.

* Through increas e enrollment in secondary education, additional opportunities for public

health awarenes s and education for protection and prevention against HIV/AIDS will be

available for sec ondary school going age among boys and girls. It is this age group that is

particularly vul erable to this epidemic.

Potential Adverse Soc al Impacts from the IRCBP

6.6 Adverse social mpacts are likely to arise from the following:

* No participator process involving local communities in the preparation of their District

and Regional S condary Schools Development Plans by their Local Governments.

. Exclusion of ulnerable groups from participating in and benefiting from project

activities, i.e., from barriers to access to/ enrollment in secondary schools due to

stigmatization, harmful cultural practices, acute poverty among vulnerable groups,

discrimination, lack of participation in the planning process etc.

* Land acquisitio s/use resulting in involuntary resettlement from impacts on people, land,

property, inclu ing access to natural and other economic resources.

6.7 The environme tal and social screening form and checklist contained in Annex 2.0 and

Annex 3.0 are specifi ally designed to ensure that adverse social impacts from SEDP activities

are identified and capt ired in the planning stages and there-in effectively mitigated.

6.8 Both environm ntal and social mitigation measures would be verifiable monitored during

the various stages of t e program cycle.

34

7. INSTIT UTIONAL ASSESSMENT AND FRAMEWORKFOR ENVIf ONMENTAL AND SOCIAL MANAGEMENT

INSTITUTIONAL ROLES AND RESPONSIBILITIES

7.1 The main nstitutions with key responsibilities for environmental and social

management are:

The Ministry of E lucation and the Presidents Office - Regional Administration andLocal Governmen

7.2 The VPO i in charge of environmental policy formulation and monitoring of

implementation. T e VPO will provide instructions and guidance on environmentalmanagement and i nplementation to Local Government Authorities regarding all aspectsof the SEDP.

The National Env ronment Management Council (NEMC)

7.3 The NEMC is responsible for ensuring that development programs comply with

all relevant environ mental laws and regulations.

7.4 This ESMF recognizes that the NEMC have a significant role to play in the

SEDP. This role w uld be to provide (i) on the ground ESMF performance reviews/auditsboth for enforceme nt purposes, but more importantly to reinforce capacity building and

to keep the SB's and the Local Government Authorities cognizant of their ESMF

responsibilities. The NEMC would also provide periodic monitoring to ensure no adversecumulative impact from the school construction program at the national level. NEMC

will also provide o versight and technical assistance to the Local Government Authoritieswhen required.

Local Governmen t Authorities

7.5 Local Gov erment Authorities will be required to review and clear the

environmental and social management process, required of the School t Boards (SB),prior to funding the construction program.

7.6 The Local Government Authorities would be responsible for carrying out the

following: (i) en uring the school construction program comply with Tanzania'senvironmental law, and requirements, and that of the World Bank's triggered SafeguardsPolicies, (ii) for receiving, reviewing and commenting, requiring revisions wherenecessary and cle ring of School Boards completed environmental and social screeningforms and checkli ts (iii) carrying out a regular and intrusive monitoring regime duringthe planning, imp ementation, construction, operations and maintenance stages of theschools (iii) for pr paring periodic monitoring reports on the District school construction

35

program at all stag s of operations and to send these reports on a regular basis to the

MoEC. (v) to com ly with (consistent with national laws) the directives of NEMC and

MOEC, (vi) to iss e directives to the School Boards consistent with national laws on

environmental requ rements.

The School Board

7.7 The School t Boards will be responsible; (i) for complying with all national laws

regarding the envir nment and with all social/poverty guidelines, parameters and targets

set by the project, nd of all triggered World Bank Safeguards policies, (ii) to implement

their school const ction program according to/consistent with the provisions of this

ESMF, implementi g, inter alia, all appropriate mitigation measures identified in their

completed enviro ental and social screening form and checklist into the construction

planning cycle, t chnical and engineering designs and drawings, and civil works

contracts, etc. (iv) to ensure that these mitigation measures are complied with during

construction and ost construction (i.e. operations ) stages of their activities, by self

monitoring of th ir activities and by periodically reporting to Local Government

Authorities and, ( ) to maintain an adequate budget to implement the appropriate

maintenance proce ures and practices for the operation of their school, to ensure relevant

mitigation measur s identified in the environmental and social screening form and

checklist are impl mented and sustained in the school sub projects and (vi) to comply

with any directives that may be issued from time to time from the MoEC, NEMC and the

Local Government Authoritis.

Capacity Assessm ent to Perform these Roles.

7.8 The SEDP ill finance all necessary capacity building activities at various levels

for the ESMF imp mentation and monitoring in collaboration with the NEMC.

7.9 Local Gov rnment Authorities will provide technical assistance to the School

Boards, to enable hem to perform the duties assigned to them in this ESMF. The Local

Government Auth rities and School Boards will also be assisted by service providers in

situations where t ere is no in-house capacity to perform these roles.

36

Fie 8.1: Flow Chart of Institutional Roles and Responsibilities

( Management ,ouncil

\N (NM

SEDPMOEC

PO-RALG

\ ~~Boards- (SB)

MONITORING Reporting

p ~~. ~-.-.--.--.----

37

TRAINING NEEDS

Proposed Training Program

DurationEnvironmental an Social Management process 3 days

* Review of Environmental and Social Management Process.

* Review of Standard school designs.

* Use of Scre ning form and Checklist to determine adverse impacts

* From sub p oject activities.

* How to mee sure cumulative adverse impacts.

* Design of a propriate mitigation measures.

* How to review and clear the school design packages.

* The import nce of public consultations in the ESMF process.

* How to mo litor mitigation measures.

* How to em bed the Environmental and Social Management process into the civil

works.

* Contract.

Environmental al d Social policies, procedures and guidelines 2 days

* Review an' discussion of Tanzania's national environmental policies, procedures,and legislat on.

* Review anc discussion of the Bank's safeguards policies.

* Strategies f )r consultation, participation and social inclusion.

Selected topics on environmental protection lday

* Land use, 1 nd degradation and soil erosion in the local community area.

* Safe manaE ement of waste disposal and implications on public health.

* Environme ntal protection of Water resources.

* Disaster Pr paredness for floods and Droughts.

Training Cost Es imates7.10 The Train ng program is to be implemented by the National EnvironmentManagement Cou icil (NEMC) in collaboration with MOEC. The costs estimates andtraining modalities will be prepared by NEMC and MOEC.

38

8. EN IRONMENTAL AND SOCIAL PLANNING,REVIE'W AND CLEARING PROCESS FOR THE

SECONDA RY SCHOOLS CONSTRUCTION PROGRAMFUNDED UNDER THE SEDP

EN VIRONMENTAL AND SOCIAL MANAGEMENT PROCESS

(Summarized in Figs 9.1 and 9.2)

8.1 The section below will illustrate specific steps involved in the environmental and

social assessment rocess leading towards clearance and approval of the EA process for

the program activit es anticipated to have adverse environmental and social impacts. The

steps incorporate gaidelines from both the National Environment Management Council

(NEMC) and the B orld Bank OP 4.01.

8.2 The constru ction of schools will be based on existing/new standard architecturalschool designs th t are presently being used/or newly prepared by the MoEC The

Construction of Sc lools will be managed by the School Boards of the secondary schools.

The construction of the schools will be done by certified contractors appointed by the

School Boards

(a) This pr )cess can only start after approval 5 for funding under the SEDP has

been gi en by the MOEC to build a secondary school in a particular area.

(b) For a n w school, the SB will be established/elected/appointed as required by

Local Government Authorities bye-laws and MoEC guidelines.

(c) The SE will work with district engineers who will assist them with carryingout their responsibilities under this ESMF.

(d) The SE will acquire suitable land and secure legal title to it, consistent with

Tanzan an Law and the Resettlement Policy Framework (RPF). Thefollowi g siting conditions should be considered when choosing/identifyland;

* The site should normally not be within an Environmentally Sensitive Area(ES A)6

* The site should ideally be located within 500meters of a settlement area.

* The re should be a sustainable source of potable water within lkm of thesite

s The decision on whe e a secondary school is to be built will be made by the Regions and Districts.

6 ESA - are defined in Annex 6

39

l

* The site should be at least 20,000m2 in size or large enough toacco nmodate the building schedule as specified by MOEC.

. The site owners and/or users if any are consulted and are invited to

parti ipate in the activities of the local community regarding the school.

* The School Board must be able to secure legal title to the land.

* The uter boundaries of the site should be clearly marked and the length

of the sides should be measured in meters.

* There should not be any natural or manmade features on the site that couldmak construction difficult or that could pose danger to building structuresor h imans such as bedrock, gullies, water pipes, swamps, floodplains and

rock falls.

* The e should not be any natural or man made features within 100 meters

of th e site that could pose danger to pupils once the school is established,

e.g. very steep cliffs, electricity pylons, etc.

* The site must conform to and be consistent with the local developmentplan for that area/district.

* The site should not lead to either the physical displacement of people, loss

of t heir shelter, loss of assets, loss of income sources or means oflive ihood, or their loss, denial or restriction of access to economicreso rces. If it does impact any one of these, chose another site. If this is

not possible then OP 4.12 is triggered and those affected must be

com pensated, consistent with the provisions of this RPF.

(e) Once s cured land has been acquired, the SMB assisted by their service

provider will screen the standard school designs to identify adverse

enviro mental and social impacts on their chosen land site by using the

screeni ig form in Annex 3.0 and the environmental and social checklist in

Annex 4.0.

(f) Once tl ese impacts are identified the various mitigation measures would also

be iden ified from use of the completed screening form and checklist. The SB

assistec by their service provider will modify various aspects of the standard

design o incorporate the required mitigation measures.

(g) The SE assisted by their service provider will re-screen the modified designs

using t le previously completed screening form and checklist to ensure that all

impact have been adequately identified and mitigated.

(h) Additi nally, for situations where this screening process has identified thatOP 4. 2 is triggered, then the provisions of the Resettlement PolicyFrame vork would apply. This would require that the SB chose another site

that do s not trigger OP 4.12. If this is not possible, then the site that triggersOP 4.12 is maintained and a resettlement and compensation plan (RAP) is

prepare d, consistent with the provisions of the disclosed RPF.

40

(i) Throug out this screening process the SB would be assisted by their serviceprovide s.

(j) Once th SB is satisfied that the modified designs are now environmentallyand socially compliant, they would now submit their modified designs which

must be accompanied by the site location plan, completed screening form,

checklist, environment management plan (EMP) and where applicable the

RAP, to the Council for review and clearance.

(k) The Lo al Government Authorities using the appraisal form in Annex 7.0 will

review he submitted modified design to ensure that all environmental and

social ir pacts have been identified and successfully mitigated based on use of

the scre ning form and checklist. If the screening form has any "Yes" entries,

or evid ntly unjustified "No" entries, the application would need to be

adequat ly explained and demonstrate from the modified design that the issuehas bee managed to avoid unacceptable adverse effects/impacts. If this is the

case th n the Local Government Authorities will give a conditional approvalfor fun Is to be released to the SB for construction to begin based on the

followi ig conditions;

* ompliance with the requirements of the Environment Act, NEMCequirements and the World Bank Policy OP4.01.

he complete implementation of the Resettlement and CompensationPlan prepared consistent with the RPF where OP 4.12 has beentriggered.

Trhe Construction Contract Documents ( i.e. the works and materialspecifications, drawings, bills of quantities, contract conditions , etc.)are made consistent with the modified designs. This ensures that thenvironmental and social management process is embedded into theivil works contracts/processes.

Application for approval includes a Maintenance Plan.

rhat a local service provider assist the SMB to supervise theonstruction process.

* MB design proposals must contain as part of their application an_nvironmental Management Plan (EMP): that will consist of a set ofnonitoring measures to be taken during the construction and operationf the school to ensure that mitigation measures identified in the

nodified standard designs are built as designed and remain functionaln the post construction stage (i.e. when the school is being used). TheEMP should also include the actions needed to implement theseneasures, including the following features: (i) Monitoring:nvironmental and social monitoring during the construction and)perational phase of the school, in order to measure the success of the

itigation measures. Specifically: (a) The need for on site constructionupervision, (b) periodic inspection of facilities post constructiontage (i.e when the school is operational) to ensure that schools

41

iaintenance plan is being implemented, e.g. the site has regular,

u ninterrupted water supply, toilets are working, waste material is

disposed of as required, etc. and that regular maintenance( nalfunctions/faults are repaired in a timely manner) is occurring.

(1) If the L cal Government Authorities find that the submitted modified design

is not c nsistent with the requirements of the screening form and checklist,

then the SB would be requested to make additional modifications and/or

chose ol her sites until it is consistent whereby clearance would then be given

as per ( ) above.

(m) Any pr posed design that does not comply with the requirements of the

Environ ment regulations, NEMC requirements and the World Bank Policy

OP 4.0 on Environmental Assessment will not be cleared for approval/

constru tion.

8.3 The proces is designed to ensure that the environmental and social assessment

process is part of a d conducted during the planning stages with full participation of the

local community, t ereby ensuring that project activities are environmentally and socially

sustainable.

Figure 8.1: Summary of Key Roles in the Environmental and Social Review Process:

42

Fig 8.2: Key stages of sub project as it applies to Environmental and Social Management

only. Other key stages of the sub project cycle omitted for claritv -

STEP 1: STEP 2 STEP 3

Project Start-Up Capacity Building and Training at Local Govemment District Educational Planning

Implementation p* Authority level for review, clearance of school design In consultation with and active participation of local communities,details/packages and on environmental/social the Local Government Authorities consistent with their

monitoring as per proposed training program in Section * 0 decentralization mandate, education for all policies, local

8 of this ESMF. planning laws. national education policy, school mapping

exercise, critical needs, etc. prepares a District SecondarySchool Development Plan (DSSDP), containing inter alia,request for funding of secondary schools in their districts. Therewill be as many DSSDP's as there are districts.

STEP 6The Regional Education Officers Wil then verify, validate,

rationalize and consolidate the DSSDP's of all the districts in their _________

region Into a Regional Secondary Schools Development Plan(RSSDP). The RSSDP's will then be approved by the appropriate STEP 5 STEP 4

regional govemment in line with their decentralization by devolution The District approved DSSDP is The DSSDP is then submitted to the

polices currenuy underway in Tanzania. Since there are 21 regions then sent to their respectve Regions 4 respective District Councils for

there-will be 21 RSSDPS for consolidaton, approval.

STEP 9Prioritization of DSSDP's

STEP 7 Once approval is given, the SEDP will make the block grants toSTEP 8 the Local Authorities . The Districts will further prioritize their

DSSDP, and choose which schools to build and at what locations.The region approved RSSDP's The MOEC will approve SEDP funding for This further prioritization process will be based on size of

are then sent to MOEC for S-----councils based on the RSSDP. * -* budget/block grant approved by the SEDP viz-a-viz the size of the

approval and funding from SEDP. budget of the plan, , variability of demand across district, staffing

availability, etc... Districts Capacity to implement, Districts criticalneeds, social inclusion policies, poverty and other criteria, etc.

| GotoSlep 10

I|From Step9 |

STEP 11 -Environmental and Social Mansoement Proess Beains

sTEP o For approved schools, the SB's prepare schools packagebased on customized standard designs, including engineering

At locations where new schools 0 designs, civil works contracts etc. During this stage, the SB

are to be builtc Local use the environmental and social screening form and checklist

Goverment Authorities to identify adverse impacts and then to identify and incorporateGovensurnmesntcfooimourd (S corresponding mitigation measures and initiate contracting

consistent with tenderng rules. is correspon s os ps ato (m) in Section 9.0 of this ESMF.

STEP 14 STEP 13Implementation STEP 12

Environmental and Social Manaaement Only after clearance of SB designProcess Continues package is funding released by Local * * Environrnental and Social Management Process Continues

Continued Environmental and Social 4 - Govemment Authorities to SB's. SB's SB's submits school design package to Local Government

Management (including monitoring) as schools tender for civil works contractors and Authorities for review and clearance.

are constructed, through day-to-day operations construction starts.and also at maintenance stages, as detailed inthis ESMF.

9. MONITORING PLAN

9.1 The objecti, e for monitoring is two fold.

1) to alert project authorities and to provide timely information about theeffectiveness of the Environmental and Social Management process outlined inthe ESMF n such a manner that changes can be made as required to ensurecontinuous mprovement to the process.

2) to make a final evaluation in order to determine whether the mitigationmeasures d signed into the District School Construction program/activities havebeen succes sful in such a way that the pre- program environmental and socialcondition h s been restored, improved upon or worst than before and to determinewhat furthe] mitigation measures may be required.

9.2 A number cf indicators would be used in order to determine the status of affectedpeople and their environment (land being used compared to before, how manyclassroom/school places available compared to before, are marginalized groups being

included etc). Ther fore, the projects Environmental and Social Management process willset two major socic -economic goals by which to evaluate its success:

* Has the pre -project environmental state of natural resources, bio-diversity andflora and fa na, been maintained or improved upon at school sites, and

* The effectiveness of the ESMF technical assistance, review, approval andmonitoring process.

9.3 In order to assess whether these goals are met, the Districts will indicate

parameters to be monitored, institute monitoring milestones and provide resourcesnecessary to carry out the monitoring activities.

9.4 The follow ng are some pertinent parameters and verifiable indicators to be usedto measure the ES F process, mitigation plans and performance;

* Number of Local Government Authorities staff who have successfully receivedESMF trai ing

* Number of School t Boards using the screening form and checklist.

* Efficiency of Schools maintenance and operating performance .

* How many completed newly built/ rehabilitated schools are in good workingcondition o ne year, two, three years after completion.

* How manv District's/Schools have implemented an effective and workingfacilities m intenance program.

45

* Are the w ter, drainage and sewage facilities in working and acceptablecondition, 6 months, one year, two years and three years after completion.

* Out of the number of poor and vulnerable people/groups identified in each

District in t e Social Assessment Studies, how many of them are;(i) targeted forprovision of access to school, ii) at what rate are they being enrolled and (iii) how

many have access to secondary school places at the end of Year 1, Year 2 Year 3,Year 4 etc. i the project cycle.

* What techn ques are the District's employing to ensure vulnerable groups are

consulted a d are benefiting from project activities. Are these techniques

working.

* At what fr quency and rate are the Districts monitoring the activities of the

School t Bo rds at all stages.

How many Districts are up to date with their periodic monitoring reports.

Is NEMC r ceiving the periodic monitoring reports of the Districts and what are

the main co icerns of the NEMC at this stage.

Is the MOE ̂ receiving and compiling the periodic reports of the Districts and is it

forwarding t to the NEMC?

9.5 Other indic Ltors can be developed based on the results of the social assessment.

MONIT RING ROLES AND RESPONSIBILITIES 7 (REFER TO FIG. 8.1)

School Boards (S 's)

9.6 It is plann d that the environmental and social impacts and their designed

mitigation mea ures are to be monitored during implementation(construction/reha ilitation works) and operation (including maintenance) stages of the

school constructior program. The roles and responsibilities for monitoring impacts and

mitigation measure s will be as follows; the SB's assisted by their service providers, will

monitor the envir nmental and social impacts and mitigation measures of their own

school constructior activities as contained in their completed screening forms, checklist

and all other doc ments in their individual application 8 The SB's will monitor and

evaluate the envi nmental and social impacts of their school construction and the

mitigation measure designed, regularly and as frequently as specified in their applicationand will maintain uitable records to be made available to their respective District. The

SB's will monitor he impacts and mitigation measures during all phases of their school

construction exec tion cycle, i.e., from planning stage to construction, operations andmaintenance stage . The SB's will also be responsible for monitoring the environmentaland social impacts and mitigation measures resulting from the action of their contractors,sub contractors, tr nsporters, suppliers and all other third parties in the course of their

7 Capacity building ne ds to achieve and sustain this have been addressed in Section 88 Application refers o the complete set of school construction documents including the completed

screening forms, chec list, ESMP, technical designs, drawings, civil works contracts, etc.

46

duties. Further, the B's would also be responsible for monitoring the environmental andsocial impacts and mitigation measures of their school construction activities at otherlocations beyond t eir project sites, at end user locations such as on nearby wetlands,game parks etc.

9.7 Therefore, herever environmental and social impacts are or can be attributed totheir school const ction activities the appropriate mitigation measures will apply

consistent with th ESMF, and the SB's would be responsible for monitoring andevaluating the sam The SB's will prepare and submit periodic monitoring reports totheir respective Dis ricts.

The Local Govern ment Authorities (LGAs)

9.8 The LGAs ill play the leading role of monitoring the activities of the SB's intheir District. The LGAs will carry out this role by ensuring that the SB's environmentaland social manage nent plan (ESMP) contained in the cleared project application/designpackage is being i nplemented as specified therein. That is to say that the LGAs willmonitor the SB's monitoring procedures and reports on a regular basis, perhaps quarterly.They will rely on a bottom up feed back system to them from the SB's by going throughtheir monitoring eports and making regular site visits to inspect and verify forthemselves the na ure and extent of the impacts and the success or lack off, of themitigation measure .

9.9 The LGAs will prepare consolidated periodic monitoring reports for submissionto the Region and MOEC.

The National Env ronment Management Council (NEMC)

9.10 The NEMC will do on the ground ESMF performance reviews/audits both forenforcement purpo es and to reinforce the training and to keep the SB's and the LGAs

cognizant of their responsibilities. The NEMC's will carry out this role by reviewing ineach District; (i) t e completed screening form and application package prepared by theSB's as they are su mitted to their LGAs, (ii) the appraisal form completed by the LGAsand the clearance 4lecision contained therein (iii) a visit to the school construction siteduring constructior to ensure construction activities going on as contained in EMP andcivil works contra t and after construction completion to ensure school maintenanceprogram is being in plemented as designed.

9.11 In addition o on the ground environmental reviews and implementing the trainingprogram, the role (If the NEMC will be monitoring as detailed in Section 8.0. They will

perform this role by reviewing periodic reports from the Districts, prepare consolidatedperiodic monitorin reports and make spot/unannounced site inspections at the Districtlevel. The NEMC vill report its findings to the MOEC and the Districts.

47

The Ministry of Es ucation and Culture (MOEC)

9.12 The MOEC will monitor the activities of the Districts and the roles of the NEMC

by reviewing the consolidated periodic monitoring reports of the NEMC and byconducting periodic technical audits of the Districts.

9.13 In conclusi n therefore, the system for monitoring functions on a bottom upapproach, on the o e hand, in terms of placing monitoring responsibilities on the SchoolBoards (SB's) and local communities who are then supervised and monitored by theirLGAs who in turn re accountable to the MOEC and the NEMC. On the other hand, thissystem is made fur ctional by the transfer of appropriate technology, capacity buildingthrough training (m stly through learning by doing) and technical assistance and, budgetsupport in the top lown direction. This system for monitoring is thus strengthened andsustainable and sho ild yield successful results overall.

Monitoring Plan ( rable 9.1)

9.14 This monito ing plan consists of a set of mitigation, monitoring and institutionalmeasures to be taken during implementation/construction and operations of theparticipating Distri ct's school construction activities, to eliminate adverse environmentaland social impacts offset them, or reduce them to acceptable levels. The plan alsoincludes actions ne ded to implement these measures. The monitoring plan specifies themonitoring measur s to be carried out with linkages to the potential adverse impacts thatwould have been id ntified through a process contained in Section 9.0, by:

1. Schedul ng and coordinating monitoring tasks.

2. Evaluati ng mitigation effectiveness.3. Identifying where applicable, corrective management practices.4. Ensuring that monitoring findings are suitably evaluated and incorporated into

future management decisions.

48

I

- ~ ~

Table 9.1: Monitoring Plan

Potential Social and Mitigation Measures Monitoring Phase/Stage Responsibility CostsEnvironmental Measures

Negative ImpactsI.Deforestation Fully implement the ESMF, Periodic monitoring On going throughout 1. Participating School Refer to Table 10.22. Land Degradation, RPF, use screening form and and evaluation of the life of the district Boards (SMB)9 .including soil elosioii cliecklist in Ainiex 3.0 aud vetifialde indicatoLs secoldaty sciool Nub 2. Respective3. Water 4.0), addressing specific for all impacts projects and project Districts' 0

Contamination. mitigation measures such as identified in the sub and beyond thereby 3.MoEC"4.Disturbance of training and capacity building project ESMP and ensuring the 4. NEMC' 2

Natural Habitats and to use modem and appropriate examples of which are institutional 5. The SB's and theWildlife. technologies for design and contained in this arrangements are Councils will be5.Degradation of implementation of district Section above. sustainable beyond the assisted by serviceWetlands secondary school sub projects, life of the program. providers and will6. Social Exclusion efficiency use, environmental receive training.7. Loss of land, impact restoration, regular andon livelihoods, loss of suitable maintenance ofassets, loss of access to infrastructure/equipment/plant,natural resources. etc.(see Section 7 of

ESMF. for completelists)

9The SB's monitoring role is detailed in Section 10.1.110 The LGAs monitoring role is detailed in Section 10.1.2" The MOEC's monitoring role is detailed in Section 10.1.412 The NEMC's monitoring role is detailed in Section 10.1.3

50

Costs for Impleme kting the Monitoring Plan

9.15 The Minist ̂ y of Education and Culture (MOEC) will be responsible for

implementing the monitoring plan. The School t Boards will be responsible for recruiting

their own service p roviders that would work with them. Budget for implementation and

monitoring includir g capacity building will be borrowed from previous NEMC and will

be integrated in SE P.

51

10. STAKEHOLDER CONSULTATIONS

10.1 The purpose of consultations is to seek the participation of the Tanzanian people

in national develo ment. This is a centerp-iece strategy of the Government in the

decentralization by devolution process in Tanzania, in general, thereby ensuring good

governance, but raore particularly to introduce transparency, accountability and

sustainability into t e SEDP. Ultimately, this process would build social capital in the

communities and nhance the opportunity for equal access to and benefit from the

planned expansion f access to secondary education.

10.2 The key sta e holders in this process are:

* The local c munities in the participating Districts;* The School oards, The Local Government Authorities, and The Regions;

* The Gove ent;* Local NGO and the Civil Society Associations; and

* Local and I Lternational Donor Agencies.

10.3 The SEDP depends on the meaningful participation of all stakeholders for

success. Opportu ities for effective consultation and participation of the ESMF

formulation and im lementation include the following:

* During pre aration of the Environmental and Social Management Framework(ESMF) a d the Resettlement Policy Framework (RPF), the Governmentconsulted t e key ministries and Agencies involved in Education and environment

matters at t e central and district levels. Development Partners, NGOs and Civil

Society Ass ciations and local communities were also consulted.

* The ESMF and RPF will be disclosed in Tanzania and at the World Bank's

infoshop.

10.4 Consultatio 1s will continue during the entire SEDP implementation, particularly

in the following as ects:

* Dur ng capacity building activities. Care will be taken so that members ofloca communities are selected using participatory methods ensuring socialexc usion of some groups does not occur.

* At ach level of planning, the communities and School Boards will havean pportunity to participate. Monitoring indicators will be prepared bythe Local Government Authorities and the regions to ensure thatco munities are participating and that no social group is left out.

* Dur ng the implementation of the construction program.

52

ANNEXES

53

ANNEX 1.0

WORLD ANK ENVIRONMENTAL AND SOCIAL SAFEGUARD POLICIES

SUMMARY

* Environmental Assessment (OP 4.01). Outlines Bank policy and procedure for the

environmental assessment of Bank lending operations. The Bank undertakes

environmental sreening of each proposed project to determine the appropriate extent

and type of EA process. This environmental screening process will apply to all sub-

projects to be funded by SEDP.

* Natural Habita ts (OP 4.04). The conservation of natural habitats, like other measures

that protect an enhance the environment, is essential for long-term sustainable

development. The Bank does not support projects involving the significant

conversion of tural habitats unless there are no feasible alternatives for the project

and its siting, a d comprehensive analysis demonstrates that overall benefits from the

project substa tially outweigh the environmental costs. If the environmental

assessment ind cates that a project would significantly convert or degrade natural

habitats, the p oject includes mitigation measures acceptable to the Bank. Such

mitigation mea ures include, as appropriate, minimizing habitat loss (e.g. strategic

habitat retentio and post-development restoration) and establishing and maintaining

an ecologically similar protected area. The Bank accepts other forms of mitigation

measures only when they are technically justified. Should the sub-project-specific

EAs indicate t at natural habitats might be affected negatively by the proposed sub-

project activiti s, such sub-projects will not be funded under the SEDP.

* Pest Manage ent (OP 4.09). The policy supports safe, affective, and

environmentall sound pest management. It promotes the use of biological and

environmental control methods. An assessment is made of the capacity of the

country's reg latory framework and institutions to promote and support safe,

effective, and nvironmentally sound pest management. This policy will most likely

not apply to S DP.

* Involuntary R settlement (OP 4.12). This policy covers direct economic and social

impacts that b h result from Bank-assisted investment projects, and are caused by (a)

the involunta taking of land resulting in (i) relocation or loss of shelter; (ii) loss of

assets or acce s to assets, or (iii) loss of income sources or means of livelihood,

whether or not the affected persons must move to another location; or (b) the

involuntary re triction of access to legally designated parks and protected areas

resulting in ad erse impacts on the livelihoods of the displaced persons. This policy is

triggered by th SEDP and therefore the Government has prepared and disclosed the

required Reset lement Policy Framework (RPF).

* Indigenous P oples (OD 4.20). This directive provides guidance to ensure that

indigenous pe ples benefit from development projects, and to avoid or mitigate

adverse effect of Bank-financed development projects on indigenous peoples.

Measures to a dress issues pertaining to indigenous peoples must be based on the

54

informed partici pation of the indigenous people themselves. Sub-projects that would

have negative in ipacts on indigenous people will not be funded under SEDP .

* Forests (OP 4. 36). This policy applies to the following types of Bank-financed

investment proj .cts: (a) projects that have or may have impacts on the health and

quality of fores s; (b) projects that affect the rights and welfare of people and their

level of depend nce upon or interaction with forests; and (c) projects that aim to bring

about changes n the management, protection, or utilization of natural forests or

plantations, wh ther they are publicly, privately, or communally owned. The Bank

does not financ projects that, in its opinion, would involve significant conversion or

degradation of ritical forest areas or related critical habitats. If a project involves the

significant con rsion or degradation of natural forests or related natural habitats that

the Bank dete ines are not critical, and the Bank determines that there are no

feasible altem tives to the project and its siting, and comprehensive analysis

demonstrates t at overall benefits from the project substantially outweigh the

environmental osts, the Bank may finance the project provided that it incorporates

appropriate mit gation measures. Sub-projects that are likely to have negative impacts

on forests will ot be funded under SEDP.

* Cultural Prop ty (OPN 11.03). The term "cultural property" includes sites having

archeological rehistoric), paleontological, historical, religious, and unique natural

values. The B nk's general policy regarding cultural property is to assist in their

preservation, a d to seek to avoid their elimination. Specifically, the Bank (i)

normally declil es to finance projects that will significantly damage non-replicable

cultural propert , and will assist only those projects that are sited or designed so as to

prevent such amage; and (ii) will assist in the protection and enhancement of

cultural proper ies encountered in Bank-financed projects, rather than leaving that

protection to hance. The management of cultural property of a country is the

responsibility of the government. The government's attention should be drawn

specifically to what is known about the cultural property aspects of the proposed

project site an appropriate agencies, NGOs, or university departments should be

consulted; if th re are any questions concerning cultural property in the area, a brief

reconnaissance survey should be undertaken in the field by a specialist. SEDP will

not fund sub-p ojects that will have negative impacts on cultural property.

* Safety of Da s (OP 4.37). For the life of any dam, the owner is responsible for

ensuring that a propriate measures are taken and sufficient resources provided for the

safety to the d , irrespective of its funding sources or construction status. The Bank

distinguishes b tween small and large dams. Small dams are normally less than 15 m

in height; this ategory includes, for example, farm ponds, local silt retention dams,

and low emba ent tanks. For small dams, generic dam safety measures designed

by qualified e ineers are usually adequate. This policy will most likely not apply to

SEDP.

* Projects on ternational Waterways (O 7.50). The Bank recognizes that the

cooperation a d good will of riparians is essential for the efficient utilization and

protection of nternational waterways and attaches great importance to riparians

making approi riate agreements or arrangement for the entire waterway or any part

55

thereof Project that trigger this policy include hydroelectric, irrigation, flood

control, navigat on, drainage, water and sewerage, industrial, and similar projects that

involve the use or potential pollution of international waterways. This policy most

likely will not a ply to the SEDP.

Disputed Areas (OP/BP/GP 7.60). Project in disputed areas may occur the Bank and

its member coui tries as well as between the borrower and one or more neighbouring

countries. Any dispute over an area in which a proposed project is located requires

formal procedu res at the earliest possible stage. The Bank attempts to acquire

assurance that it may proceed with a project in a disputed area if the governments

concerned agree that, pending the settlement of the dispute, the project proposed can

go forward wit out prejudice to the claims of the country having a dispute. This

policy is not e pected to be triggered by sub-projects. This policy is unlikely to be

triggered by su -projects to be funded by SEDP.

56

ANNEX 2.0ENVIRONMENTAL AND SOCIAL SCREENING FORM

The Environmental and Social Screening Form (ESSF) has been designed to assist in the

evaluation of desi n proposals for the new secondary school construction and

rehabilitation prog am. The form is designed to place information in the hands of

implementers and reviewers (i.e. the School Management Boards and District

Environmental Coo dinators) so that impacts and their mitigation measures, if any, can be

identified and/or tha t requirements for further environmental analysis be determined.

The ESSF contai ns information that will allow reviewers to determine the

characterization of 1 he prevailing local bio-physical and social environment with the aim

to assess the potent al project impacts on it. The ESSF will also identify potential socio-

economic impacts that will require mitigation measures and or resettlement and

compensation.

Name of Village/T wn/Area in which School is to be Built:

Name of Contact P rson on School Board:

Name of District w] iere school is to be built:

Name of Approvin Authority ( District environmental Coordinator):

Name, job title, an contact details for the person who is responsible for filling out this

form.

Name:

Job Title:

Telephone number:

Fax number:

E-Mail address:

Date:

Signature:

57

1. Brief School/ Project DescriptionPlease provide info ation on the number of students who will attend the school, the

range of their ages, nd the standards they will be in, in the following year. Also provide

area of acquired lan and approximate size of total building floor areas.

2. The Natural En ironment(a) Describe the Ian formation, topography, vegetation in/adjacent to the Project area

(b) Estimate and in icate where vegetation might need to be cleared

(c) Are there any e vironmentally sensitive areas or threatened species (specify below)

that could be adver ely affected by the project?

(i) Intact n tural forests Yes No_

(ii) Riveri e forest Yes No_

(iii) Wetla ds (lakes, rivers, seasonally inundated areas) Yes No_

(iv) How r is the nearest Wetlands((lakes, rivers, seasonally inundated areas)?km

(v) Habita s of endangered species for which protection is required under

Tanzania 1w and/or international agreements. Yes No_

(d) Protected areas

Does the sub proj ct area (or components of the project) occur within/adjacent to any

protected areas des gnated by government (national park, national reserve, world heritage

site etc.)

Yes No _

If the project is ou side of, but close to, any protected area, is it likely to adversely affect

the ecology within the protected area areas (e.g., interference with the migration routes of

mammals or birds)

Yes No _

(vi) Others (descri e). Yes No_

If "Yes", to any o e of the above, tick the following boxes as appropriate:

0 The Environmen al Management Plan (EMP) included in this school application

contains measures o suitably address these impacts adequately.O The Architectura I and Engineering drawings, included in this school application

contains measures o suitably address these impacts adequately.ClThe Proposed ci il works contract included in this school application contains

measures to suitab y address these impacts adequately.

58

3. Rivers and Lak s EcologyIs there a possibilit -that, due to construction and operation of the project, the river and

lake ecology will be adversely affected? Attention should be paid to water quality and

quantity; the nature productivity and use of aquatic habitats, and variations of these over

time.

Yes No

If "Yes", tick the f llowing boxes as appropriate:O The Environment 1l Management Plan (EMP) included in this school application

contains measures tD suitably address these impacts adequately.O The Architectural and Engineering drawings, included in this school application

contains measures t suitably address these impacts adequately.O The Proposed civ 1 works contract included in this school application contains

measures to suitabl address these impacts adequately.

4. Geology and So IsBased upon visual nspection or available literature, are there areas of possible geologic

or soil instability (e osion prone, landslide prone, subsidence-prone)?

Yes No

Based upon visual nspection or available literature, are there areas that have risks of

large scale increas in soil salinity?

Yes No

If "Yes", to any o e of the above, tick the following boxes as appropriate:

O The Environmen al Management Plan (EMP) included in this school application

contains measures o suitably address these impacts adequately.O The Architectura and Engineering drawings, included in this school application

contains measures lo suitably address these impacts adequately.

O The Proposed ci il works contract included in this school application contains

measures to suitab address these impacts adequately.

5. Landscape/aest eticsIs there a possibil y that the school will adversely affect the aesthetic attractiveness of

the local landscape.

Yes No

If "Yes", tick the Following boxes as appropriate:O The Environme al Management Plan (EMP) included in this school applicationcontains measures o suitably address these impacts adequately.O]The Architectur 1 and Engineering drawings, included in this school application

contains measures o suitably address these impacts adequately.O The Proposed ci il works contract included in this school application contains

measures to suitab y address these impacts adequately.

59

6. Historical, archa eological or cultural heritage site.

Based on available sources, consultation with local authorities, local knowledge and/or

observations, could the school alter any historical, archaeological or cultural heritage site

or require excavatio near same?

Yes No _

If "Yes", tick the f Ilowing boxes as appropriate:O The Environment 1 Management Plan (EMP) included in this school application

contains measures t suitably address these impacts adequately.O The Architectural and Engineering drawings, included in this school application

contains measures t) suitably address these impacts adequately.[ The Proposed civ 1 works contract included in this school application contains

measures to suitabl address these impacts adequately.

7. Resettlement an /or Land Acquisition

Will involuntary re ettlement, land acquisition, or loss, denial or restriction of access to

land and other eco mic resources be caused by project implementation?

Yes No

If "Yes" Involunt ary Resettlement OP 4.12 is triggered. Please refer to RPF for

appropriate mitigat on measures to be taken.

8. Loss of Crops, ruit Trees and Household InfrastructureWill the project res ut in the permanent or temporary loss of crops, fruit trees and

household infra-st cture (such as granaries, outside toilets and kitchens, etc)?

Yes No_

If "Yes", tick the iollowing boxes as appropriate:E1 The Environmen al Management Plan (EMP) included in this school application

contains measures o suitably address these impacts adequately.1 The Architectura and Engineering drawings, included in this school application

contains measures o suitably address these impacts adequately.C The Proposed ci il works contract included in this school application contains

measures to suitabl address these impacts adequately.

9. Noise pollutio during Construction and Operations.Will the operating oise level exceed the allowable noise limits?

Yes_No_

60

If "Yes", tick the f Ilowing boxes as appropriate:

[ The Environment l Management Plan (EMP) included in this school application

contains measures t suitably address these impacts adequately.

Cl The Architectural nd Engineering drawings, included in this school application

contains measures t suitably address these impacts adequately.

] The Proposed civi works contract included in this school application contains

measures to suitabl address these impacts adequately.

11. Solid or Liquid Wastes.Will the project ge nerate solid or liquid wastes?

Yes No_

If "Yes", tick the f llowing boxes as appropriate:DThe Environment 1 Management Plan (EMP) included in this school application

contains measures t suitably address these impacts adequately.

l The Architectural and Engineering drawings, included in this school application

contains measures t suitably address these impacts adequately.

F The Proposed civ 1 works contract included in this school application contains

measures to suitabl address these impacts adequately.

12. Public Consul ationHas public consul ation and participation been sought?

Yes No

If "Yes", describe riefly the measures taken to this effect.

CERTIFICATIO

We certify that w have thoroughly examined all the potential adverse effects of this

secondary school pplication. To the best of our knowledge, the proposed secondary

school as describ d in the application and appended design reports (e.g. EMP, RAP,

completed screenil ig form, proposed civil works contract, etc. ), if any, will be adequate

to avoid or minimi e all adverse environmental and social impacts.

Representative of chool Board (signature):

...................... ......... .....................................Service Provider ( ignature):...................... ..... ......................................

Date: ........... .......................

FOR OFFICIAL USE ONLYDesk Appraisal b Local Government Authorities

61

The Secondary Sc ool Application can be considered for approval. The application is

complete, all signifi ant environmental or social issues are resolved, and no further

subproject planning is required.

A field appraisal i required.Note: A field appra sal must be carried out if the school application:

* Needs to quire land, or an individual or community's access to land oravailable re ources is affected or changed, or any individual or family isdisplaced

* Encroach s onto an important natural habitat, restricts access to resourceswithin that rea, or may affect ecologically sensitive ecosystems (e.g. rivers,

streams, wei lands)* Involves, c r results in: a) diversion or use of surface waters; b) construction

and/or reha 5 ilitation of latrines, septic or sewage systems; c) production of waste(e.g. slaughi erhouse waste, medical waste, etc); d) new or rebuilt drainage

systems; or 9) reservoirs or water points.

The following issue s need to be clarified at the school site:....................... ........ ....................................................................................................... ........ ................................................................................

....................... ........ ................................................................................

A Field Appraisal teport will be completed and added to the school application file.

Name of Local Go) rermient Authority Director (print):....................... .......... ..............................Signature:...... I................. ........ ..............Date:.........................................

62

ANNEX 3.0 TYPICAL CHECKLIST TO IDENTIFY IMPACTS AND MITIGATION MEASURES OF CONSTRUCTION AND/OR REHABILITATION

OF TANZANIA SECOND EDUCATION DEVELOPMENT PROGRAM (SEDP)

Environmental andSocial Components Impacts Mitigation Measures

Physical Environment Refer to Annex 2.0 for summary of safeguard policies

Soils * Erosion of lands down slope from borrow areas. Construction in dry season; protection of soil surfaces

* Landslides and slips. during construr; e-vcgetiun ui phys

* Contamination from waste materials, e.g. cement and paints, stabilization of erodable surfaces. Land restoration

engine oils, etc. measures.

* Excavating borrow pits for aggregate materials (sand and stone) for Adequate protection from livestock entry by fencing the site

concrete. perimeters.

* Cutting of stone for use on fa9ades. Control and daily cleaning at construction sites,

Provision of adequate waste disposal services.

Proper disposal of chemicals and other hazardousmaterials.

Dust control by water, appropriate design and siting, restrict

construction to certain times.

Appropriate and suitable storage of building materials on

site.

Water Resources * Creation of stagnant water pools Special attention to drainage; prevention of erosion;

- Increased sediments into streams consideration of alternative alignments; retention ponds;

- Clogging of drainage works proper disposal of oil and other hazardous materials

e Decline in water quality Siting of Latrines at safe distances from wells and using

* Increase in runoff and flooding conditions closed systems for sewage drainage.

* Introduction of hazardous wastes

* Contamination of Wells

Air Quality - Dust during construction Dust control by water or other means.

- Poor air circulation/quality in classrooms. Ensure designs incorporate large windows covered by longoverhanging roofs. Position windows for natural crossventilation. Use appropriate roofing materials with

suitable insulation.

Acoustic Environment * Noise disturbance Restrict construction to certain hours

Bio-physical Environment Refer to Annex 2.0 for summary of safeguard policies.

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Environmental andSocial Components Impacts Mitigation Measures

Natural Habitats * Disturbance of natural habitats Consideration of alternative alignments or sites (especially

* Disturbance to protected areas for new schools)

Fauna and Flora * Disruption or destruction of wildlife Minimize loss of natural vegetation during construction;

* Threats to rare and endangered species alternative sites; various special measures for sensitive

species

Social Environment Refer to Annex 3.0 for summary of safeguard policies.

Aesthetics and Landscape * Marred landscapes Restoration of vegetation; cleanup of construction sites

* Debris

Historical/Cultural Sites -Degradation of sites Alternative alignments and/or sites

* Disturbance to structures Special measures to protect cultural heritage sites

Human Health * Transport of hazardous substances Regulation of transport of materials

* Traffic accidents Safety designs (signage)

* Pedestrian accidents Ensure availability of clean potable water for use in latrines,

* Personal hygiene of students and teachers. canteens and for drinking.Use of appropriate building materials. No asbestos etc.

Human Communities * Involuntary resettlement Prepare Resettlement and Compensation Plans consistent

* Loss of crops, buildings, property, or economic livelihood with disclosed RPF as per OP 4.12

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ANNEX 4.0ENVIRONMENTAL MITIGATION PLAN FOR SEDP

Project Mitigati n Implementing Monitoring Timing Costs

Activities Mensur s Agencies Responsibility

Construction of Environ nental and School District Ongoing Included in

schools social sc eening Management Environmental program

Public Boards Coordinator TBD

consulta ions/ School Boards, MOEC Included in

sensitiz ion District and sub-projects

Regional TBD

Prepare RAPs as Governments Districtnecessa School Boards Environmental Ongoing Included in

(SB's) Coordinator program

Environ ental SMB's /service District Ongoing

guidelin s for providers Environmental Included in

contract rs Coordinator. contract

Regular SBmainten nce of Included in

water points & program.

latrines, solid waste See Table

disposal,, school 10.2

buildin s,compo d, etc.

Training of NEMC MOEC TBD TBD

(DistrictEnvironmentCoordinators/serviceproviders)

__ _ _ __ _ _ ___ _ _ __ _ _ __ _ _ __ _ _ __ _ _ _ Total Costs TBD

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ANNEX 5.03

ENVIRON ENTALLY SENSITIVE AREAS ( ESA'S) AND ECOSYSTEMS

1. Areas pron to natural disasters (geological hazards, floods, rain storms,

earthquakes, landslides, volcanic activity, etc.)

2. Wetlands: ( lood plains. Swamps, lakes, rivers, etc.) water bodies.

3. Areas susce tible to erosion e.g. (a) hilly areas with critical slopes and (b)

unprotected r bare lands.

4. Areas of im ortance to threatened cultural groups.

5. Areas with r re/endangered/or threatened plants and animals.

6. Areas of uni ue socio-cultural, historic archaeological, scientific, tourist areas.

7. Polluted are s.

8. Area subjec to desertification and bush fires.

9. Coastal are s and Marine ecosystems., such as coral reefs, Islands, lagoons and

estuaries, c ntinental shelves, beach fronts and inter tidal zones.

10. Areas decl ed as, national parks, water shed reserves, forest reserves, wildlife

reserves an sanctuaries, sacred areas wildlife corridors and hot spring areas.

11. Mountaino s areas, water catchment areas and recharge areas of aquifers.

12. Areas classi ied as prime agricultural lands or range lands.

13. Green belts or public open spaces in urban areas.

14. Burial sites nd graves.

13 Culled from Appen ix 10 of Vol. 1, Tanzania Environmental Impact Assessment Procedure and

Guidelines (rev. Marc 2002).

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ANNEX 6.0NVIRONMENTAL AND SOCIAL APPRAISAL FORM

The Environmental nd Social Appraisal Form (ESAF) has been designed to assist in the

evaluation of desi n proposals for the new secondary school construction and

rehabilitation progr m. The form is designed to place information in the hands of the

Local Government Authority MOEC and the NEMC so that school applications for

environmental and, ocial clearance can be reviewed and cleared.

The ESAF conta ns information that will allow reviewers to determine the

characterization of he prevailing local bio-physical and social environment with the aim

to assess the potent al project impacts on it. The ESAF will also identify potential socio-

economic impacts that will require mitigation measures and or resettlement and

compensation.School Application Number:....................

Part 1: Identification

1. School Na e:

2. School Loc tion:

3. Reason for ield Appraisal: Summarize the issues from the ESMF Checklist that

determined the needfor a Field Appraisal.

4. Date(s) of ield Appraisal:

5. Field Appr isal Officer and Address:

6. Service Pro vider Representative and Address:

7. School Bo d Representative and Address:

Part 2: Description of the School Application

8. School Ap lication Details: Provide details that are not adequately presented in

the secondary sch ol application. If needed to clarify school application details, attach

sketches of the su project component(s) in relation to the community and to existing

facilities

Part 3: Environmental and Social Issues

9. Will the project* Need to ac uire land? Yes . ..... .......

* Affect an i idividual or the community's access to land or available resources?

Yes . o.

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Displace or esult in the involuntary resettlement of an individual or family?

Yes. N

If "Yes", tick one Of the following boxes:El The Resettlement Action Plan (RAP) included in the subproject application is adequate.No further action re 4uired.[1The RAP incluc ed in the subproject application must be improved before theapplication can be c nsidered further.G-1A RAP must be prepared and approved before the application can be consideredfurther.

10. Will the project* Encroach or to an important natural habitat? Yes ...... No.

* Negatively E ffect ecologically sensitive ecosystems? Yes ... No.

If "Yes", tick one (of the following boxes:[HThe Environmen al Management Plan (EMP) included in the school application isadequate. No furthe action required.LlThe EMP includ d in the school application must be improved before the applicationcan be considered f irther.[]An EMP must be prepared and approved before the application can be consideredfurther.

11. Will this projec involve or result in:* Diversion o use of surface waters?

* Constructioil and/or rehabilitation of latrines, septic or sewage systems?

* . Production of waste (e.g. slaughterhouse waste, medical waste, etc.)?

* New or rebt ilt irrigation or drainage systems?

If "Yes", tick one f the following boxes:E The application d scribes suitable measures for managing the potential adverseenvironmental effe ts of these activities. No further action required.[I The application d Des not describe suitable measures for managing the potential adverseenvironmental effe ts of these activities. An Environmental Management Plan must beprepared and appro ed before the application is considered further.

12. Are there any o her environmental or social issues that have not been adequatelyaddressed?

If "Yes", summari ze them:

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and tick one of the following boxes:u Before it is donsidered further, the application needs to be amended to includesuitablemeasures for addres sing these environmental or social issues.D .An Enviror nental Management Plan needs to be prepared and approved beforethe application is ccnsidered further.

Part 4: Field Appraisal Decision

C The school appli ation can be considered for approval.

Based on a site visil and consultations with both interested and affected parties, the field

appraisal determine d that the community and its proposed secondary school applicationadequately address environmental and/or social issues as required by the SEDP's ESMFand meets the reqt irements of Environment Act, in Tanzania, NEMC and the WorldBank OP4.01

] Further subproj ct preparation work is required before the application can beconsidered furthei.

The field appraisal ias identified environmental and/or social issues that have not beenadequately addres, ed. The following work needs to be undertaken before furtherconsideration of the application:

All required docut nentation such as an amended application, EMP, RAP, ScreeningForms, draft Civil works contracts, etc., will be added to the school application package

before it is conside ed further.

Name of Local GoN ernment Authority designated staff....................... ......... I..........................................Signature:....................... .. ...........................

Date: ...........

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