Federal University Otuoke EIA CHAPTER SIX MITIGATION AND AMELIORATION 6.1 Introduction Chapter 5 presented the basis for identifying, quantifying and ranking of the potential impacts, which are likely to arise as a result of the Federal University Otuoke (FUO) permanent site project. This indicated that various components of the biophysical, health and social environments would be impacted. The negative impacts identified through that analysis were ranked as low, medium or high. In order to reduce the impact of the proposed development to acceptable levels (or where this is not possible to as low as reasonably practicable (ALARP)), a number of actions is proposed to mitigate the high and medium negative impacts. The development also results in positive impacts and a number of measures are also proposed to enhance these effects. The residual impacts that arise despite the mitigation measures are discussed in order to keep any inability to mitigate these to a low level. The mitigation measures proposed for the predicted medium and high-ranking impacts arising from this Project recognized the following: Environmental laws in Nigeria, with emphasis on permissible limits for waste streams - FMEnv Best Available Technology for Sustainable Development Feasibility of application of the measures in Nigeria Concerns expressed by stakeholders during consultation meetings and the socioeconomic/health status of the host communities. These mitigation measures are presented in Table 6.1. Chapter Six: Mitigation and Amelioration 6-1 Federal University Otuoke EIA Table 6.1: Project Phase Project Activity Proposed Mitigation Measures Description of ImpactSignificance Mitigation Rating Before Mitigation Mobilization Movement of goods, equipment and personnel Potential increase in road traffic volume High Potential increase in road traffic incidents Medium Increase in noise levels High Chapter Six: Mitigation and Amelioration Large and slow moving vehicles should be scheduled during off peak periods Ensure maintenance of Otuoke road of any damage caused by project Raise community awareness of unusual activity through the Director of works and Security department team. Pre-mobilization of all vehicles Visible warning signs on roads and vehicles Speed breakers at sections traversing communities Flag men at road intersection First aid training of workforce and provision of first aid boxes in operational vehicles Enforce night driving policy (no night driving except when unavoidable) FUO shall ensure that all vehicles and equipment conform to Regulatory limits for noise 6-2 Significance Rating After Mitigation (Residual Impact Rating) Low Low Low Federal University Otuoke EIA Project Phase Project Activity Description of ImpactSignificance Mitigation Rating Before Mitigation Construction Site preparation (Land clearing, excavation) Reduction in air quality (dust, exhaust fumes) Damage to the Otuoke Road Loss of flora and fauna Medium FUO shall ensure that only vehicles with road worthiness certificates are used to reduce emissions from vehicle exhaust High Medium FUO shall ensure repair of road when damage is caused by the project Site clearing shall commence from developed (e.g. roads) to undeveloped areas to provide escape routes for wildlife Hunting by employees of contractors shall be prohibited FUO shall educate construction workers on the sensitive nature of the biodiversity of the area and the need for conservation FUO shall limit cleared area to what is required FUO shall encourage the re-vegetation of land cleared for temporary use where feasible Loss of habitat Medium Chapter Six: Mitigation and Amelioration 6-3 Significance Rating After Mitigation (Residual Impact Rating) Low Low Low Low Federal University Otuoke EIA Project Phase Project Activity Description of ImpactSignificance Mitigation Rating Before Mitigation Community unrest High Chapter Six: Mitigation and Amelioration FUO shall ensure that all host communities are represented in the employment of locals during land clearing and excavation to avert any conflict that could arise from perceptions of unfairness FUO shall ensure that land clearing and excavation jobs are reserved exclusively for the host communities FUO shall abide by all MOUs signed with the host communities 6-4 Significance Rating After Mitigation (Residual Impact Rating) Medium Federal University Otuoke EIA Project Phase Project Activity Description of ImpactSignificance Mitigation Rating Before Mitigation Stress on existing Structures (security, welfare High Chapter Six: Mitigation and Amelioration FUO shall ensure that the contractors’ and FUO’s personnel develop a high level of security consciousness both within and outside the work area Daily security reports shall reviewed by the FUO security adviser and Project Manager Special security force shall be established and deployed for the project. This shall include deploying some of FUO special security to strengthen security in the project area FUO shall ensure liaison with the community to foster partnership so as to guarantee security for the project is established and sustained In order to strengthen security for the project, FUO shall contact government authorities to improve the strength of the police force at Kolo and shall consider providing assistance with equipment e.g. patrol vehicles, to ensure improved security FUO shall ensure that safety workshops to identify, evaluate and recommend contingency plans for all security risks are regularly organized 6-5 Significance Rating After Mitigation (Residual Impact Rating) Medium Federal University Otuoke EIA Project Phase Project Activity Description of ImpactSignificance Mitigation Rating Before Mitigation Increase in dust and noise Medium Potential increase in High erosion Chapter Six: Mitigation and Amelioration FUO shall ensure that nose masks and ear muffs are worn by site workers during excavation Water shall be sprayed on construction sites to reduce dust levels especially during the dry season FUO shall ensure that all construction equipment shall be in proper operating condition and fitted with standard silencing features if appropriate FUO shall construct sound proofing walls around stationary power generating sources FUO shall re-landscape areas not needed for construction as soon as possible following excavation 6-6 Significance Rating After Mitigation (Residual Impact Rating) Low Low Federal University Otuoke EIA Project Phase Project Activity Description of ImpactSignificance Mitigation Rating Before Mitigation Threat to health of workers (snake bites, insect stings, injuries etc) High Construction Changes in local population High Chapter Six: Mitigation and Amelioration FUO shall ensure use of PPE by field workers FUO will ensure there are adequately trained and sufficient numbers of first aiders at each site FUO shall ensure that anti-venom/antihistamine is provided on site to mitigate snake bites and insect stings FUO shall ensure that awareness is created among site workers and nearby communities on the likelihood of exposure to poisonous wildlife and plants Prior to commencement of the construction phase, FUO shall advertise construction jobs that will be available. This will hopefully discourage unqualified personnel from moving into the project area, thus reducing the rate at which the local population will grow FUO will look into the development of offsite job recruitment based on the training provided for local community personnel. Movement of unauthorized persons into the campus or associated work camps shall be strictly restricted 6-7 Significance Rating After Mitigation (Residual Impact Rating) Low Medium Federal University Otuoke EIA Project Phase Project Activity Description of ImpactSignificance Mitigation Rating Before Mitigation Construction Increase in morbidity High (including STIs) and mortality Chapter Six: Mitigation and Amelioration Health awareness lectures shall be given to workers on the mode of transmission of STIs (including HIV/AIDS) As much as possible provide psychological support to persons living with the HIV virus Regular spraying of camp and work sites Provision of insecticide treated nets to field workers to reduce incidence of malaria Awareness campaign shall be carried out to enlighten the communities/field workers on the common communicable diseases and the health implications of drug and alcohol abuse, unprotected sex, prostitution and the need to sustain cultural values An alcohol and drug policy shall be implemented to encourage healthy lifestyle for workers FUO shall assist the activities of the state action committee on STIs/HIV/AIDS within the local communities FUO shall ensure a site clinic is provided to take care of minor illnesses for all construction workers 6-8 Significance Rating After Mitigation (Residual Impact Rating) Low Federal University Otuoke EIA Project Phase Project Activity Description of ImpactSignificance Mitigation Rating Before Mitigation Increase in social vices Medium Chapter Six: Mitigation and Amelioration Pressure on existing infrastructures and utilities Changes in culture, lifestyle and habits High Medium Increase in potential for erosion High FUO shall encourage contractor to support sporting activities FUO shall support public health lectures with emphasis on common communicable diseases such as malaria, TB, STIs including HIV/AIDS As appropriate, FUO shall support the development of the health facility at Otuoke. FUO shall carry out enlightenment campaigns to encourage positive influences on cultural values and healthy lifestyles (e.g. breast feeding habits, alcohol and drug use, exercise, monogamy, high moral values with regard to sexuality etc) and discourage adverse influences (e.g. prostitution, drug abuse, alcoholism etc) FUO shall re-vegetate areas not needed for construction as soon as possible 6-9 Significance Rating After Mitigation (Residual Impact Rating) Low Medium Low Low Federal University Otuoke EIA Project Phase Project Activity Description of ImpactSignificance Mitigation Rating Before Mitigation Chapter Six: Mitigation and Amelioration Soil degradation Medium Injury to workers High FUO shall provide containment for chemicals and liquid discharges FUO waste management policy shall be enforced in cases of domestic waste, scrap metals, non-plastic combustible packaging materials, plastic packaging materials, drums and containers as well as medical wastes FUO shall ensure that a controlled fuelling, maintenance and servicing protocol for construction machinery at worksite is established and followed to minimise leaks and spills FUO will ensure there are adequately trained numbers of first aiders at each site. FUO shall provide and enforce appropriate use of PPEs (e.g. coveralls, hard hats, eye goggles) FUO shall ensure that health talks awareness lectures and job hazard analysis are conducted prior to work activities 6-10 Significance Rating After Mitigation (Residual Impact Rating) Low Medium Federal University Otuoke EIA Project Phase Project Activity Description of ImpactSignificance Mitigation Rating Before Mitigation Waste generation and disposal Loss of biodiversity Medium Reduction in air quality Medium Increase in High breeding ground for disease vectors and other agents of diseases Increase in nuisance Chapter Six: Mitigation and Amelioration Medium FUO shall limit cleared area to what is required FUO shall ensure that site clearing is commenced from developed (e.g. roads) to undeveloped areas to provide escape routes for wildlife FUO shall undertake to educate construction workers and locals on the sensitive nature of the biodiversity of the area and the need for conservation FUO shall ensure that hunting by employees of the contractors shall be prohibited FUO shall encourage the contractor to revegetate land cleared for temporary use where feasible FUO shall ensure that all mobile and stationary internal combustion engines are properly maintained FUO waste management policy shall be enforced FUO CLOs will ensure there is continuous communication with the communities. 6-11 Significance Rating After Mitigation (Residual Impact Rating) Low Low Low Low Federal University Otuoke EIA Project Phase Project Activity Description of ImpactSignificance Mitigation Rating Before Mitigation Chapter Six: Mitigation and Amelioration Blockage of natural drainage Medium Changes in aesthetic quality of the environment Medium Contamination of the environment by domestic wastes Potential for falls into exposed trenches (by animals, unsuspecting passers-by) Soil degradation from spills and leaks Medium Medium FUO shall put barriers and warning signs close to open trenches Low High FUO shall ensure that all maintenance and repair of equipment and vehicles is carried out in a secure location with clean-up materials (e.g. drip pans, containers, absorbent materials etc) readily available Low FUO shall ensure that wastes are disposed of at appropriate locations provided for waste disposal and collected as quickly as possible FUO shall ensure that the site restoration process is completed FUO shall re-landscape areas that are not required for operation and maintenance of the well head cellar FUO shall ensure regular collection and disposal of wastes in accordance with the project waste management plan Significance Rating After Mitigation (Residual Impact Rating) Low 6-12 Low Low Federal University Otuoke EIA Project Phase Project Activity Description of ImpactSignificance Mitigation Rating Before Mitigation Operation and Maintenance Operation and Maintenance of structures and utilities Change in the topography of the soil Exposure to radiation materials Medium FUO shall ensure that the original topography is maintained as far as practically possible Medium Low Increase in noise levels Reduction in air quality Medium Medium FUO shall ensure that adequate safety measures (appropriate PPE and engineering techniques) are put in place to avoid exposure to dangerous materials FUO shall ensure that appropriate maintenance programs are in place for all equipment. FUO shall ensure that appropriate maintenance programs are in place for all equipment Potential for erosion Medium FUO shall incorporate on-site drainage system to collect run off from all impervious on-site locations FUO shall incorporate sub-surface drains to intercept seepage and convey it to an acceptable point of disposal Low Chapter Six: Mitigation and Amelioration Significance Rating After Mitigation (Residual Impact Rating) Low 6-13 Low Low Federal University Otuoke EIA Project Phase Project Activity Description of ImpactSignificance Mitigation Rating Before Mitigation Decommissioning Restoration and Abandonment Surface equipment dismantling, Excavation, Removal and Disposal of concrete works and pipes Chapter Six: Mitigation and Amelioration Degradation of soil and surface water from spills and leaks Medium Increase in dust generation Medium Increase in noise levels Medium Increase in respiratory tract diseases Medium FUO shall provide containment for chemicals and liquid discharges FUO waste management policy shall be enforced FUO shall ensure that a controlled fuelling, maintenance and servicing protocol for operation and maintenance of machinery is established and followed to minimise leaks and spills FUO shall ensure proper use of PPEs FUO shall ensure that water is sprayed to reduce dust levels FUO shall inform communities in advance of likely increase in noise level during decommissioning FUO shall ensure proper use of PPE (ear muffs) FUO shall ensure that all personnel are medically certified for the operation prior to engagement FUO shall enforce appropriate use of PPE (nose mask) FUO shall use barriers to separate dusty activities from non dusty ones 6-14 Significance Rating After Mitigation (Residual Impact Rating) Low Low Low Low Federal University Otuoke EIA Project Phase Project Activity Description of ImpactSignificance Mitigation Rating Before Mitigation Chapter Six: Mitigation and Amelioration Increase in waste generation High Potential for community unrest (from employment, pollution and resistance to dismantling of equipment) High FUO shall ensure that wastes are disposed of in accordance with her waste management plan for this project FUO shall ensure fair community representation In the employment of local labour FUO shall ensure that the waste management plan for this project is implemented FUO shall abide by the MOUs signed with the communities for this project 6-15 Significance Rating After Mitigation (Residual Impact Rating) Low Medium Federal University Otuoke EIA 6.2 Residual Impacts after Mitigation Measures 6.2.1 Community Unrest The presence of a large number of vehicles and unusual movements is likely to create unease among the communities given the present state of the roads. As a mitigation measure, FUO shall maintain established channels of communication and inform communities in advance of activities associated with this important phase of the project. Community unrest stems primarily from (a) intra- and inter-community chieftaincy tussles; (b) perceptions of FUO’s failure to deal even-handedly with all strata of community stakeholders; and (c) claims of infrastructural deprivation. This situation may continue during the project. In order to deal with this, FUO shall establish channels of communication with the communities during all phases of the project. Furthermore, FUO shall require contractors to hire local labour where feasible, and to honour all MOU requirements with the local communities. Following the foregoing, the impact rating should drop from high to medium, rather than low because many causes of community unrest are outside the ambit of the project and therefore cannot be addressed at this stage. In the communities youth restiveness is synonymous with community unrest. This is currently high because of joblessness, high expectations, complaints of broken promises, infrastructural deprivation, lack of contract awards etc. This condition could be exacerbated by the project, especially during construction, operation and maintenance as well as during decommissioning, restoration and abandonment of facilities. During construction because of the pressure of employment; during operation and maintenance because of apparent drop in business activities; during decommissioning, restoration and abandonment because of perceived finality of project activities. As mitigation, FUO shall abide by all agreements reached with the communities; unskilled labour shall be drawn from the community; preference shall be given to qualified skilled labour from the project area; FUO shall encourage recreational activities; and maintain regular dialogue with the communities. FUO shall not play favouritism in the communities. It is important that FUO ensures that the contractors adopt transparent approaches in matters of employment even for the unskilled labour. The impact rating is expected to drop from high to medium significance, but not to low. This is Chapter Six: Mitigation and Amelioration 6-16 Federal University Otuoke EIA because the measures to be undertaken by FUO cannot adequately address all or even most of the reasons for community unrest, which may not be related to this project. 6.2.2 Stress on Existing Security Structures FUO shall ensure that a high level of security consciousness is maintained by both contractor and FUO personnel. To enhance security in the area, it may be necessary to establish and deploy a special security force while fostering a closer working relationship between the Nigerian Police in the area, FUO Police and the community. 6.2.3 Changes in Local Population Based on the 2006 population census, the projected population of Ogbia in 2006 is approximately 179,606. It is estimated that the incoming workers and followers have the potential to increase this population of Otuoke, Otuaba and Kolo by up to 4% especially during the construction phase and full operation of the university. In most construction projects, incoming labour is usually predominantly male, aged between 20 and 44 years (the so-called productive age). The population of this age bracket and between 20-44 will certainly increase with influx of students and employment of lecturers as departments and courses increase in number. 6.2.4 Pressure on Existing Infrastructure and Utilities Baseline information indicated that there was scarcity of decent accommodation in the project area to house operations staff of the university temporary staff resulting to relocation to yenagoa and other communities. Permanent accommodation for Operational Staff is to be provided outside of the host communities’ housing. This is therefore expected to minimize the stress on existing housing within the communities during the operations phase of the project. The influx of labour is expected to increase the demands for health services. At present there is a general paucity of health facilities and health services in the project area with existing health services being limited to the management of minor ailments at the university health centre in Otuoke and the Cottage hospital in Chapter Six: Mitigation and Amelioration 6-17 Federal University Otuoke EIA Otuoke. Emergency rescue and Medevac / Med-rescue procedures shall also be put in place at all worksites The impact is considered to be of high significance, but following mitigation, it should drop to medium. It will not drop to low because even at the end of the construction phase and demobilisation of construction workers, a substantial number of these are likely to remain in the area and continue to apply pressure on local infrastructure. 6.2.5 Increase in Inflation Level Inflation of local prices for foodstuffs and other commodities is expected to cut across all three phases of the development of the FUO Campus (mobilization, construction, operations). After construction, there is expected to be an upturn in the local economy as opposed to the situation during the construction period. Most of the unskilled construction workers are likely to leave Otuoke area for other areas where their services may be needed but an nflux of students, lecturers and workers during the operational phase of the University’s development will transform the area. The training schemes could be expanded to include seminar sessions on economic planning and judicious use of the resources acquired during the boom period. Inflation is of high significance and after mitigation it will only drop to medium and not too low because once prices go up it is difficult for them to go down. Furthermore, inflation is a national phenomenon and responds to other factors that originate outside the project area. 6.2.6 Injuries to Workers Experience of other major projects within the Niger Delta suggests that during construction, operation and maintenance as well as during decommissioning, restoration and abandonment, activities could lead to increased work related injuries/fatalities. 6.2.7 Threat to Health of Workers (snake bites, insect stings, injuries, etc.) There are several potential threats to the health of workers during different phases of the project life. These include insect bites (such as mosquitoes), bee stings and attacks by wild animals and snakes etc. Other threats include injuries due to contact with dangerous plants. The potential for transmission of Chapter Six: Mitigation and Amelioration 6-18 Federal University Otuoke EIA communicable diseases, such as tuberculosis (due to overcrowding or close proximity to cases), gastroenteritis (contaminated foods and drinks) and malaria are also high during this phase of the project. Although mitigation measures such as use of PPE by field workers and ensuring the availability of antivenom and anti-histamine drugs, to be administered on site by trained first-aiders are to be implemented by FUO, it is not likely that these threats to health of workers can be reduced to low. 6.2.8 Increase in Noise Level (during Mobilization, construction, operation decommissioning and restoration) During all these phases, it is certain that noise levels will increase either from human activities or equipment. The noise can be mitigated, however, to the level of low significance. 6.2.9 Potential for Community Unrest (from employment issues, pollution and resistance to dismantling of equipment) As has been observed in other project locations within the Niger Delta, there is always the potential for conflict between communities and companies or institutions managing the construction and operation of a major facility . This is especially so: If communities believe that there is unfairness in applying local content principles and employing skilled and unskilled workers as well as contractors from the communities; If communities perceive that attendant pollution has not been satisfactorily dealt with. For these reasons, it is likely that this impact will remain of medium significance even after mitigation measures have been implemented. 6.3 Enhancing Positive Impacts 6.3.1 Utilization of off-cut vegetation by Communities FUO would be helping to meet the energy needs of the communities by permitting community members to remove and convert felled trees (during bush clearing) to firewood. In order to enhance this positive impact, FUO shall facilitate controlled access to the campus site so that local community members can cut wood appropriate sizes and transport it for use off-site Chapter Six: Mitigation and Amelioration 6-19 Federal University Otuoke EIA 6.3.2 Increase in Economic Activities This project is expected to increase economic activities during different phases. During mobilization, and construction, jobs will be created that locals and others will be expected to take advantage of. This will improve purchasing power and enhance economic activities. During the operation and decommissioning, restoration and abandonment phase, jobs are expected to be available even albeit possibly at a lower rate than during the construction phase. This will also improve purchasing power and enhance economic activities. So as to ensure enhanced economic activities throughout the life of the project, FUO shall ensure that all subcontracts for supplies and minor repairs are reserved for qualified contractors from the project area in the first instance. The surveys of the communities revealed many workers with skills, which may not meet the required standards for the project. FUO shall suggest to the contractors that such persons and local contractors from these communities could formally register with a skills’ registration centre, which could be established for the project so that initial considerations shall be given to them for employment and contracts. With employment and contracts given to the local communities, in order fully to implement the local content law of the Federal Republic of Nigeria, economic activities through availability of capital are likely to be enhanced. 6.3.3 Increase in Employment and Business Opportunities As part of sustainable approach to community interaction, FUO under its development programme shall embark on necessary support to the communities so that they can take advantage of the business opportunities which shall be available at the Otuoke area as a result of this project. 6.3.4 Skills Acquisition Technically, for this project, proven technologies shall be applied in the design, construction and operation of the facilities. The University shall endeavour to train men and women, other than FUO’s academic and management staff, in new skills for the operation and maintenance of the university structures. Chapter Six: Mitigation and Amelioration 6-20 Federal University Otuoke EIA 6.4 Mitigating/Enhancing Cumulative Impacts Mitigation measures and proposals for enhancing the negative/positive impacts have been presented for each of the impacts listed in Table 5-6 of Chapter 5, which have been considered as cumulative impacts arising from the permanent site project in Otuoke area. In order to ensure the effectiveness of these measures and proposals, the frequency of monitoring of the appropriate (environmental) parameters will have to be increased. 6.5 Stakeholder Perceptions Public interest in this project is expected to be high because of the perceived socio-economic transformation, which this project is likely to engender coupled with its impacts on the surrounding communities, especially during construction and operation (e.g. noise, traffic, dust, emissions etc) and from the influx of workforce. Effective and realistic measures to mitigate/enhance these impacts have been proposed. Nevertheless, stakeholder perceptions such as damage to structures due to vibration and increase in air and noise pollution are likely to persist. In executing the project, FUO shall employ and sustain a dialogue with the communities and other stakeholders and involve them in all phases of the project in the spirit of securing the social license to operate. In particular, FUO shall ensure that stakeholder communities are informed about and where possible involved in environmental monitoring and management plan for this project. Use available records on community development and other community-based activities as evidence of a being a good institutional neighbour. Chapter Six: Mitigation and Amelioration 6-21
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