Ep Eia Seacom

SEACOM Cable System Project Equator Principles Environmental Impact Assessment
Prepared for: SEACOM Prepared by: ENVIRON London, UK Date: March 2009 Project / Issue Number: 61C12704_06
SEACOM
Equator Principles EIA SEACOM Cable System Project
Contract/Proposal No: Issue: Author (signature):
61C12704 06 Chris Halliwell
Project Manager/Director (signature):
Neil Daetwyler
Date:
March 2009
This report has been prepared by ENVIRON with all reasonable skill, care and diligence, and taking account of the Services and the Terms agreed between ENVIRON and the Client. This report is confidential to the client, and ENVIRON accepts no responsibility whatsoever to third parties to whom this report, or any part thereof, is made known, unless formally agreed by ENVIRON beforehand. Any such party relies upon the report at their own risk. ENVIRON disclaims any responsibility to the Client and others in respect of any matters outside the agreed scope of the Services.
VERSION CONTROL RECORD

Issue 01 02 03 04 05 06 Description of Status Draft to Client Second Draft to Client Third Draft to Client Fourth Draft to Client Public Release; EP AP includes national requirements for Kenya Public Release; EP AP includes national requirements for all countries Date 02/07/08 18/07/08 28/07/08 09/08/08 03/09/08 06/03/09 Reviewer Initials ND ND ND ND ND ND Authors Initials CH CH CH CH CH CH
SEACOM
Summary
The SEACOM Cable System Project will provide a fibre optic telecommunications cable network linking southern and eastern Africa with the global telecommunications infrastructure via Egypt and India. The System includes approximately 13,000km of fibre optic cable which will be laid in the Indian Ocean and the Red Sea. The cable will land in South Africa, Mozambique, Tanzania, Kenya, Djibouti, India and Egypt, and will have onward connectivity to Europe. The Project will provide for the transmission of data of various bandwidths, including voice, internet and TV signals. It will provide significant benefits to the landing countries and is expected to act as a catalyst for increased productivity and the growth of service industries such as call centres, and research institutes. The Project is being developed in compliance with relevant national and international environmental and social requirements, as well as the international standards of the Equator Principles, a financial industry benchmark for determining, assessing and managing social and environmental risk. The Equator Principles require that the SEACOM Project be developed in a manner that is socially responsible, reflecting sound environmental management practices, and that it be categorized based on the magnitude of its potential impacts and risks, in accordance with the environmental and social screening criteria of the International Finance Corporation (a member of the World Bank Group). The Equator Principles financial institutions associated with the SEACOM Project have determined it to be a Category B project, with potential limited adverse social and environmental impacts that are few in number, generally site-specific, largely reversible and readily addressed through mitigation measures The EIA process has identified the potential impacts associated with the construction, operation and decommissioning of the Project, and assigned a significance rating to each impact after the application of any mitigation measures. The significance criteria comprise High, Moderate and Low categories. With the application of the proposed mitigation measures no Project impacts have been identified in the High or Moderate categories. The Project is implementing a Social and Environmental Management System that incorporates an Equator Principles Action Plan. The Action Plan describes and prioritises the actions needed to implement mitigation measures, corrective actions and monitoring measures to manage the impacts and risks identified in this EIA. The Action Plan will also incorporate the social and environmental management requirements emanating from the environmental approvals processes in the various landing countries.
SEACOM
Contents
Page Glossary 1 1.1 1.2 1.3 2 2.1 2.2 2.3 2.4 3 3.1 3.2 3.3 3.4 3.5 3.6 3.7 3.8 3.9 3.10 4 4.1 4.2 5 5.1 5.2 5.3 6 6.1 6.2 6.3 7 7.1 7.2 Introduction Project Proponent Need for the Project Scope of the Equator Principles Environmental Impact Assessment Policy Legal and Administrative Framework Host Country Regulations International Treaties and Conventions Requirement of Lenders Categorization of the Project Project Description Background Ownership Project Consultants and Contractors The SEACOM Cable System Route Description System Manufacture and Installation - General System Manufacture and Installation Country specific System Operation System Decommissioning Schedule Baseline Data Approach and Methodology Findings Social and Environmental Impacts and Mitigation Measures Significance criteria Positive Impacts Negative impacts and mitigation measures Occupational Health and Safety Telecommunications Safety in General Construction Vessel related hazards Cumulative Impacts Cumulative Impacts existing projects and conditions Cumulative Impacts future projects i 1 2 3 3 6 6 12 18 19 20 20 20 23 24 25 27 34 46 47 47 48 48 51 63 63 64 66 89 89 90 90 92 92 93
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8 9 9.1 9.2 10
Transboundary Impacts Analysis of Alternatives Analysis of Alternatives available technologies Analysis of Alternatives route selection Management Program
94 95 95 95 97 98 100 106 109
References Annex 1: Equator Principles Annex 2: Example data sets acquired from the marine surveys Annex 3: Equator Principles Action Plan
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Glossary
Backhaul BMH BU CZ DTS EASSy EEZ EGS EIA EMP HDD High Seas Terrestrial telecommunications networks that are separate from but associated with each landfall of the SEACOM cable Beach man hole Branching Unit Contiguous Zone Desk Top Study Eastern Africa Submarine Cable System Economic Exclusion Zone Company name Environmental Impact Assessment Environmental Management Plan Horizontal Directional Drilling All parts of the sea that are not included in the exclusive economic zone [including the contiguous zone], in the territorial sea or in the internal waters of a State, or in the archipelagic waters of an archipelagic State International Finance Corporation Country in which the SEA Cable comes ashore (India; South Africa; Mozambique;; Tanzania; Kenya; Djibouti; Egypt) Lowest Astronomical Tide International Convention for the Prevention of Pollution from Ships, 1973, as modified by the Protocol of 1978 Meters water depth Pre Lay Grapnel Run Post Lay Inspection and Burial Point of Presence, an access point to the Internet. A Point of Presence is a physical location that houses servers, routers, ATM switches and digital/analogue call aggregators. Remote Operated Vehicle South Africa Far East [cable] Company name Tera Bytes Territorial sea United Nations Convention on Law of the Sea
IFC Landing Country LAT MARPOL 73/78 mwd PLGR PLIB PoP
ROV SAFE SEACOM TB TS UNCLOS
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Introduction
The SEACOM Cable System Project (The Project) is a fibre optic telecommunications cable network that will link southern and eastern Africa with the global telecommunications infrastructure via Egypt, India and South Africa (Figure 1). The system includes approximately 13,000km of fibre-optic cable, almost all of which will be located in the Indian Ocean and the Red Sea. The cable will rest on the sea bed in deep water (off the continental shelf) and will be buried to a target depth of 1.0 metre below the sea bed in shallower waters. The system will have a terrestrial component in seven countries:

South Africa Mozambique Tanzania Kenya Djibouti India Egypt
Figure 1. Map of the SEACOM Fibre optic cable system
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These terrestrial components provide the link between the marine component and the domestic telecommunications network in each of the seven countries, and comprise:

the point at which the marine cable connects to the terrestrial cable (the beach manhole or BMH), terrestrial cabling, and a cable station, where connection is made to domestic telecommunications networks (and potential links to neighbouring countries)
In addition to providing access to domestic telecommunications networks the terrestrial component of the Project in India and Egypt will also link the Project to the global fibre optic telecommunications network. The terrestrial component in India also includes the Network Operating Centre, from where the SEACOM Cable System will be controlled.
1.1
Project Proponent
The SEACOM Cable System is being developed by SEACOM, in conjunction with local partners in each of the landing countries. African investors have a significant majority stake (76.25%) in the project. SEACOM's investors comprise:

Industrial Promotion Services (26.25%), an arm of the Aga Khan Fund for Economic Development Venfin Limited (25%) Herakles Telecom LLC (23.75%) Convergence Partners (12.5%) Shanduka Group (12.5%)
SEACOM is a Mauritian corporation with its registered office as follows: SEACOM, Ltd. Level Six, One Cathedral Square Jules Koenig Street, Port Louis Republic of Mauritius
The Project has a value of US$650 million and is fully funded, including debt funding provided by Nedbank Capital and Investec Bank (the Lenders), two South African financial institutions.
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1.2
Need for the Project
It is widely recognized that access to electronic communications bandwidth is key to economic development. For Africa, which has lagged behind other continents in terms of economic development, information technology presents an opportunity to catch up with the rest of the world. One of the major obstacles to increased use of information technology is the cost of bandwidth. High bandwidth at low costs will be a catalyst for productivity and the growth of service industries such as call-centres, back offices and research institutions in Africa. The additional bandwidth offered by the Project will also contribute significantly to bringing down the cost of connectivity. The Project will facilitate transmission of voice, data of various bandwidths, Internet and television signals. Of particular significance is the fact that the network will facilitate intercountry transmission thereby reducing and to a large extent eliminating the need to transit via third countries outside the region for country to country communication and information exchange. SEACOM will be a seller of international bandwidth to African carriers at wholesale prices. The SEACOM Cable System is intended to offer point of presence (PoP) to PoP solutions to African carriers for connectivity in Europe and Asia. Each landing station and co-location center attached to the SEACOM System will be operated on an open access principle (permitting direct access within the cable station to any licensed or licence-exempt operator with the right to co-locate and interconnect their equipment) to ensure compliance with appropriate legislation and act as a catalyst to the East and South African communication markets.
1.3 Scope of the Equator Principles Environmental Impact Assessment

The Project is subject to the environmental approval requirements of the landing countries. In addition to these requirements (which are summarised for South Africa, Mozambique, Tanzania, Kenya, Djibouti, and Egypt in Section 2.1 below) the SEACOM Project is being developed in compliance with the relevant requirements of the Equator Principles (Annex 1). The Equator Principles are a financial industry benchmark for determining, assessing and managing social & environmental risk in project financing. Key elements of Equator Principles (EP) compliance include:
the categorisation of an EP project based on the magnitude of its potential impacts and risks in accordance with the environmental and social screening criteria of the International Finance Corporation (IFC) the conduct of a Social and Environmental Assessment process to address the relevant social and environmental impacts and risks of the proposed project. The Assessment should propose mitigation and management measures relevant and appropriate to the nature and scale of the proposed project
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The SEACOM Project has been categorised by the Lenders to the Project as Category B (defined as a project with potential limited adverse social or environmental impacts that are few in number, generally site-specific, largely reversible and readily addressed through mitigation measures). This Equator Principles Environmental Impact Assessment (EP EIA) has been prepared to meet the requirements for documentation of the social and environmental assessment of the Project. This EP EIA therefore includes:

A description of the project and its social and environmental aspects Maps and drawings of the project and a delineation or description of its area of influence Discussion of the Projects compliance with the legal and regulatory framework, the applicable IFC Performance Standards and the environmental and health and safety performance levels established for the project Key potential impacts and risks, including the identification of the affected communities Planned mitigation and any areas of concern that need to be further addressed The process of community engagement
This EIA is additional to a number of country-specific EIAs that have either already been or will be prepared in accordance with local regulatory requirements in the following landing countries:

South Africa Mozambique Tanzania Kenya Egypt
Compliance with the environmental approval requirements of Djibouti does not require the preparation of an EIA, as an approved environmental assessment for a similar new cable [Ref 1] system already exists. The environmental regulator (the Director of Environment at the Ministry of Housing and Environment) has indicated that the existing approval is applicable to the SEACOM Project provided that an EIA supplement is prepared to account for any variations between the cable system described in the existing environmental assessment document and the SEACOM Project. For the Project in India, all approvals have been obtained by the local landing partner.
This EP EIA has been prepared so that mitigation measures identified are incorporated into an Equator Principles Action Plan (EP AP) that will be implemented from the start of Project
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construction. Because Project construction will commence before all national environmental processes are completed, the first release of the EP EIA (and the EP Action Plan) cannot fully reflect the findings and requirements of the various national environmental approval processes to which the Project is subject. The version of the EP EIA released prior to the commencement of Project construction addresses generic impacts and mitigations for the Project as a whole, as does the EP Action Plan that it incorporates. As each national environmental approval process is completed (resulting in some cases in the production of a country action plan or environmental management plan), the EP EIA and EP Action Plan will be updated accordingly and reissued prior to commencement of construction in the country in question. The primary preparer of this EIA is ENVIRON, an international environmental consulting company (www.environcorp.com). The EIA utilises various data generated for the environmental approval documents prepared in the various landing countries; these documents have prepared by local consultants in each country, in cooperation with ENVIRON.
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2.1
Policy Legal and Administrative Framework

Host Country Regulations
Various environmental approvals are required in each of the countries where the SEACOM cable will come ashore. In some cases country specific EIAs are required and further details regarding national requirements will be provided in each of the EIAs for Egypt, Kenya, Tanzania, Mozambique and South Africa (and in the EIA Supplement for Djibouti). National permitting requirements are summarised below for the six landing countries where approvals were not otherwise obtained by the local landing partner.
2.1.1 South Africa

The relevant environmental authorities in South Africa are:

National Department of Environmental Affairs and Tourism (DEAT); KwaZulu-Natal Department of Agriculture and Environmental Affairs (DAEA) (i.e. Provincial authority); Umlalazi Municipality; Ezemvelo KZN Wildlife.
Relevant environmental legislation is as follows:
The National Environmental Management Act (No. 107 of 1998) (NEMA), which establishes a set of principles that all authorities have to consider when exercising their powers. These include the following: Development must be sustainable; Pollution must be avoided or minimised and remedied; Waste must be avoided or minimised, reused or recycled; Negative impacts must be minimised; and Responsibility for the environmental consequences of a policy, project, product or service is applied throughout its life cycle.
EIA Regulations (June 2006), as promulgated under Sections 24 and 44 of NEMA. These Regulations identify activities which may not commence without an environmental authorisation. In this context, the EIA Regulations are contained in three General Notices in terms of NEMA and came into force on 3 July 2006. GN R 385 lays out two alternative authorisation processes. Depending on the type of activity that is proposed, either a basic assessment process or a Scoping and EIA process is required to obtain environmental authorisation. GN R 386 lists activities that require basic assessment; GN R 387 lists activities that require Scoping and EIA.
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The regulations for both alternative processes stipulate that:

public participation must be undertaken at various stages of the assessment process; the assessment must be conducted by an independent Environmental Assessment Practitioner; the relevant authorities respond to applications and submissions within stipulated time frames; decisions taken by the authorities can be appealed by the proponent or any other interested and affected party; and a draft environmental management plan must be included in a full EIA and released for public comment.
The activities relevant to the proposed SEACOM cable installation identified in the EIA Regulations as requiring environmental authorisation include:
Listing Notice GN R 387 (Scoping and EIA): No. 1(m) - Marine telecommunications.
Listing Notice GN R 386 (Basic Assessment): No. 2(g) - Construction or earthmoving activities in the sea or within 100 metres inland of the high-water mark of the sea in respect of infrastructure. No. 6 - The excavation, moving, removal, depositing or compacting of soil, sand, rock or rubble covering an area exceeding 10 square meters in the sea or within a distance of 100 metres inland of the high-water mark of the sea.
According to the South African EIA Regulations, a marine telecommunications cable requires a full Scoping and EIA process to be followed (i.e. due to Listing Notice GN R 386 No. 2g being triggered).
2.1.2 Mozambique
The Environment Law (Law No. 20/97, dated 7 October 1997) defines the legal basis for the sound use and management of the environment as a means to safeguard sustainable development in the country. This Law applies to all activities in the public or private sectors that may directly or indirectly affect the environment. According to the Environment Law, environmental impact assessment (EIA) is a legal requirement and an instrument that supports the Mozambican government in the decisionmaking process regarding the issuing of environmental licences for development projects. The issuing of an environmental licence must precede any other required legal licences. MICOA (Mozambican Ministry for Environmental Affairs), through its National Directorate for Environmental Impact Assessment (DNAIA), is the authority responsible for the EIA process and environmental licensing.
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The environmental impact assessment process was previously regulated by Decree No. 76/98 of 29 December 1998, which was later revoked by Decree No. 45/2004 of 29 September 2004. This new Decree establishes the environmental assessment process defining procedures for the environmental screening, the content of the required environmental studies, timing for review, public participation process, among others. The Decree is complemented by the General Guidelines for Environmental Impact Studies which details the contents of EIA and by the General Guidelines for Public Participation in the EIA process. For environmental screening the EIA Regulation (Art 3) applies one of three project categories to identify the appropriate level of environmental assessment required, namely: Category A: projects that could have significant impacts due to the proposed activities or the sensitivity of the area, requiring a full EIA, including an Environment Management Plan (EMP). A Scoping Report with terms of reference for the EIA requires prior approval by MICOA. Category B: corresponds to projects that would have negative impacts with lower duration, intensity, extension, magnitude and/or significance, requiring a simplified environmental assessment and EMP. The terms of reference for the simplified environmental assessment has to be previously approved by MICOA. Category C: for projects that do not require any environmental assessment, but which are subject to the rules included in specific directives. The responsibility for the classification of projects into one of the three categories lies with MICOA. However, Annex 1 of the Regulations lists certain activities and/or proposed sites which will always lead to the classification of the project as Category A projects, including the implementation of submarine cables that are greater than 5 km in length. A Public Participation Process (PPP) is compulsory for Category A projects and must be initiated during the scoping phase, including public consultations and public meetings. The PPP is the responsibility of the proponent and must be implemented from the onset of the activity until the submission of the EIA report to MICOA. Ministry Diploma No. 130/2006 guides the Public Participation Process and defines the principles, methodologies and procedures for public consultation and public meetings. Ministry Diploma No. 129/2006 approves the General Guidelines for Environmental Impact Assessment, which is a set of guidelines and parameters to be followed in the undertaking of environmental impact assessments for different types of projects. The objective of the General Guidelines is to standardise procedures followed by various key players in undertaking the environmental impact assessment process.
2.1.3 Tanzania
Environmental management is guided by the National Environmental Policy (1997) and the Environmental Management Act (No 20 of 2004). Due to the cross-cutting nature of environment conservation and protection, environmental management powers fall within a
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number of Central Government institutions. The Ministry of State responsible for Environment is located in the Vice Presidents Office and provides overall policy, planning and implementation oversight mandate on environmental matters. The Ministry is also tasked to support and influence sector Ministries in carrying out their mandates with respect to the environment and for identifying and assessing strategic environmental concerns and key issues. The following institutions provide the technical and operational support to the Ministry:
The Division of Environment (DoE): originally created by the Ministry of Tourism and Natural Resources. The Vice Presidents Office DoE is headed by a Director and is responsible for the day-to-day supervision of environmental issues. Its primary activities include undertaking policy analysis, developing policy choices to influence decision making and coordinating broad-based environmental programmes, plans and projects. The DoE is also mandated in terms of the Environmental Management Act (No. 20 of 2004) to guide strategic environmental assessment in Tanzania, and is in the process of drafting Strategic Environmental Assessment Regulations that will be promulgated under this Act. The National Environment Management Council (NEMC): was established by Parliament in terms of the National Environmental Management Act (No 19 of 1983) to create environmental policies and make recommendations to government regarding their implications. This Act was repealed by the promulgation of the Environment Management Act in 2004. Headed by a Permanent Secretary, the NEMC has been reestablished with the following key functions: provision of a legal and institutional framework for the sustainable management of the environment; prevent and control pollution; waste management; setting environmental quality standards; public participation; and environmental compliance and enforcement. The NEMC is mandated to ensure enforcement, compliance, review and monitoring with respect to environmental impact assessment (EIA). The EIA procedure is detailed in the Environmental Impact Assessment Procedure and Guidelines, Volume 1-5.
2.1.4 Kenya
The key environmental legislation is the Environmental Management and Co-ordination Act, 1999 (EMCA 1999). Part VI of the Act outlines procedures for conducting an Environmental Impact Assessment. Before any project is implemented, it is obligatory that an EIA is conducted based on the guidelines outlined in the Act. Environmental Impact Assessment and Audit Regulations 2003 is a subsidiary legislation that operationalises the EMCA 1999 on EIA and Audit. The Kenya Gazette Supplement No. 56 of 13 June 2003 makes submission of environmental reports mandatory for projects listed under second schedule of the Act. According to these regulations no proponent shall implement a project likely to have a negative environmental impact or for which an environmental impact assessment is required under the act or these regulators unless an environmental impact assessment has been concluded and approved in accordance with these regulators.
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The Law gives the Minister the right, by notice in the Gazette, to declare a coastal zone to be a protected area and impose such restrictions as he considers necessary, to protect the coastal zone from environmental degradation. The Minister may also issue general and specific orders, regulations or standards for the management of coastal zones and such orders, regulations or standards may include management, protection, or conservation measures in respect of any area at risk of environmental degradation. He shall also provide for special guidelines for access to and exploitation of living and nonliving resources in the continental shelf, territorial sea and the Exclusive Economic Zone. Any person who contravenes or fails to comply with any orders, regulations or standards issued under this section shall be guilty of an offence. Other regulatory requirements that may be relevant to the SEACOM Project are:

Water Act Cap 732 Forest Acts-Mangroves Cap 386 Government Fisheries Protection Act Cap 379 Wildlife Conservation and Management Act Cap 376 Merchant Shipping Act Cap 389 Maritime Zones Act Kenya Continental Shelf Act Cap 312 Land Planning Act Cap 303 Town Planning Act Local Authority Government Act Cap 265 Coastal Development Authority Act Kenya Ports Authority Act
National permitting requirements of significance to the Project are:

Building/construction approvals from the Mombasa Municipal Council (including excavation permits) Archaeological survey permits subsequent to an archaeological impact assessment. Land ownership (lease or purchase) Telecoms Licence from The Communications Commission of Kenya (CCK)
2.1.5 Djibouti
Djibouti Law n106/AN/00/4me L on the Environment Framework, and in particular articles 16, 33, 54, 55 relating to the environment impact assessment for the protection of natural habitats and article 56 relating to the environmental follow-up, defines the objectives and the general principles of environment management in the Republic of Djibouti. The objectives of the environment management are presented as follows:
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To protect the environment so as to ensure the regeneration and conservation of its components; To ensure sustainable and equitable development between generations; To improve and maintain the framework of livelihoods of the population; To restore the degraded elements of the national ecological heritage; To prevent any action being taken to induce significant negative impacts by carrying out specific evaluation and planning mechanisms in respect of the environment; To prevent any pollution or degradation, or to limit the negative effects on the environment.
The procedure for the Environmental Impact Assessment is as follows:
Any activity with the potential to induce negative impacts on the environment must be the subject of a preliminary environmental and social impact assessment. The impact assessment must be integrated in the project feasibility studies. The evaluation of the impact assessment is sanctioned by the delivery or otherwise of an environmental authorization by the ministry in charge of the environment issues. The impact assessment is the responsibility of the project proponent, within the framework of the project feasibility study, but can be performed by specialist consultants or research centres on behalf of the project proponent.
2.1.6 Egypt
The principal law concerning the protection of the environment in Egypt is Law No. 4 of 1994 and its Executive Regulations issued by Ministerial Decree 338/1995 and later modified by Ministerial Decree 1741/2005. Law 4/1994 stipulates in Articles 19 through 23 that an Environmental Impact Assessment (EIA) is required for development projects, as a step in the licensing procedure. The EIA screening system categorises projects according to the significance of potential impacts, as follows:

Black-list projects - for establishments/projects which require complete (or Full) EIA due to their potentially significant impacts. Grey-list projects - for establishments/projects which may result in substantial environmental impact, requiring Environmental Screening Form B; and White-list projects - for establishments/projects with minor environmental impact, requiring Environmental Screening Form A.
The EIA procedure is predicated largely within a series of inter-relations between its components; the proponent, the environmental consultant (advisor), the Competent Administrative Authority (CAA) and the Egyptian Environmental Affairs Agency. The proponent prepares the study according to available guidelines and submits the EIA to the CAA. The procedure that follows is dependent on the category of the project. White list
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projects (minor impact) are reviewed by the CAA, and EEAA should be informed of the decision, unless the CAA is incapable of reviewing form A, in which case it is sent to EEAA for review. In the majority of cases, the more significant projects (black and grey list) are sent directly to EEAA for their review. The SEACOM project has been categorised as a black list project and therefore requires a full EIA. Other permitting requirements relevant to the SEACOM Project are those required by the Ministry of Defence, the Navy, the Ports Authority and the Maritime Safety Authority.
2.2
International Treaties and Conventions
The landing countries are party to various international treaties and conventions, in addition to which there are also treaties and conventions applicable to areas beyond national jurisdictions (such as international waters, or the High Seas.) The High Seas by definition are located beyond the Economic Exclusion Zone (EEZ) of individual nations and are regarded as open access common areas under the United Nations Convention on the Law of the Seas. The relevant international laws, treaties and conventions are:

The International Convention for the Protection of Submarine Cables (1884) Geneva Convention on the High Seas (1958) United Nations Convention on the Law of the Sea (UNCLOS) (1982)
The International Convention for the Protection of Submarine Cables establishes that the breaking or injury of a submarine cable, done wilfully or through culpable negligence, and resulting in the total or partial interruption or embarrassment of telegraphic communications, shall be a punishable offence, but the punishment inflicted shall be no bar to a civil action for damages. [Ref 2] The Geneva Convention on the High Seas establishes the High Seas as being open to all nations; no State may validly purport to subject any part of them to its sovereignty. Freedom of the High Seas is exercised under the conditions laid down by the Articles of the Convention and by the other rules of international law. It comprises, inter alia, both for coastal and non-coastal States: (1) Freedom of navigation; (2) Freedom of fishing; (3) Freedom to lay submarine cables and pipelines; (4) Freedom to fly over the high seas. [Ref 3]
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UNCLOS requires that: beyond the outer limits of the 12 nm territorial sea, a coastal State may not (and should not) impede the laying or maintenance of cables, even though the delineation of the course for the laying of such pipelines on the continental shelf is subject to its consent. The coastal State has jurisdiction only over cables constructed or used in connection with the exploration of its continental shelf or exploitation of its resources or the operations of artificial islands, installations and structures under its jurisdiction. When laying submarine cables or pipelines, due regard should be paid to cables or pipelines already in position. In particular, possibilities of repairing existing cables or pipelines shall not be prejudiced. [Ref 4] The requirements of UNCLOS and their relevance to submarine cables are summarised in Table 1. Table 1. Definition and relevance of maritime zones to cable systems under UNCLOS
Maritime Zone Territorial Sea (TS) Contiguous Zone (CZ) Definition Territorial seas usually extend to a distance of 12 nautical miles. In the contiguous zone (usually between 12 and 24 nautical miles) which is contiguous to its territorial sea. The contiguous zone may not extend beyond 24 nautical miles from the baselines from which the breadth of the territorial sea is measured (UNCLOS, Art. 33). The economic exclusive zone extends from 24nm (edge of contiguous zone) to the High Seas (not exceeding 200 nautical miles from shore). Defined in the United Nations Convention on the Law of the Seas as all parts of the sea that are not included in the exclusive economic zone [including the contiguous zone], in the territorial sea or in the internal waters of a State, or in the archipelagic waters of an archipelagic State. (UNCLOS Art. 86). 1
Relevance to cables
States have jurisdiction over cables entering territorial seas although all vessels have the right to innocent passage (UNCLOS Art. 3). In the contiguous zone the coastal State may exercise the control necessary to: (a) prevent infringement of its customs, fiscal, immigration or sanitary laws and regulations within its territory or territorial sea; (b) punish infringement of the above laws and regulations committed within its territory or territorial sea. Within an EEZ all States have the right to lay submarine cables (UNCLOS Article 58).
Economic Exclusion Zones (EEZ) High Sea
All states have the freedom to lay submarine cables in the High Seas.
Other international conventions relating to the High Seas that are relevant to the Project include International Maritime Organisation conventions such as MARPOL 73/78 and the
1
Defined in the Geneva Convention on the High Seas as all parts of the sea that are not included in the territorial sea or in the
internal waters of a State. Thus, the Geneva Convention includes the contiguous zone and the EEZ within its definition of High Seas.
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Convention on the Prevention of Marine Pollution by Dumping of Wastes and other Matter. Various conventions are intended to protect biodiversity, taking account of the rights of the users of the High Seas under UNCLOS. For example, the Convention for Biological Diversity (CBD) underlines the need for parties to cooperate towards the conservation and sustainable use of biological resource in areas beyond national jurisdiction (whilst being implemented consistently with UNCLOS). The CBD established a Conference of Parties (CoP); the seventh CoP, February 2004, adopted a target to develop a global network of protected areas by 2012, although none have been specified in the vicinity of the Project. Further control is exercised by the International Seabed Authority (ISA), established under UNCLOS, which is tasked with the control of all exploration and mining activities on the seabed outside of national jurisdictions. The ISAs rules and regulations are binding on UNCLOS parties. [Ref 5]. There are also a number of regional treaties and agreements addressing environmental protection that have adopted an ecological protection approach. In the Project affected areas, regional treaties include:

The Regional Convention for the Protection of the Red Sea and the Gulf of Aden Environment (aimed primarily at pollution control) and The Convention for the Protection, Management and Development of the Marine and Coastal Environment of the East African Region. The South Indian Ocean Fisheries Agreement (SIOFA) signed by Comoros, France, Kenya, Mozambique, New Zealand and Seychelles and the European Community in July 2006 with the aim of managing fishing activities in the high seas of the South Indian Ocean.
The SIOFA joins the existing network of fishery commissions already established in the region, including the Indian Ocean Tuna Commission. SIOFA has established a number of [fishing] closure zones, none of which will be traversed by the cable. A summary of international treaties and conventions that could potentially be applicable to the Project are presented in the Table 2.
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Table 2: Potentially Applicable International Treaties and Conventions Habitats, Biological Diversity and Heritage Convention on Wetlands of International Importance especially as Waterfowl Habitat 1971 Convention on Biological Diversity, 1996 Convention for the Protection, Management and Development of the Marine and Coastal Environment of the Eastern African Region (the Nairobi Convention) 1996 The Regional Convention for the Protection of the Red Sea and the Gulf of Aden Environment, 1982 South Indian Ocean Fisheries Agreement, 2006 Convention concerning the Protection of the World Cultural and Natural Heritage Paris, 1972 Convention on the Conservation of Migratory Species of Wild Animals (CMS) (The Bonn Convention 1979) and agreement (Birds mammals and their habitats, 1994) Waste management Basel Convention on the Control of Trans-boundary Movements of Hazardous Wastes and their Disposal (accession to)Convention on the Prevention of Marine Pollution by Dumping of Wastes and other Matter, 1972 Shipping International Convention for the Protection Submarine Telegraph Cables (1884) Geneva Convention on the High Seas (1958) UNCLOS (1982) International Loadline convention, 1966 Convention on the International Regulations for Preventing Collisions at Sea, (COLREGs)1972
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Table 2: Potentially Applicable International Treaties and Conventions International Convention on Standards of Training Certification and Watchkeeping for Seafarers (STEW)London, 1978 International Convention for the Prevention of Pollution from Ships (MARPOL) London, 1973 MARPOL 73/78 Annex I/II MARPOL 73/78 Annex III MARPOL 73/78 Annex IV MARPOL 73/78 Annex V MARPOL 73/78 Annex VI International Convention on Civil Liability for Oil Pollution Damage Brussels, 1969 International Convention on Oil Pollution Preparedness, Response and Co-operation (OPRC), 1990 (guidance) Oil Company International Marine Forum (OCIMF) Guidelines 1975 International Convention on the Control of Harmful Anti-fouling Systems on Ships, October 2001 The International convention for the control and management of ships ballast water and sediments, 2004. Social/Human rights/Consultation International Labor Organisation (ILO) Forced Labour Convention, No 29 1930 ILO Abolition of Forced Labour Convention, No 105 1957 ILO Freedom of Association and Protection of the Right to Organise Convention. No. 87. 1948 ILO Right to Organise and Collective Bargaining Convention. No. 98.1949 ILO Equal Remuneration Convention. No. 100 1951 ILO Discrimination (Employment and Occupation) Convention, No. 111 1958
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Table 2: Potentially Applicable International Treaties and Conventions ILO Minimum Age Convention, No.138 1973 ILO Worst forms of Child Labour Convention, No. 182 1999 UN Convention on the Rights of the Child 1989
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2.3
Requirement of Lenders
The Project is backed by a number of private investors and receives support from certain commercial banks (the Lenders), which necessitates compliance with the requirements of the Equator Principles. The Project is subject to the most recent revision of the Equator Principles, dated June 2006. The Principles are listed below and provided in full in Annex 1. Principle 1: Review and Categorisation The proposed project is categorized based on the magnitude of its potential impacts. Principle 2: Social and Environmental Assessment For each project assessed as being either Category A or Category B, the borrower has conducted a Social and Environmental Assessment process, appropriate to the nature and scale of the proposed project. Principle 3: Applicable Social and Environmental Standards The project Social and Environmental Assessment will establish the projects compliance status with applicable IFC Performance Standards and Industry Specific EHS Guidelines. Principle 4: Action Plan and Management System For all Category A and Category B projects the borrower must prepare an Action Plan to describe and prioritise the actions needed to implement mitigation measures, corrective actions and monitoring measures necessary to manage the impacts and risks identified in the Social and Environmental Assessment. Principle 5: Consultation and Disclosure For all Category A and, as appropriate, Category B projects, consultation should take place with project affected communities in a structured and culturally appropriate manner. Materials will be made available to the public by the borrower for a reasonable minimum period in the relevant local language and in a culturally appropriate manner. Principle 6: Grievance Mechanism For all Category A and, as appropriate, Category B projects a grievance mechanism scaled to the risks and adverse impacts of the project will be established. The mechanism will address concerns about the projects social and environmental performance promptly and transparently, in a culturally appropriate manner, and will be readily accessible to all segments of the affected communities. Principle 7: Independent Review For all Category A projects and, as appropriate, for Category B projects, an independent social or environmental expert not directly associated with the borrower will review the Assessment, Action Plan and consultation process documentation. Principle 8: Covenants The borrower will covenant in financing documentation to comply with applicable legislation, the Action Plan, periodic compliance reports and to decommission facilities in accordance with an agreed decommissioning plan. Principle 9: Independent Monitoring and Reporting For all Category A projects and, as appropriate, for Category B projects, an independent environmental expert(s) will be appointed to verify monitoring information.
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Principle 10: Public reporting by Lenders The Equator Principles are underpinned by IFC policies, standards and guidelines, including the IFC Performance Standards:

PS1 Social & Environmental Assessment and Management System PS2 Labour and Working Conditions PS3 Pollution Prevention and Abatement PS4 Community Health, Safety and Security PS5 Land Acquisition and Involuntary Resettlement PS6 Biodiversity Conservation and Sustainable Natural Resource Management PS7 Indigenous Peoples PS8 Cultural Heritage
In addition to sectoral environmental, health and safety (EHS) guidelines, particularly the EHS Guidelines for Telecommunications (2007), compliance is also required with the IFC General EHS Guidelines (2007). All the IFC Performance Standards have some degree of applicability to this Project with the exception of Performance Standard 7 (Indigenous Peoples).
2.4
Categorization of the Project
The Equator Principles require categorization of proposed projects in accordance with the environmental and social screening criteria of the International Finance Corporation. Projects are assigned an A, B or C categorization by the Lenders, depending on the potential significance of environmental and social impacts, defined as follows:

Category A Projects with potential significant adverse social or environmental impacts that are diverse, irreversible or unprecedented. Category B Projects with potential limited adverse social or environmental impacts that are few in number, generally site-specific, largely reversible and readily addressed through mitigation measures. Category C Projects with minimal or no social or environmental impacts.
The Lenders have determined the SEACOM Project to be Category B for Equator Principles purposes.
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3
3.1
Project Description
Background
SEACOM intends to construct and operate a 13,000km undersea fibre optic cable system connecting south and east African countries with India and Egypt enabling onwards connectivity to Europe. The cable will provide a capacity of 1.2TB/s, to allow high definition TV and to meet the needs of surging internet demand. The Project will address the deficiencies in the existing global telecommunication system by providing high quality broadband connectivity to east Africa, removing the need to rely on expensive satellite systems. Figure 2 shows the current global system of cables highlighting the absence of fibre optic cable servicing east Africa. Figure 2. Global Submarine Cable Systems
Source: http://www1.alcatel-lucent.com/submarine/refs/
3.2
Ownership
SEACOM, Ltd is a company registered in Mauritius that intends to develop, construct, own and operate the SEACOM submarine fibre optic cable system, to be commissioned in 2009.
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The cable system will complement the business of national carriers, broadcasters and education and research networks by providing a wholesale solution for international bandwidth to be sold by national carriers through their already established retail channels. The SEACOM Project is being designed with a nominal capacity of 1,280 Gb/s connecting South Africa, Mozambique, Tanzania, Kenya, Dijbouti, Egypt and India. The Project also provides onwards connectivity to Europe. Table 3 presents the ownership structure of the SEACOM Cable System. SEACOM, Ltd is owned by investors including 75% which is owned by African investors as a collaboration between East and Southern Africans. The remaining 25% non African investment is provided by Herakles Telecom LLC. The ownership structure varies for each landing country ensuring an appropriate level of local ownership of the cable segments in compliance with regulatory requirements. The offshore cable system beyond the territorial waters of the landing countries is owned by SEACOM, Ltd. The cable in the territorial waters of landing countries (from a distance of 22km (12nm) offshore to the onshore cable station) are either 100% locally owned (South Africa, Mozambique, Djibouti and Egypt) or 35% locally owned (Tanzania, Kenya), with the balance owned by SEACOM.
Table 3: Ownership structure of the SEACOM Cable System System section Ownership structure Ownership details
Those parts of the SEACOM System not in landing countries or their territorial waters
SEACOM, Ltd (100%) Investors in SEACOM, Ltd: Industrial Promotions Services (26.25%) an arm of the Aga Khan Fund for Economic development Venfin Ltd (25%) Herakles Telecom LLC (23.75%) Convergence Partners (12.5%) Shanduka Group (12.5%)
Egypt Djibouti Kenya Tanzania Mozambique South Africa
100% Egyptian 100% Djiboutian 35% Kenyan 65% SEACOM, Ltd 35% Tanzanian 65% SEACOM, Ltd 100% Mozambican 100% South African
Landing partner Telecom Egypt Landing partner Djibouti Telecom Landing partner - Sea Submarine Communication Limited Landing partner SEACOM Tanzania Ltd Landing partner - CAPITEL Landing partner - Neotel
Further details of each of the investors in SEACOM Ltd are provided below.
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The Aga Khan Fund for Economic Developments Industrial Promotion Services The Aga Khan Fund for Economic Development (AKFED) is an international development agency dedicated to promoting entrepreneurship and building economically sound enterprises in the developing world. AKFED focuses on building enterprises in parts of the world that lack sufficient foreign direct investment. AKFED operates as a network of affiliates with more than 90 separate project companies employing over 30,000 people, with annual revenues in excess of US$1.5 billion. The Fund is active in 16 countries in the developing world: Afghanistan, Bangladesh, Burkina Faso, the Democratic Republic of the Congo, India, Ivory Coast, Kenya, Kyrgyz Republic, Mali, Mozambique, Pakistan, Senegal, Syria, Tajikistan, Tanzania and Uganda. The Aga Khan Fund for Economic Development works with governments, international corporations, international financial institutions and donors to create solutions to pressing infrastructure needs, including power generation and telecommunications. AKFED has invested in, and manages, over 50 industrial project companies in Africa and Asia. In the early 1960s, a group of companies was set up under the corporate name Industrial Promotion Services (IPS). Each company was created to provide venture capital, technical assistance and management support to encourage and expand private enterprise in countries of sub-Saharan Africa and South Asia. Today, IPS companies play a vital role in local and regional economies. VenFin Limited VenFin is an active private equity and venture capital investor focusing on high growth investment opportunities. The company has assets in excess $1.1 billion spanning the telecommunications, software, energy and media sectors. The company also has selected fund and direct investments in China. Prior to 1 January 2006, VenFin was listed on the Johannesburg Stock Exchange (JSE) with its largest investment being a 15% stake in Vodacom (Pty) Ltd, South Africas largest mobile network operator. VenFin was a founding shareholder in Vodacom. The group subsequently disposed of the Vodacom investment to Vodafone Plc, and delisted from the JSE. More recently, VenFin disposed of its 25% stake in Alexander Forbes, a leading insurance broker and financial services company, for just under $300 million. The company is actively making new investments across a number of sectors, including media, technology and renewable and alternate energy sectors. VenFin is part of a family of companies, JSE listed Remgro Limited (www.remgro.co.za) and Swiss based Richemont (www.richemont.com). Herakles Telecom Herakles Telecom is an international development group based in New York City. The management of Herakles Telecom has decades of experience in the development of international infrastructure, including more than $4 billion dollars of infrastructure investment in Africa. The Herakles Telecom experience includes a full spectrum of development
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expertise including project development, project finance, technical expertise and project controls. Convergence Partners Convergence Partners is a Black Economic Empowerment (BEE) investment company focusing on the Telecommunications, Media and Technology (TMT) sector. Convergence Partners' investment philosophy is to take meaningful equity stakes in quality companies within its chosen sectors, and act as both a strategic, value-adding active investor as well as BEE partner. Convergence Partners primary strategy is to partner businesses where it believes that it can make a meaningful contribution to strategic development and growth to the benefit of all shareholders over the medium to long-term. There is a significant investment focus on projects that will improve general access of African corporates and individuals to communications, broadband services and new technology offerings that can improve lives. Shanduka Group Shanduka Group is a leading African investment company. The companys main investment activities are in Resources, Financial Services, Property, Energy and Industrial & General. The companys Corporate Social Investment activities are conducted through the Shanduka Foundation, a vehicle for transformation and empowerment dedicated to the education and development of business skills amongst the previously disadvantaged community.
3.3
Project Consultants and Contractors
SEACOM is supported by the David Ross Group (DRG), a leading consultancy in the field of international telecommunication. SEACOM has also commissioned the bulk of the construction effort for the Cable System to Tyco Telecommunications (Tyco) which will act as the main contractor responsible for system manufacture and installation. Tyco Telecommunications is a business unit of Tyco Electronics, an industry pioneer in undersea communications technology and marine services, and a leading global supplier for today's undersea communications requirements. Operating for over 50 years, Tyco Telecommunications has designed, manufactured, and installed more than 80 undersea fibre optic systems around the world. Tyco will draw upon a number of sub-contractors and partners to assist with marine surveys and system installation within the landing countries.
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3.4
The SEACOM Cable System
A submarine fibre optic cable system is primarily comprised of marine cables, but also includes terrestrial cables at each location where the system makes landfall. The marine cable includes the offshore components and that part of the cable system that crosses the shoreline as far onshore as the Beach Manhole (BMH), where the marine cable is connected to the terrestrial cable. The terrestrial cable provides the connection from the BMH to the Cable Station, where the cable system interfaces with other communications networks. The SEACOM System is made up of a number of segments, which typically terminate either at an onshore Cable Station or an offshore Branching Unit (BU). A BU provides a junction to the adjacent segment of the Cable System, which might be a link to a landing country, or which might be entirely offshore, linking to a further BU. In some cases a segment may terminate on the ocean floor, from where a future connection to an additional landing country can be made as required. Fibre optic cables transmit data via beams of laser-generated light that are internally reflected within the optical fibres. The strength of the light signal degrades with distance and therefore amplifiers are installed along the cable. In the SEACOM System optical amplifiers are installed in the marine cable at intervals of approximately 80km. These amplifiers are sometimes referred to as repeaters and are electrically powered. The marine cable includes a copper sheath around the insulation material that in turn surrounds the optical fibres. The copper sheath carries an electrical current that is used to power the subsea section of the cable system. This use of a single conductor is made possible by using the surrounding seawater as the earth (or ground) connection, which requires the installation of an ocean ground bed as part of the marine component of the system. The ocean ground bed comprises a number of vertical rods installed below ground level adjacent to the BMH which act as sacrificial anodes (Figure 3).
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Figure 3. Typical Installation for an Ocean Ground Bed
3.5
Route Description
3.5.1 Overview
The SEACOM cable system will connect Mtunzini, South Africa to Mumbai in India and Ras Sudr in Egypt (as illustrated in Figure 1), with onward connectivity to Marseilles, France via the TE Transit Corridor2 and the TE North cable system3. The network will also serve Mozambique, Kenya, Djibouti and Tanzania, landing at these countries via a number of branch cables or segments. The cable will be almost entirely submarine, with short terrestrial sections required to connect the marine cable to domestic networks. In each landing country the terrestrial component comprises the connection between the marine and
The TE Transit Corridor comprises Telecom Egypts terrestrial infrastructure linking submarine communications systems terminating on the Egyptian shores of the Red and Mediterranean seas. TE North is a submarine cable network being developed by Telecom Egypt that will link Egypt with France. According to Telecom Egypt (www.telecomegypt.com) the TE North submarine cable system will help Telecom Egypt enhance its network capacity to operate as a wholesale carrier to other operatorswill further establish Egypts role as international communication hub between Europe and Asia/Africa, and it will also reinforce the city of Marseilles as a communications hub with open access facilities. 61C12704 Issue: 06
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a terrestrial cable, the terrestrial cable itself, and a Cable Station, which will generally be located within a few hundred metres, and no more than a few kilometres from the landing point. The improved telecommunications resulting from the Project will assist in the economic development of those countries served by the SEACOM System. Commissioning of the cable system is scheduled for mid 2009 in order to meet the demands of the Southern and East African markets, ahead of the 2009 Confederations Cup and the 2010 Football World Cup in South Africa.
3.5.2 Route through international and national waters

There are a number of international conventions which define maritime boundaries and provide jurisdiction of the sea. Maritime zones include territorial waters, contiguous zones, economic exclusion zones and the High Seas as defined in the United Nations Convention on the Law of the Seas (UNCLOS, 1982) and summarised in Table 1. At each landing location the cable will traverse national waters (the territorial seas) and also contiguous zones and economic exclusions zones of those countries in which the cable comes ashore. It will also impinge upon the EEZs and CZs of other, non-landing countries where narrow water ways means that the option of cable routing through high seas is not available. This is particularly the case for the African and Arabian coastal states of the Red Sea and Gulf of Aden.
3.5.3 Landing locations

The SEACOM System includes cable landings in several countries. At each location the marine cable will cross the shoreline and traverse a short distance to a beach manhole. At the beach manhole the marine cable interfaces with three terrestrial cables that are colocated in buried ductwork connecting the BMH and the Cable Station. The Cable Station represents the terminal point of the SEACOM System, where it connects with national terrestrial cable networks.
3.5.4 Cable route selection

Before the cable can be laid a preferred route is determined. The route selection will generally consider numerous factors including optimal operational needs, bathymetry, natural hazards such as sand wave fields and submarine landslides, other seabed users including fishing activity, dredging, anchoring and existing cables and pipelines, environmental and social sensitivities. The two principal steps in cable route selection involve a desk top study followed by a marine survey. The detailed desk top study (DTS) is a comprehensive review of available information pertaining to the feasibility of a route, taking account of physical and operational constraints. The DTS for this project, undertaken on behalf of Tyco Telecommunications, the overall SEACOM Cable System supplier, was undertaken in phases and included analysis of bathymetry, geology, climatology, oceanography, fisheries, permitting and other hazards and restrictions. A number of route alternatives were considered resulting in survey and cable engineering recommendations. Despite the nomenclature, field work typically forms part of a
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DTS, and site visits to all landing countries were made as part of the DTS for the SEACOM Project. The Marine Survey for the SEACOM Project has also been undertaken in phases, involving extensive data collection from dedicated marine survey vessels traversing the full extent of the Cable System in order to provide the information necessary for the engineering, construction, installation, and subsequent maintenance of the SEACOM Cable System. Nearshore and Deep Sea Survey programs were designed to allow field evaluation of the preliminary routing plan developed as part of the DTS. Phase 1 of the Marine Survey encompassed the southern portion of the Cable System route, from South Africa, via Mozambique and Tanzania to the BU offshore Kenya. Phase 2 of the Survey covers the cable route and landing countries to the north, between Kenya, Djibouti, India and Egypt, and was incomplete at the time of writing. Examples from the extensive data sets acquired from the Marine Survey are presented in Annex 2.
3.6
System Manufacture and Installation - General
3.6.1 Marine Cable

Modern submarine fibre optic cables have optical fibres at their core and a series of surrounding layers to provide strength, conductivity and external protection. The amount and type of protective armouring (if any) varies in line with the risks posed to the cable, but in general will be made of steel wire or polypropylene. In deeper low energy waters, such protective armour may be unnecessary. Regardless of the amount of armouring, submarine fibre optic cables have a small diameter (generally less than 50mm when armoured and less than 20mm when without armour). The use of armoured cable offers a high level of protection against natural risks. However, cables can be adversely affected by anthropogenic activities, notably from shipping, fishing and other offshore activities. Given the dependency the modern world now places upon rapid and reliable telecommunications, and hence the strategic importance of these systems, submarine cables are often given additional protection in shallower waters in the form of protection zones where certain activities, such as fishing, are prohibited. The figures below show modern fibre optic cable systems, to be used in deep water and continental shelf areas, which are representative of the cable that will be used in the Project. In deep water, Light Weight (LW) cable or Special Purpose Application (SPA) cable with the protection of polyethylene insulation is used; the outside diameter of the cable is 12 mm and 15 mm respectively. In shallower water, a single layer of steel armour wires provides protection; the outside diameter is 23 mm. Also used in the approaches to the landing is a double armour cable where cable burial may be difficult or infeasible due to seabed conditions. This second layer of steel armour is provided with an outer diameter of 29 mm. The external protection of the cable comprises naturally occurring bitumen (asphalt) as a compound to adhere the outer polyethylene roving to the armour wires on the armoured
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shallow water cables. No form of additive to prevent bio-degradation or fouling is used in the cable's outermost layers. The other cable components in contact with the sea are the galvanized steel armour wires and the polyethylene sheath, which also contain no additives that are harmful to marine life. The SEACOM network will use a combination of armoured and non armoured cable, depending on the risks posed to the integrity of the cable, reaching a maximum of 29mm in the coastal areas. The cable will be manufactured in New Hampshire, North America and Japan taking account of all design requirements before it is loaded aboard cable laying vessels, such that the deployment from the vessel simply involves the uncoiling of a pre strung cable, including repeaters, without the need for modifications aboard the vessel. Figure 4. SL17 Lightweight fibre optic communications cable for deep water4
Optical Fibers PBT Tube OD = 2.97 mm 8 Ultra-High Strength Steel Wires Wire OD = 1.88 mm
Copper Sheath OD = 7.45 mm
High Density Polyethylene Jacket OD = 11.54mm
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Figure 5. SL17 Double Armour fibre optic communications cable
Same As Lightweight (LW) Cable
Nylon Yarn Bedding
16 Galvanized Armor Wires Wire OD = 2.77 mm
22 Galvanized Armor Wire Wire OD = 2.77 mm
Tar Soaked Nylon Yarn Serve
Tar Soaked Nylon Yarn Serve
Tycos Reliance Class Vessels (Figure 6) built between 2001 and 2003 are representative of typical ocean going cable vessels. They have a gross tonnage of 12,184 tonnes, a length of 140m and can accommodate up to 80 persons. They have a ballast water capacity of 4,400 cubic meters. Figure 6. Tyco Reliance Class cable lay vessel
A frame supporting plough
ROV
Cable tanks
(source: Tyco Telecommunications)
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3.6.2 Terrestrial components

At each landing location, the marine cable will come ashore and be installed beneath the beach for a short distance inland to an underground concrete vault (referred to as a Beach Manhole (BMH) The BMH provides a chamber situated above the high-tide level where the marine and terrestrial cables are connected. Once constructed, with the exception of the manhole cover, there is little or no visible evidence of a BMH (Figure 7). The optical signal and power functions of the single marine cable are performed by three colocated terrestrial cables (comprising an earth cable, a power cable and the optical fibre cable) each of which will have a diameter of up to 25mm and will be laid between the BMH and the Cable Station in plastic ducts. The ducts themselves will be installed into shallow trenches of one to two metres depth and approximately one metre width. The trenches will be backfilled after the ducts are laid, and the surface conditions existing prior to construction will be reinstated. Depending upon the final configuration of the route of the terrestrial cable there may be a requirement for access to the ducts and cable along the route, which would be via standard manholes. Figure 7. Example Beach Man Holes
BMH (open)
BMH (covered)
From the BMH the cable will continue a short distance to a cable station where it will connect with terrestrial networks. In most cases the cable placed in an open trench and then buried. However in South Africa the cable will be buried using Horizontal Directional Drilling (HDD) discussed below. The Project will include either the use of existing cable stations or construction of new cable stations within each country. The cable stations will include secure (restricted to SEACOM) and open access facilities, including:
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An area to receive the submarine cable and interconnect with the backhaul to a metropolitan Point of Presence (PoP); An area to house ancillary equipment containing power back up and other essential plant; and A co-location area to ensure terrestrial providers with direct open access to the submarine fibre optic network.
In Egypt and Djibouti, existing cable stations (or extensions to existing landing partner facilities) will be used whereas in the other four landing countries cable stations will be constructed. Where new cable stations are required, these will typically consist of preassembled buildings (or containers) that will be transported to site and positioned on concrete pads. A typical landing configuration is shown in Figure 8. Specific configuration details are provided for each country in the sections below. Figure 8. Typical landing configuration
Typical cable landing configuration
Cable station
Secure
International waters
Territorial waters (12km)
Ancillary area air con. etc
Open Co location space Connection for national carriers
BMH
SEACOM cable
Backhaul to metropolitan areas
OGB
SEA
LAND
Source: amended from SEACOM website, Open Access http://www.seacom.mu/network/openAccess.html The marine cable includes a copper sheath around the insulation material that in turn surrounds the optical fibres. The copper sheath carries an electrical current that is used to power the subsea section of the cable system. This use of a single conductor is made possible by using the surrounding seawater as the earth (or ground) connection, which requires the installation of an ocean ground bed as part of the marine component of the system. The ocean ground bed comprises a number of rods installed below ground level, usually adjacent to the BMH. These rods are typically made of cast iron encased with magnesium to act as sacrificial anodes. The rods are placed vertically on the beach such that the lower end reaches the mean seawater level. A minimum of 3 rods are used for any
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anode field, but more typically 6/7 rods, each approximately 4m long (depending on the slope of the beach) and 0.25m in diameter. Installation will typically take up to 5 days. A Horizontal Directional Drilling technique will be used to bury the cable between beneath the Umlalazi nature reserve in South Africa. The process involves precision drilling techniques to control the angle and direction of a drill head in order to drill a hole of potentially several kilometres through which the cable can then be fed. In this instance HDD will be used to drill a narrow passage beneath the nature reserve over a distance of approximately 1.0km between the beach and the western edge of the nature reserve. The use of HDD removes the need to trench, although a limited earthworks and a small area of land is temporarily required to accommodate the vehicle mounted HDD equipment.
3.6.3 Marine components

Telecommunication cables are generally laid unburied on the seabed in deep waters off the continental shelf, where the risk of damage by activities such as fishing or vessel anchoring are minimal. In shallow waters cables are generally buried to a target depth of one metre below the seabed, using a towed plough. Before the cable is laid, a Pre Lay Grapnel Run (PLGR) is required along those sections of the route that require cable burial. This involves dragging a grapnel along the entire length of the buried cable route as an attempt to clear the sea bed of debris, i.e. wires or hawsers, fishing equipment, etc., which may have been deposited along the route. Any debris recovered during these operations is discharged ashore upon completion of the operations. Exposed cable sections may occur in areas where burial was intended, as a result of the need to cease ploughing near the intersection of the cable route with existing cables or pipelines. On occasions it may also be necessary to retrieve the plough for unplanned maintenance or repairs, and where adverse bottom conditions are encountered, such as steep slopes and rock outcrops. Areas of reduced burial may be attributable to a lack of seabed sediment or difficult seabed conditions. The marine cable is connected to a land cable at the beach manhole. Since landing areas are often located in sandy places near metropolitan areas, beach manholes are often located in or near beaches that are used for recreation. There may be some localized disruption of recreational activities during construction with machines trenching and pulling cable, but after installation, recreational beachgoers are typically unaware of the cable and it has no effect on their activities. On the beach, the cable is typically installed in flexible steel pipe with outside diameter on the order of 0.2m, in a trench two metres deep dug previously by equipment such as a backhoe. In cases of severe erosion, if the pipe becomes exposed it may be reburied.
3.6.4 Shallow water installation (low water mark to 10 m water depth)

At locations where the cable comes ashore the cableship is stationed offshore near its minimum working water depth of around 10m. A messenger line is passed ashore from the cableship, and is wound onto a winch located on the beach, via the beach manhole. The
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messenger line is connected to the cable on the cableship, and the line and cable are then winched ashore through the pre-dug trench and into the beach manhole. After the cable is is secured in the manhole, the cableship begins moving away from the beach to progress the offshore installation. The shallow water segment of cable, between the low water level and 10 m water depth, lies on the seabed until divers with water jetting machines bury it, normally to a target depth of 1 m. This process begins immediately after installation in order to avoid risk to the cable and potential interference with other activities. The diver-held water jetting machines remove and liquefy sediment, and the cable is placed in the trench they produce. The process produces some localized turbidity and disruption of bottom-dwelling flora and fauna. The trench is allowed to backfill naturally at varying rates, depending on local currents, sediment characteristics and the resultant movement of sediments.
3.6.5 Offshore continental shelf

The cable is installed by the cableship, and buried wherever seabed conditions permit from the landing point until the cable reaches a depth of 1000m, or the edge of the continental shelf. The burial is accomplished by a sea plough. A plough towed by the cableship opens a furrow in the seabed on the order of 0.75 m wide. The communications cable passes through the plough and exits the plough share at the aft lower extremity. As the plough moves forward, the cable is left in the bottom of the furrow. The furrow fills by natural movement of sediment. Normal target burial depths are on the order of 1m. Forward movement proceeds at about 0.2 to 1 knot, depending on the stiffness of the seabed and other factors. Figure 9 shows the plough burial process. Figure 9 Cable installation and plough burial
In water depths greater than 15 m at points where the cable crosses an existing active cable, the plough is lifted off the seabed and the cable is laid on the seabed (a fly-over). Later the cableship returns with a Remotely Operated Vehicle (ROV) to bury the cable using water jets at this crossing point. In rocky areas, places with hard bottom or steep slopes, the cable is laid on the seabed.
3.6.6 Deep water installation

In deeper water, where burial is considered unnecessary, the plough is recovered and the cable is laid unburied on the seabed.
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3.7
System Manufacture and Installation Country specific
3.7.1 South Africa

Onshore cable The marine cable will come ashore near the town of Mtunzini, in the Province of KwaZulu Natal. The landing point will be located approximately 400 metres south of existing infrastructure on the same stretch of beach, comprising the SAFE cable operated by Telkom and a seawater pipeline system owned by Vanuni Aquaculture. The landing beach backs on to sand dunes and coastal dune forest. The beach, coastal dunes and forest habitat are within the Umlalazi Nature Reserve, and as such they are protected to the extent that these areas should not be disturbed during cable installation operations. However, there is an exception made for a 1 km wide boat launch area across the beach, within which the landing location has been positioned [Ref 7]. From the landing point the marine cable will traverse a distance of 925m to a manhole at the Cable Station located adjacent to a railway station approximately 1km south west of the Umlalazi Nature Reserve gate in KwaZulu Natal Province (Figure 10b). Figure 10a. Landing location in Mtunzini, South Africa: Cable route - South Africa
Figure 10b. Landing location in Mtunzini, South Africa: Aerial view of preferred location of cable station and BMH
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The cable will be installed beneath the nature reserve using th Horizontal Directional Drilling (HDD) technique in which a small diameter borehole is drilled between 2 points through which the cable can be pulled. The HDD section will run between the HDD entrance (or punch-in) point adjacent to the Cable Station and the HDD exit (or punch-out) point close to the waterline on the beach. Some minor earthworks will be required near to the Cable Station to enable mobilisation of the HDD drill rig. The drill rig will drill a pilot hole in an arc profile from the this location, under the dune and natural vegetation between the Cable Station location and the beach, to break surface through the bottom of a 2m pre-excavated trench within a boat launch area of the Umlalazi Nature Reserve. The pilot hole will then be enlarged such that a duct can be installed through which the SEA Cable will be pulled, thus linking the system from the shore zone to the Cable Station via a subterranean passage. Figure 11. South Africa cable landing configuration
Marine cable From the beach, the cable will be oriented eastwards across South Africas territorial waters before trending in a north-easterly direction (Segment 1) towards Branching Unit (BU)1 where a branch cable links the main cable with Mozambique (Figure 10a). The sea bed slopes gently away from the beach reaching a depth of 20m at a distance of 5km and 50m depth approximately 40km from the beach. The sea bed is comprised of fine grain size sand to the 12mwd approximately 1km offshore. Beyond this point reef outcrops with intermittent sediment pockets of medium to very coarse sand dominate the cable route. Further offshore the cable will cross an area of sandy mobile megaripples with a 25m trough to trough distance5. The cable route will be located with in the prawn (shrimp) bottom trawl fishery area which extends to a depth of 200m. There is an existing 1nm no anchor/trawling zone designated either side of the South Africa Far East (SAFE) cable.
5
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Between the waterline and the edge of South Africas territorial waters the cable design and installation methods will be tailored in line with risks posed and operational constraints. The cable will be double armoured to a depth of 20m where it will be replaced by a combination of single armoured and then light weight armoured cable to a depth of 1000m at a distance of 65km from the shore. The cable will cross a number of out if service cables. This will involve the clearance of certain sections of such cables in order to clear the path for the SEACOM cable.
3.7.2 Mozambique
The marine cable will land in Maputo in an urban setting 8.5km north of the entrance to the Port of Maputo, immediately adjacent to and just south of the existing Mozambique Domestic cable landing site. The BMH will be positioned 70m inland from the landing point. (Figure 12). Figure 12. Landing location, Mozambique
Figure 12a. Cable route - Mozambique Figure 12b. View of cable landing area and existing BMH
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Figure 12c. Cable route across the beach
The landing beach slopes at about 4o and is a 20 to 30m wide sandy beach comprised of a very light-brown to buff coloured medium grained quartz sand. The area surrounding the BMH is covered by a reddish light-brown sandy soil with patches of grass and scattered large evergreen trees. Onshore cable From the BMH the 3 co-located terrestrial cables will be buried in a conventional services trench under the Maputo coast road (Avenida Marginal) and along the Avenida Marginal road reserve to the Cable Station location on the private property of autdromo ATCM. Onshore construction methods will be similar to those employed in South Africa except the cable will be buried following its placement in a conventional trench rather than by HDD. Construction activities will include:

Construction of the BMH Cable laying from the waterline to the BMH (20-30m trench on the beach) Installation of a pre-constructed cable station on a concrete pad Cable laying via a trench from the BMH to the Cable Station
Marine cable
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The cable route between Maputo and the Branching Unit offshore Maputo is shown on Figure 16a. The cable will follow the same path as the existing Mozambique Domestic Cable within Maputo Bay. Sand waves at the entrance to the Bay of Maputo along the route indicate strong current activity. At approximately 20mwd the route turns towards the southeast, crossing out of the Mozambique territorial sea and contiguous zone into the EEZ and deepening slowly to BU1 at approximately 1,500mwd. The cable will be buried to a depth of 1m from the shoreline to a water depth of approximately 1000mwd, as protection from external aggression. This is particularly important along the extensive shallow area between the mainland and Ilha Xefina Grande and at the mouth of Maputo Bay where strong currents and sand waves are present, as well as extensive third party activities such as fishing. Double armoured cable will be used from the BMH to a depth of 100m where it will be replaced by light weight armour and Special Purpose Application cable until it reaches BU1 located 250km from the landing at a water depth of 1500mwd.
3.7.3
Tanzania
In Tanzania the marine cable will land approximately 20km north of Dar Es Salaam adjacent to the Silver Sands Resort Hotel Complex in a sandy area adjacent to an area of mangroves. Silver Sands is adjacent to a designated marine conservation area (Dar es Salaam Marine Reserves System or DMRS). The BMH will be positioned within the boundary of the hotels western edge near the boundary fence on an unpaved access road. Figure 13. Cable landing location, Tanzania
Figure 13a. Cable route - Tanzania Figure 13b. Aerial view of cable landing and BMH
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Figure 13c. Beach landing location
The upper beach is characterised by small trees on compact reddish-brown grassy soil. The beach slopes gently down to the tidal flat where the extension of land at low tide is significant. The sand on the beach is poorly-sorted medium to fine light tan sand. Many rock jetties are in place to prevent erosion on this lower beach. Onshore cable Onshore construction methods will be similar to those employed elsewhere in the Project. Construction activities will include:

Construction of the BMH Cable laying from the waterline to the BMH using conventional trenching (100m trench on the beach) Installation of a new cable station beside the BMH (Figure 13b)
Marine cable From the BMH, heading to sea in an eastward direction, the SEA cable route winds through an area of coral reef and then across the continental shelf. The outer reef is the seaward limit for inshore operations. From the 25m depth contour the route drops down a 7 sandy slope then up a 5 slope on a plateau of coralline sand and gravel with several coral structures up to 8m in height. Approximately 1.5km before the shelf break the route crosses a NNE-trending line of small rock outcrops with more extensive, underlying structure visible in survey results. The route then crosses successive bands of sand, coralline sand with gravel and sand. The route crosses exposed rock just prior to and while dropping down the very steep shelf break at approximately 105mwd to 126mwd.
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3.7.4 Kenya
The landing location is situated on the site of the Swahili Cultural Centre, on Mombasa Island at an elevation of 22m, approximately 100 metres south of Fort Jesus. The site is owned by National Museums of Kenya which has indicated its support for the project, subject to the adoption of appropriate management measures. SEACOM has entered into a lease agreement with the National Museums of Kenya for the land required to construct and operate the BMH and Cable Station. The cable station will be containerized and located within a building faade that is architecturally and culturally appropriate to the site. The BMH will be located immediately adjacent to the cable station. Figure 14. Cable Landing location, Kenya
Figure 14a. Cable route - Kenya Figure 14b. Aerial view of cable route and BMH
Fort Jesus
Onshore cable The cable will land on a small sandy beach with rock outcrops (Figure 14d). The beach extends approximately 10m at a steep slope before it ends at a small rock outcrop. From here the slope gradient increases and the cable will climb a steep angle through an area densely vegetated with shrubs and small trees (Figure 14c).
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Figure 14c. Rocky outcrop with slope
Figure 14d. Landing beach
Figure 14e. Wave cut platform
Marine cable On its approach from the sea the cable will cross a wave cut platform (Figure 14e). A small trench will be cut through the platform to house the cable. Beyond the wave cut platform the physiology of the marine cable route is characterised by water depths that increase very gently as the route trends to the ESE. The route heads south, crossing a west-trending scarp where slope gradients reach up to 19. The route turns towards the SSE, crossing from the Kenya EEZ into the Tanzania EEZ.
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3.7.5 Djibouti
Onshore cable The beach manhole in Djibouti is located on the shoreline, approximately five km from the Cable Station, which will be located in an existing terminal building that has already been constructed by SEACOMs landing partner Djibouti Telecom. Figure 15a. Cable route, cable landing location, Djibouti
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Figure 15b. Aerial view of cable route and BMH
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Figure 15c Aerial view of cable route and BMH
Marine cable The cable route follows an existing cable corridor (two retired and one live cable) that is subjected to anchoring, dredging and trawling prohibitions as it approaches Djibouti. The SEACOM cable will deviate to the south of this corridor approximately 0.5 km from the shore and again over a 2 km length around the 30m depth mark (Figure 15d).
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Figure 15d. Cable route through Djibouti waters
3.7.6 Egypt
The cable lands in Egypt at the town of Ras Sudr, on the west coast of the Sinai Peninsula, in the Gulf of Suez. The landfall beach is a sandy public beach (government owned) which is largely derelict with extensive areas of concrete foundations and rubble. The area is shown in Figure 16b. The land is bordered to the south by a brick wall and holiday houses. More open land is located to the north and a tarmac public access road and car park is located to the east. The Intertidal area is approximately 10m wide and is backed by an approximately 1m high beach berm. Figure 16 shows the beach manhole location and the terrestrial cable route that follows road reserves to an existing Telecom Egypt facility that will house the Cable Station.
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Figure 16. Cable landing location, Egypt

Figure 16a. Cable route - Egypt Figure 16b. Aerial view of cable route and BMH
Figure 16c. Landing beach
Figure 16d. Cable route (adjacent to wall) leading to an existing Telecom Egypt cable station approx 1.35km from the beach.
3.8
System Operation
The cable will not require significant routine maintenance, thus limited activities are anticipated during the operational phase of the Project, although the cable may be recovered for repairs or replacement in exceptional circumstances. Where repair is required, the cable is recovered and repaired by a ship. For example, in the event that the cable is broken it would be recovered using a grapnel hook towed by a vessel travelling perpendicular to the cable route, spliced and return to the seabed. If burial is required this would be achieved using water jet burial, or else the cable would be simply laid on the seabed. Following such repair work additional cable is used to connect the severed ends which results in slack cable once retuned to the sea floor.
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3.9
System Decommissioning
At the end of the Projects design life of 25 years the cable will be decommissioned in line with best practice at that time. Based on current best practice the cable will either be left insitu, or recovered and to the extent possible recycled. The latter will involve short term and localised disruption of the sea floor through physical disturbance and increased turbidity. Additional impacts and increased risks typically associated with any large vessel will also occur. For this Project, following an environmental appraisal to determine net environmental benefit, it is anticipated that some cable will be recovered from the shallow waters whilst the majority buried cable and deepwater cable will be left in-situ.
3.10
Schedule
SEACOM will be ready to serve Southern and East African markets from 2009, in time to meet the bandwidth needs of the 2009 Confederations Cup and the 2010 Soccer World Cup in South Africa, and the growing requirements of the economies in the countries it serves. The Gantt chart below summarises the timescales associated with key stages of the Projects development. Figure 17. Project schedule 2007 2009
2007 Activity DTS and route selection Marine Surveys Cable manufacture Cable laying Terrestrial Construction
Q1 Q2 Q3 Q4 Q1
2008
Q2 Q3 Q4 Q1
2009
Q2 Q3 Q4
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Baseline Data
The characterisation of project areas is an essential component of the EIA process and is required in order to determine the likely impacts and to document baseline conditions for monitoring purposes. The level of effort afforded to baseline data collection should be commensurate with the scale and nature of the Project. This section outlines the approach and methodologies used to collect baseline data and summarises the findings. More detailed baseline data is provided in the country specific EIAs. Baseline data has been acquired to meet national requirements and to comply with Equator Principles requirements for a Category B project. Given the Projects limited environmental impact, ecological survey of the entire route is unnecessary. Instead, bathymetric and geological survey (including characterisation of the seabed) has been undertaken for the entire 13,000km cable route. In certain cases where known or perceived sensitivities have been identified (e.g. coral reefs) supplementary baseline data collection studies have been performed. The main aim of the baseline data collection process has been to provide a sufficient level of detail such that environmental and socio-economic sensitivities can be avoided. In particular, areas that are unique and/or particularly vulnerable to disturbance were identified.
4.1
Approach and Methodology
4.1.1 Environmental (offshore)

The entire submarine cable route has been assessed, firstly in a comprehensive desk top study (DTS), and secondly by a marine survey (see section 3.5.4). The main purpose of the DTS was to undertake a comprehensive review of available information pertaining to the feasibility of a route, taking account of physical and operational constraints. The DTS for this project, undertaken on behalf of Tyco Telecommunications, the overall SEACOM Cable System supplier, included analysis of bathymetry, geology, climatology, oceanography, fisheries, permitting and other hazards and restrictions. The subsequent Marine Survey for the SEACOM Project has been undertaken in phases, involving extensive data collection from dedicated marine survey vessels traversing the full extent of the Cable System. Nearshore and Deep Sea Survey programs were designed to allow field evaluation of the preliminary routing plan developed as part of the DTS. Phase 1 of the Marine Survey encompassed the southern portion of the Cable System route, from South Africa, via Mozambique and Tanzania to the BU offshore Kenya. Phase 2 of the Survey covered the cable route and landing countries to the north, between Kenya, Djibouti, India and Egypt.
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The scope of the Marine Survey included the survey of each Landing Site, Nearshore waters by diver and small boat, deep sea and branching unit surveys, including:

A beach landing topographic survey within a survey corridor of 10m from the beach manhole (BMH) to 0m Lowest Astronomical Tide (LAT). A diver swim survey from 0m (LAT) to approximately 3mwd within a 10m corridor, with a minimum of one line along the route. An inshore survey collected bathymetric, Side Scan Sonar (SSS) and Side bottom profiler (SBP) data within a corridor width of 500m from 3 to 20 metres water depth (mwd). A nearshore survey collected bathymetric, SSS and SBP data within a 500m corridor from approximately 20mwd to the first occurrence of 100mwd. And a corridor width of 1,000m from 100mwd to the end of burial depth (i.e. 1,000mwd, or 300m in Red Sea area). Gravity cores at 5km intervals. Survey equipment comprises swathe echo sounder, side scan sonar, sub-bottom profiler and magnetometer survey to detect any existing cables and pipelines. A deep sea survey along the route collected bathymetric data within a corridor width of at least two times water depth in excess of 1,000mwd, up to a maximum single swath of 10km. A branching unit (BU) survey over an area six times water depth centred over the BU site. A seabed / ground sampling program covered all survey areas and consisted as a minimum of: Landing site survey: bar probing every 25m, Diver survey: bar probing every 25m, (100m for the landing in Mozambique) Inshore survey: grab sampling every 500m with a minimum of two attempts, Nearshore survey: piston cores on average every 10km with a minimum of two attempts, and in the event of core failure, dredge sampling with a minimum of two attempts.
Temperatures and sound velocities through the water column were measured on a daily basis, or more if required, using expendable probes (XBTs).
Cable and pipeline crossing surveys to detect existing cables/pipelines. Survey in water depths of less than 20 meters was undertaken using a locally chartered boat and collected bathymetric, side scan sonar (SSS) and sub-bottom profile (SBP) data within a corridor width of 500m from 3 to 20mwd, with a minimum seven primary survey lines (100% SSS overlap) and tie lines at 10 times the primary line spacing with a minimum of two lines. These various surveys provided information on the bathymetry and geology along the surveyed route, including a characterisation of the seabed. Examples of the mapped survey output are provided in Annex 2.
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For each country EIA data gathered using the above techniques has been considered and where appropriate supplemented with additional ecological survey works, using desk-top study and/or shallow water ecological survey techniques where necessary e.g. dive surveys. Additional nearshore ecological surveys were performed in Djibouti, South Africa (desk-top), Egypt, Tanzania, Kenya (desk-top) and Mozambique (desk-top). Details are provided in the respective national environmental documentation.
4.1.2 Environmental (onshore)

In all landing countries the cable will traverse small distances (a few kilometres or less) to the Cable Station. For each landing country a number of potential landing sites have been surveyed (within the scope of the desk-top study) and a preferred landing location/cable route selected based on operational and environmental factors. The initial studies included a walkover survey for each location between the landing location and the cable station. More detailed studies for the selected terrestrial routes have also been completed as part of national environmental approval processes. ENVIRON, the preparers of this EIA has inspected each landing location, in conjunction with local environmental consultants.
4.1.3 Socio-Economic (onshore and offshore)

Socio-economic baseline data has been gathered on a country specific basis including the characterisation of the socio-economic environment. Due to the limited size and nature of the Projects terrestrial component and the limited social impacts, systematic and extensive socio-economic baseline surveys were not required. Although not identical, each country EIA adopted a similar approach for the collection of socio-economic baseline data collection involving the targeting of directly affected parties. The targeting involved:

Stakeholder identification Consultation with regulatory parties Consultation with the public through meetings and focus groups.
Issues and priorities varied between countries, but in general were concerned with possible adverse impacts to:

fisheries (artisanal and commercial) tourism other marine users (recreational and commercial)
Onshore concerns were minimal, with the most significant potential sensitivity identified being proximity to the Swahili Cultural Centre in Kenya, although even here the mitigation measures discussed during consultation were seen to provide an overall positive benefit. Potential socioeconomic impacts offshore are focussed on potential damage to socio-cultural artefacts such as shipwrecks. One of the objectives of the marine survey described in section 4.1.1 above was to identify and avoid any seabed obstructions, such as shipwrecks, that could interfere with the laying or operation of the cable. At one location, Mombasa, Kenya, the known location of an historic wreck was pointed out to Project representatives and it was confirmed that the cable route did not intersect the wreck site.
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4.2
Findings
The key characteristics of the Project-affected natural and socio-economic environments are highlighted in Table 5.
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Table 5a - Environmental characterisation of Project area - Terrestrial and shallow waters

Landing country Egypt Terrestrial Landing beach/intertidal zone Territorial Waters Notable sensitivities (e.g. protected areas/rare species) None
Short terrestrial cable route alongside existing roads in the urbanised area of Ras Sidr.
Sandy urban beach consisting of very fine to coarse sand.
The shallow coastal water of the study area comprises extensive sand and mud areas. The sandy bottom gradually slopes into offshore areas with occasional poor quality fringing dead reef patches covered with algae. Poor diversity of benthic organisms, although numbers are high.
Djibouti
Urbanised area of Djibouti city. The cable will traverse <100m of reclaimed land with no ecological value.
Shoreline is reclaimed material. Intertidal reef platform and nearshore muddy sand and sand with little ecological value.
Nearshore muddy sand and sand desert, and further offshore gravelly and rocky bottoms intersected by fine sandbank channels. The area is considered to be in poor ecological condition as a result of the large volumes of untreated solid and liquid waste discharged to the sea particularly from Djibouti city. There are a number of Marine Protection areas, but the cable does not traverse these.
None
Kenya
Urbanised area of Mombasa. Short terrestrial cable route to a Cable Station site in the grounds of the Swahili Cultural Centre.
The shoreline is comprised of a wave cut platform of soft coral rock. Immediately offshore, the cable is routed through a shipping channel. In the project area, various aquatic flora and fauna such as Crabs, Limpets, Mussels, Clams, Sea Urchins, Sea
In the project area, various studies have reported sea grass, fauna, fishery, and crustaceans. The studies have not pointed to any specific measures requiring priority conservation in these systems. Numerous fish species have been identified but no special life stage areas
None
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Landing country
Terrestrial
Landing beach/intertidal zone
Territorial Waters
Notable sensitivities (e.g. protected areas/rare species)
Anemones, Tube worms, Algae and Seaweed, among others, are present in the intertidal zone. However, studies have not revealed any critical assemblages of fauna and flora in the benthic and aquatic systems.
including nursery, migration routes and breeding areas have been reported in and around the cable path. Seagrass is abundant along the majority of the Kenyan coastline providing an important habitat for many species. However, there is no evidence of sea grass along the path of the cable. A number of marine nature parks are avoided by the cable.
Mozambique
The area is urbanised. A short cable route along a road reserve leads to a Cable Station located on a race course.
A narrow strip (<100m) of dune vegetation exists along the beach with predominantly native species although native species have been replaced with non natives to help stabilise dunes. The intertidal area consists of bare fine sands, with no vegetation.
A shallow subtidal area of clear, marine water over medium sand sediments. There is no vegetation and the only flora consists of phytoplankton in the water column. Nearshore waters support a variety of cetaceans, fish, shellfish, turtles and marine birdlife. Sea turtles, dugongs and dolphins in the Maputo Bay area are considered to be protected species under national law and international conventions. Sporadic reef, seagrass and rocky intertidal areas found in the Maputo bay area are sensitive habitats.
None
Tanzania
Very short (<100m) terrestrial cable route in a peri-urban area of Dar es Salaam. Adjacent to the grounds of a hotel.
Sandy beach. The intertidal zone is comprised of medium grained sand.
The general area supports a number of important habitats. These are preserved in a number of Marine Reserves (the Dar es Salam Marine Reserve System) which
The cable route avoids the numerous marine reserves. While there remains an unavoidable
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Landing country
Terrestrial
Landing beach/intertidal zone
Territorial Waters
Notable sensitivities (e.g. protected areas/rare species) band of coral (approx 500m width), its biological diversity is not of great concern, because many years of damaging fishing activity have reduced the diversity of the reefs.
surround the islands off the Kunduchi coast. The cable will avoid all marine reserves although it does cross an area of coral reef and sea grasses. Unregulated use of dynamite for fishing (especially in coral reefs). Elsewhere, the seabed within the territorial waters tends to be a uniform sandy bottom. South Africa The cable route between the landing on a sandy recreational beach traverses the Umlalazi nature reserve which includes dune and mangrove habitats and a diversity of flora and fauna and is a internationally recognised Important Bird Area (IBA). However, the cable connection between the beach manhole and the Cable Station will be via a small diameter bored tube, so there will be no impacts to the surface of the reserve over this section of the cable. Coastline consists of a linear, clastic, prograding shoreline comprised of a series of coastparallel beach ridges. The continental shelf along the KwaZuluNatal coast, is very narrow (averaging 5km), and has a shelf break in water depths of between -60 m and -100 m The seafloor topography on the shelf, is gently sloping (0.1-0.2) with intermittent rock outcrops and the development of a mid-shelf plateau (palaeo-coastline) feature. The seafloor sedimentary facies comprise fine-grained well-sorted sands), poorly sorted shelf sands, interspersed with inner and mid-shelf muds, and coarsegrained sand and gravels. Macro-benthic and reef communities on the cable route are not considered to be markedly different from those nearby.
While the cable must traverse the protected Umlalazi Nature Reserve the use of the horizontal directional drilling technique between the shoreline and the Cable Station means that there will be no surface impacts over this section of the Reserve.
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Table 5b - Social characterisation of Project area - Terrestrial and shallow waters

Landing country Egypt Social setting Landing at the small town of Ras Sudr; population of ~2,000. Existing social activities The tourism industry is the main employer in the governorate of South Sinai, in general, and Ras Sudr. Fishing is practiced. In 2004, 140 individuals worked in the fishing industry in Ras Sudr The Cable Station will be housed in an existing building 5 km from the BMH, in a suburban area of Djibouti city. The BMH will be connected to the Cable Station with cable to be installed in pre-existing ducts. An important area for tourism due to the presence of the old town of Mombasa and Fort Jesus. The terrestrial component of the project area falls under the old town conservation area. Shipping activities - The cable route traverses a navigation channel to the old port of Mombasa. Traffic into the old port is not high, but nevertheless is used by vessels moving between regional harbours. The Port of Mombasa is also nearby. Artisinal fishing activity has been observed in front of the Swahili Cultural centre. Commercial fishing activities take place in deeper waters off the reefs. A substantial fishing fleet operates in Kenyan waters following the migratory route of their catch. Shellfish are collected for subsistence and sale. Shrimp are caught on a semi-commercial basis using trawl and beach seine nets. Other fish species of special concern also use Maputo Bay mangrove habitat, which serves as nursery. Several coastal and estuarine fish species are also caught. The proposed Cable route crosses an important artisanal fishing area in the northern part of the Bay (but misses commercial areas). Other marine activities within Maputo Province include None None Notable sensitivities
Djibouti
Landing in the urbanised and densely populated Djibouti City The Project area is in the urbanised southern end of Mombasa island The cable station will be located on the property of the Swahili Cultural Centre (SCC) adjacent to Fort Jesus, which is a public recreational area and an area of cultural importance.
Kenya
Possible archaeological artifacts and the Swahili Cultural Centre which is designated as historic site within the Old Town Conservation Area. (These have been investigated by conducting an archaeological survey of the Project area and the development of mitigation measures.) Potential interference with fishing activities during the brief construction period.
Mozambique
The cable will land in a suburban residential area of Maputo city.
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Landing country Tanzania
Social setting The cable comes ashore in a peri-urban area of Dar es Salaam, via a recreational beach adjacent to the grounds of a hotel. The area is mainly vegetated with little residential or commercial use other than the hotel.
Existing social activities navigation and some water sports, as windsurf, kayaks, sailing. There are diverse livelihoods in the general area; economic activities including a stone quarry, sand mining, shops and small business, salt making, fishing, small gardens and animal husbandry. Few fishers operate from the area. The beach area of Silver Sands Resort Hotel is far from major settlement areas and has a limitation to free access. Local fishing communities are involved in the direct extraction of marine resources in the waters within Dar es Salam Marine Nature reserves system (DMRS). Fishing is mainly artisanal and conducted by local community but sometimes seasonal fishers from elsewhere. Commercial fishing tends to take place away from the cable route. Fishing along the Kunduchi coast is unregulated resulting in unsustainable fishing gear and methods such as the use of dynamite, beach seines and spear guns that are detrimental to marine ecosystems.
Notable sensitivities Potential interference with artisinal and commercial fishing activity during the brief construction period..
South Africa
The cable will land on a recreational beach backed by a nature reserve.
The beach area within the Reserve is utilised for various recreational activities such as kite-boarding, swimming and recreational fishing, both on-shore and off-shore (ski-boat). The Reserve also offers accommodation in the form of lodges and camping facilities. In the vicinity of Mtunzini, recreational fishing mainly by members of the Umlalazi Ski Boat Club. There is a small-scale established commercial prawn trawling fishery in the area.
Fishing activities potential expansion of an existing trawling exclusion zone. Short term impacts on Umlalazi Nature Reserve recreational beach/nearshore sea users during the brief construction period.
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4.2.1 Deep water characterisation

In contrast to the shallower Continental Shelf areas, the High Seas worldwide are poorly understood, particularly in terms of ecological and natural resources, with only 0.0001% of the deep sea floor having been subject to biological investigation [Ref 8] In general, the deep waters of the High Seas are ecologically less productive than shallower waters (due to limited light penetration). However, the High Seas account for 50% of the earths surface and have been increasingly recognised over recent decades for their ecological diversity, interconnectivity with other ecosystems and the role they plays in the overall health of the planet. Despite the limited scientific knowledge of the High Seas, a picture has emerged over recent decades that reveals previously unknown biological value and also identifies a number of particularly important resources and distinct habitats such as deep sea hydrothermal vents which can support a wealth of exotic species. A brief summary of known features and habitats generally found in the High Seas is provided below, along with their known proximity to the cable route for the SEACOM Cable System. Hydrothermal vents The first hydrothermal vent was discovered in 1977 at a depth of approximately 2500m on the Galapagos rift off the coast of Ecuador. Since that first discovery many more have been found along mid ocean ridge systems with estimates made that vent sites might typically occur at a rate of one every 100km of ridge, equating to 500 vent sites worldwide. A vent occurs when seawater penetrates fissures in the ridge, is heated by proximity to magmatic chambers and expelled from the seabed as a high temperature plume of mineral laden water, often referred to as a smoker (Figure 18). The water often contains high concentrations of hydrogen sulphide, and it is the sulphide which provides the primary energy source for microbial chemosynthesis, and thus a food source for adapted organisms including snails, tube worms, crabs and shrimps. Vent habitats are extremely localised and each is generally restricted to an area of less than 1 km. Figure 18. An active hydrothermal vent
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Active hydrothermal vents are found across the globe but are generally restricted to spreading ridges. The most studied vents are located on the Mid Atlantic Ridge and Pacific Mid Ocean Ridge with the majority of the ridge systems yet to be explored. Within the project area active vents have been identified along the Central Indian Ocean Ridge and along the ridges of the Red Sea and Gulf of Aden. These are either inactive (with no unique ecological value) or located away from the cable route. The closest are between 20 and 80 km of the cable route. Known active vents in the Red sea and Gulf of Aden are shown in Figure 19 relative to the cable route. Numerous vents are found in the Indian Ocean although these are located hundreds of kilometres from the cable route. [Ref 9] Figure 19. Location of hydrothermal vents
Seamounts Seamounts are steep sided undersea mountains or hills generally of volcanic origin but sometimes formed through converging tectonic plate movements. Seamounts are a relatively recent ecological discovery with knowledge of their distribution only becoming apparent over the last 50 years. Globally there are an estimated 30,000 in the Pacific Ocean alone providing mid ocean habitat for 600 identified invertebrates which in turn support an abundance of fish and birdlife in comparison to the surrounding area. Seamounts are important because:
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They vary greatly in their biodiversity, can have a high degree of endemism, may be centres of speciation, and may act as "stepping stones" for the dispersal of coastal species. They are areas of high production that support commercially important fisheries.
Nearly 80 species of fish and shellfish are commercially harvested from seamounts and include rock lobster, mackerel, deep-sea red king crab, red snapper, several tuna species, orange roughy and perch. Some seamounts have been shown to support high levels of biodiversity and unique biological communities. Marine mammals, sharks, tuna, and cephalopods all congregate over seamounts to feed, and some seabirds have been shown to be more abundant in the vicinity of shallow seamounts. Figure 20. Image of a seamount using multi beam sonar techniques
Source: [Ref 10] As indicated above, seamounts are abundant but can support unique ecosystems. Figure 22 identifies seamounts in the Indian Ocean, indicated by red or green dots where they occur outside of economic exclusion zones.
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Figure 21. Seamounts in the Indian Ocean
The SEACOM cable route does not impinge upon any seamounts. Deep sea trenches Deep sea trenches are formed at the boundary of tectonic plates as the oceanic crust buckles downwards as the plates collide. The majority of trenches range from 6,000m to 11,000m water depth and comprise approximately 1% of the total oceanic area. The benthos of these deep water zones has been termed hadal fauna and is largely unique because it has adapted to the tremendous water pressure at such depths. Often organisms will be endemic to a single trench. Consequently these areas provide unique habitats for organisms that have adapted to cope with the immense hydrostatic pressure. Across the globe there are 37 deep sea trenches including 4 in the Indian Ocean. However all are considerable distances from the cable route and are therefore not discussed further. Deep sea corals Deep sea corals (also referred to as cold water corals) are similar to warm water corals, forming a hard branched exoskeleton of calcium carbonate to house polyps and similarly support a diversity of marine organisms. However, deep sea corals feed on detritus and develop in cold deep water e.g. Lophelia pertusa which can develop in depths of up to
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2000m and water temperatures between 4 8oC. They are commonly found on seamounts, where the elevated terrain generates fast moving currents that supply food and helps maintain sediment free surfaces. Figure 22 provides an indication of known deep sea coral areas around the world. To a certain extent the figure is a reflection of study areas, but does indicate that the cable route does not traverse any known deep water corals.
Figure 22. Known global distribution of deep sea corals. [Ref. 11] The cable will be laid in areas to specifically avoid seamounts and associated deep water corals for cable security reasons. However, even if the cable was to traverse an unknown area of deep sea coral the impacts would be minimal and it may even offer a hard substrate for further coral growth. Any detrimental impact associated with cable laying would be expected to be minimal. Cold seeps A cold seep (sometimes called a cold vent) is an area of the ocean floor where hydrogen sulfide, methane and other hydrocarbon-rich fluid seepage occurs, often in the form of a brine pool. Cold seeps constitute a niche habitat supporting several endemic species. Entire communities of light independent organisms develop in and around cold seeps, most relying on microbial chemosynthesis. Cold seeps are similar to hydrothermal vents in that they are the only known ecosystems that do not rely on photosynthesis for food and energy production. Unlike hydrothermal vents which are volatile and ephemeral environments, cold seeps emit at a slow and dependable rate and many cold seep organisms are much longerlived than those inhabiting hydrothermal vents. Recent research has revealed that the seep tubeworm Lamellibrachia luymesi may be the longest living noncolonial invertebrate known, with a lifespan between 170 and 250 years.
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The first cold seeps were discovered in 1984 in the Gulf of Mexico at a depth of 3,200 metres. Since then, seeps have been discovered in other parts of the world's oceans, including the Monterey Canyon just off Monterey Bay, California, the Sea of Japan, off the Pacific coast of Costa Rica, in the Atlantic off Africa, in waters off the coast of Alaska, and under an ice shelf in Antarctica. The deepest seep community known is found in the Japan trench at a depth of 7326 m. Cold seeps develop unique topography over time, where reactions between methane and seawater create carbonate rock formations and reefs. To date no cold seeps have not been identified in the Indian Ocean and there is no evidence to suggest any are located close to the cable route. In summary, despite limited understanding of the High Seas, there are known to be a number of unique features supporting diverse and ecosystems and unique species, often restricted within small geographical areas. A number of international treaties offer some environmental protection to these areas, although these tend to have limited scope and are difficult to both apply and enforce. Nevertheless, no High Seas sensitivities have been identified along the cable route, and where such sensitivities have the potential to occur the impact of the Project would be minimal.
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Social and Environmental Impacts and Mitigation Measures
This section highlights the potential impacts associated with construction, operation and decommissioning of the cable including both real and perceived impacts. A significance rating is assigned to each impact after the application of any mitigation measures aimed at reducing the potential impacts.
5.1
Significance criteria
In order to prioritise issues requiring mitigation and determine the overall significance of the Project a number of social and environmental significance criteria have been developed. Using a simple approach impacts can be categorised as High, Moderate, or Low taking account of numerous factors such as:

The sensitivity of receptor (e.g. common species/habitats vs protected species/habitats) Geographical extent of impact Duration (short, medium, long term or permanent) Recoverability (natural recovery/intervention required/non recoverable)
Numerous criteria/techniques are available to assign significance, although there is no consensus on a preferred methodology, and all require some degree of professional judgement. However, they should allow significance to be assessed using a systematic approach in which significance determinations are reproducible. Table 6 provides definition for social and environmental significance. The criteria have been based on the threshold guidance for the interpretation of major accidental harm to the environment [Ref 12] and are intentionally developed to be applicable to any large scale project, rather than specifically for the SEACOM project. In this way the Project is realistically compared against other international projects. Where no impacts have been identified a statement to that effect is made in Section 5.2.
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Table 6: Impact Significance Criteria

Category High Moderate Low
Environment
Social
1 2
Knock-on threats to human health Affects large areas of designated conservation areas1 Persistent impact and/or inhibits regeneration Severe long-term damage to eco-system2 Permanent loss of significant local culture, amenity Significant loss/reduction of livelihood Significant disruption to the community/ indigenous people (e.g. resettlement)
Affects moderate areas of designated conservation areas3 Moderate long-term or severe short-term damage to ecosystems4
Minor detrimental impacts
Permanent loss of moderate amenity Moderate loss/reduction of livelihood Moderate economic disruption to the community/indigenous people
Minor detrimental impacts
>10% or 0.5 ha of designated conservation area, sensitive flora and fauna Any loss of Red Data Book6 species or >5% of common species 3 >1% of designated conservation area, sensitive flora and fauna 4 >1% of common species population.
5.2
Positive Impacts
The SEACOM Project will result in a range of positive impacts, the most important of which are discussed below. Submarine telecommunication cables are important for international telecommunication networks as they transport almost 100% of transoceanic internet traffic throughout the world (www.iscpc.org). In addition, it is widely recognised that access to affordable international bandwidth is key to economic development in every country. Currently, Africa relies primarily on satellites to provide for international communications. Communication via submarine telecommunication cables generally allows for lower cost, improved performance and greater capacity (throughput) than that available via satellite. Improvements in Africas information technology infrastructure via telecommunication cables will remove one of the current key perceived inhibitors to development in Africa and support economic growth opportunities on the continent. For example, greater bandwidth performance and capacity at significantly lower costs will be a potential catalyst for productivity and the growth of service industries such as call-centres, back offices and research institutions in Africa.
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Following installation of the proposed SEACOM Cable System, SEACOM will be the first full service provider of international fibre-optic bandwidth along the eastern coast of Africa and will facilitate more affordable and effective transport of voice, data, internet and television services. The improved telecommunications resulting from the Project will assist in the economic development of those countries served by the SEACOM cable. In addition to the overall impetus to economic development that the Project will generate SEACOM, as part of its social mission, is offering 40 universities, education and research institutions in South Africa access to 50 times their currently available bandwidth, at the same price that they currently pay. Furthermore, after six years of this arrangement the institutions will own the capacity for the remaining life of the SEACOM Cable System. The bandwidth that the institutions will have access to will be almost equal to that currently available to the entire South African population. With access to high capacity bandwidth, these institutions can anticipate an increase in international research collaborations and distance learning programs. SEACOM has extended this below-cost bandwidth offer to an alliance of Southern and Eastern African Universities. SEACOM is also developing a strategy to partner with African governments in deployment of mass-based e-government services through existing and extensive government structures such as post offices in various African countries. NEPAD (New Partnership for Africas Development) objectives include increasing sustainable growth in Africa, halting the marginalisation of Africa in globalisation and eradicating the inequalities between Africa and the developed world. SEACOM has acknowledged NEPADs policy directives for the development of broadband in Africa. The table below outlines the rights and obligations of the new telecommunications operating entity as stipulated in Article 10 of the NEPAD Protocol.
Article 10 of NEPAD Protocol 1a) Provide affordable cross border broadband regional infrastructure. 1b) Ensure landing rights in various countries to Authorised Service Providers (ASPs). 1c) Purchase capacity in bulk on behalf of all ASPs. 3d) Provide national leased capacity to ASPs. SEACOM offerings SEACOM would consider facilitating intra-Africa cross border traffic via submarine cable. SEACOM would consider becoming an ASP to NEPAD and explore the opportunity to land in land -locked countries. SEACOM will provide wholesale priced bandwidth to any party for resale subject to local regulations. SEACOM would explore any offer for national leased capacity which would extend network reach.
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5.3
Negative impacts and mitigation measures
The project will result in a number of negative and positive impacts. The majority of these will be associated with the construction activities, although some may occur later during the operational phase, depending on the need for maintenance/repair, and then later still in the decommissioning phase. Potential impacts are described for the pre-construction, construction, operational and decommissioning phases of the Project. Where appropriate, mitigation measures are provided with reference to the Action Plan, where applicable mitigation measures are further detailed. The Action Plan is a stand-alone document that is referenced in chapter 10 of this report; the current version is reproduced as Annex 3. Cross references to the Action Plan are indicated in parentheses e.g. EPAP ES27 & ES28.
5.3.1 Pre-construction
The pre construction phase refers to initial route selection work including the desk-top survey (DTS) which delineated the indicative cable route, and subsequent onshore/offshore route selection survey work, in particular, the marine survey. It therefore includes a number of onshore surveys and the use of vessels and survey equipment during marine surveys. There are no impacts resulting from desk-top survey work and therefore this section focuses on the marine survey. ENVIRONMENTAL IMPACTS A number of survey techniques are used during route selection studies that include use of geophysical and geotechnical survey equipment, such as: Geophysical equipment

Side scan sonar Sub-bottom profiler Multibeam Marine magnetometer, and
Geotechnical Equipment

Gravity corer or vibrocore Cone penetrometer test (CPT) rig
The geophysical equipment utilises non intrusive techniques (e.g. echo sounding) to record sea bed bathymetry/objects. Coring devices and the cone penetration tests involve minimal ground disturbance at discrete locations. Impacts from these survey techniques are all considered to be low. Impacts that may result from the operation of survey vessel(s) are described in Section 5.3.2 vessel operations.
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SOCIAL IMPACTS There are no discernible social impacts associated with the pre construction phase.
5.3.2 Construction
The construction phase will include offshore cable laying and construction of terrestrial cable system facilities. ENVIRONMENTAL IMPACTS (OFFSHORE) Offshore construction activities will result in some negative environmental impacts during route clearance and cable laying, particularly to benthic biota along the survey route. However, at any one location the disturbance will occur over a very short duration, natural recovery will readily occur and impacts will therefore tend to be minor in nature. Route clearance The Pre Lay Grapnel Run (PLGR) operation (as described in Section 3.6.3) can result in a number of impacts. Firstly, any debris recovered during these operations will be brought ashore for disposal. Any recovered waste should be classified by type and disposed of in an environmentally responsible manner and in accordance with the Basel Convention. The removal of wastes from the seabed will be a positive impact of the Project. The impact of onshore disposal of the wastes has the potential to be of moderate significance, but with adherence to the waste management provisions set out in the Project Action Plan (EPAP ES27 & ES28) this negative impact will be of low significance. Secondly, the grapnel will penetrate the seabed to a depth of up to 0.8 metres. Due to the intrusive nature of this operation some negative impact is unavoidable. Impacts include the generation of a small amount of turbidity and through physical contact mortality or injury to marine organisms, particularly plants and other organisms that have low mobility. These impacts will be minimised if sensitive areas e.g. coral reefs are avoided to the extent possible. In reality, the cable will not be buried amongst coral reef (and other hard substrates) and therefore PLGR is not required in such areas. Furthermore, the same centreline will subsequently be used for the cable burial and any impact from the PLGR will be minor by comparison. There may be occasions when additional grapnel runs are required either side of the centre line when debris is located, but such occasions are typically infrequent and associated impacts will be minor. Based on the operational necessity to avoid certain sensitive areas, the short term duration of the PLGR and the ability of soft sediment habitats to readily recover without intervention, the potential environmental impacts associated with physical disturbance of the seabed are assessed to be of low significance and no mitigation, other than those associated with operational necessity is necessary.
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Cable Laying Cable laying techniques are described in Section 3, with the towed plough being the favoured burial option where technically feasible. Although the cable itself is less than 30mm in diameter, cable burial will cause some physical disturbance along the route centreline. Physical disturbance, associated with the cable laying will affect a 5 meter swath of the seabed. Negative impacts can also result from raised suspended sediment and turbidity levels. Physical harm to aquatic organisms, especially sessile or low mobility organisms can occur over the 5m swath. The impact in the immediate vicinity of the buried cable taken in isolation is expected to be negligible. The impact of cable burial activities on marine aquatic organisms is assessed as being of low significance and is not subject to mitigation measures other than those incorporated into industry standard practices such as those listed below (EPAP ES24). Where areas of coral cannot be completely avoided, the coral crossing distance will be minimised and the cable laid on the surface of the coral. Raised turbidity and suspended sediment levels can have a number of adverse effects on marine organisms, particularly in areas that would normally have clear waters. Where suspended sediment concentrations are present for prolonged periods, or are particularly high and widespread, visibility can be reduced affecting the ability of some fish to feed. Gill irritation and respiratory problems can occur in some fish species and benthic organisms/fish eggs can be smothered. Raised turbidity can also reduce light penetration in the water column and reduce photosynthesis/productivity in sea grasses etc. However the duration, spatial extent and level of suspended sediment associated with route clearance and cable installation in this project are unlikely to cause such problems. Nevertheless, turbidity levels should be minimised during cable lay operations by minimising the duration and extent of physical seabed disturbance. This can be achieved using the sea plough burial method in preference to jetting wherever possible (EPAP ES40). Consequently, the impact of turbidity generation is assessed as being of low significance. Other Impacts - Entanglement While there have been historical reports of marine mammals becoming entangled in telecommunication cables, no reports have been made since 1960 [Ref 14]. This is considered to be a result of improved cable laying techniques, including routine (and prompt) burial of the cable in shallower waters and careful management (minimisation) of cable slack thus avoiding coiled cable. These now standard cable laying techniques will be used in this Project and with these mitigation measures in place the potential impact of entanglement of marine species is considered to be low (EPAP ES41). Vessels operations Cable laying will require use of dedicated cable lay vessels resulting in a number of general environmental impacts and risks. During normal operational activities, vessels emit exhaust gases, discharge wastewaters and ballast waters, and generate solid wastes. These
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potential impacts, discussed below, can be effectively managed by the adoption of good shipping practices in accordance with applicable international conventions such as MARPOL 73/78 [Ref 15]. Air Quality Historically ships have typically used lower grade and more polluting fuels. In recognition of air polluting emissions, a number of control measures have been introduced under the MARPOL convention (MARPOL 73/78, Annex VI). These include limits on SO2 and NOx emissions from ship exhausts and the prohibition of ozone depleting substances. More specifically, Annex VI includes a global cap of 4.5% (by mass) on the sulphur content of fuel. In special SOx Emission Control Areas (not applicable to this project) this is further restricted to 1.5 by mass. Other Annex VI requirements prohibit the deliberate emission of ozone depleting halons and hydro-chloroflorocarbons (CFCs). To minimise air emissions the Projects cable laying vessels will operate in line with the requirements specified under MARPOL 73/78 Annex VI, Prevention of air pollution from ships and the IFC EHS Guidelines for Shipping, Section1 [Ref 16]. When mitigated by compliance with MARPOL requirements and the IFC EHS Guidelines for Shipping the impact of vessel operations on air quality is assessed as being of low significance (EPAP ES26). Solid Waste A variety of wastes are typically generated during vessels operations. These wastes include non hazardous wastes (packaging etc.) and hazardous wastes (oily wastes, batteries, paints etc.). Hazardous wastes can clearly have a toxic effect on organisms and can in some circumstances lead to bioaccumulation and ultimately lethal or sub lethal affects if badly managed. In addition, some non hazardous waste types can be equally harmful, particularly non degradable plastics that can remain at sea for many years posing an entanglement risk to sea birds and marine life. Guidance for the management of ship generated wastes is provided in MARPOL 73/78 Annex V, IFC EHS Guidelines for Shipping, Section1 and the IFC General EHS Guidelines, Section 4.1. In summary these require ships operators to develop a waste management procedure that aims to manage wastes by minimising waste generation as far as possible, adopting the waste management hierarchy (the cornerstone principle for waste management whereby in order of preference waste is reduced (waste minimisation), re-used, recycled, used for energy recovery or disposed) and disposing/treating wastes in an environmentally sound manner. Annex V of MARPOL prohibits the disposal to sea of any plastics whilst restricting the discharge of other non hazardous waste in coastal waters and in designated Special Areas. Other specific requirements include:
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development of a Garbage Management Plan and Garbage Record Book for all ships of 400 gross tonnage and above and every ship certified to carry 15 persons or more. Restrictions on the disposal of wastes at sea depending on the nature of the waste and proximity to coastal waters or special areas. For example, disposal of comminuted food wastes is prohibited within 3 miles of land (outside of special areas) and prohibited within 12 miles if non comminuted (inside special areas).
Of note, the Red Sea is categorised as special areas for wastes under Annex V, MARPOL. Hazardous waste should be stored on board the vessel until it can be disposed at a suitably equipped port, respecting the requirements of the Basel Convention on Transboundary Shipment of Hazardous Wastes. When mitigated by compliance with MARPOL requirements, the IFC General EHS Guidelines and the IFC EHS Guidelines for Shipping, the impact of solid waste in vessel operations is assessed as being of low significance (EPAP ES27, ES28 & ES29). Aqueous Discharges (excluding ballast waters) Planned aqueous discharges can include sewage water, grey waters (discharge from showers and sinks) and potentially contaminated drainage from the ship deck. Sewage and grey waters can have high bacteria levels, surfactants and a high Biological Oxygen Demand (BOD5), all which can result in potential human health issues and harm to marine organisms, particularly in sensitive areas or locations with poor mixing and dilution potential. These wastewaters should therefore be managed in accordance with applicable international regulations and guidance, including the requirements of MARPOL 73/78, Annex IV (sewage), IFC EHS Guidelines for Shipping. The provisions in of MARPOL 73/78, Annex IV apply to new ships engaged in international voyages, of 400 gross tonnage and above or which are certified to carry more than 15 persons. Existing ships will also be required to comply with the provisions by 27 September 2008. The Annex requires ships to be equipped with either a sewage treatment plant or a sewage comminuting and disinfecting system or a sewage holding tank. The discharge of sewage into the sea will be prohibited, except when the ship has the sewage treatment facilities indicated above, at a distance of more than three nautical miles from the nearest land; or is discharging sewage which is not comminuted or disinfected at a distance of more than 12 nautical miles from the nearest land. Beyond 12 nautical miles the sea is considered capable of assimilating raw sewage by natural bacteria action and does not need treatment. MARPOL, Annex 1 also addresses discharge of oily waters, for example bilge waters. For ships of 400 gross tonnage and above, for control of oil from machinery spaces, waste water must have an oil concentration below 15ppm without any prior dilution. More specifically:
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Within special areas discharges are prohibited, except when the ship is proceeding en route, and the oil content of the effluent without dilution does not exceed 15 ppm, and the ship has in operation oil filtering equipment with automatic 15 ppm stopping device. The Red Sea and Gulf of Aden are designated special areas under MARPOL Annex 1 and subject to additional conditions. Outside special areas - discharges are prohibited, except when the ship is proceeding en route, the oil content of the processed bilge water (from machinery spaces ) effluent is less than 15 ppm, and the ship has in operation an oil discharge monitoring and control systems, oily-water separating or filtering equipment
When mitigated by compliance with MARPOL requirements and the IFC EHS Guidelines for Shipping the impact of aqueous discharges (excluding ballast waters) in vessel operations is assessed as being of low significance (EPAP ES36). Ballast Waters Management The transfer of marine organisms, resulting in the introduction of harmful aquatic organisms to some waters, is recognised as a major global threat to marine ecosystems. In recognition of this threat the International Convention for the Control and Management of Ships Ballast Waters and Sediments was adopted in 2004. This convention (ratified at the time of preparation of this EP EIA by two landing countries; Kenya and Egypt) will require ships to implement ballast water management procedures. The requirements of this convention vary depending on the age and size of a vessel as detailed in the convention. Annex B of the convention (Management and Control Requirements for Ships), requires that they have a Ballast Water Management Plan and a Ballast Water Record Book to record ballast loading and discharge or exchange. The specific requirements for ballast water management are contained in regulation B-3 Ballast Water Management for Ships, summarized below:
Ships constructed before 2009 with a ballast water capacity of between 1500 and 5000 cubic metres must conduct ballast water management that at least meets the ballast water exchange standards or the ballast water performance standards until 2014, after which time it shall at least meet the ballast water performance standards. Ships constructed before 2009 with a ballast water capacity of less than 1500 or greater than 5000 cubic metres must conduct ballast water management that at least meets the ballast water exchange standards or the ballast water performance standards until 2016, after which time it shall at least meet the ballast water performance standard.
Under Regulation B-4 Ballast Water Exchange, all ships using ballast water exchange should:
whenever possible, conduct ballast water exchange at least 200 nautical miles from the nearest land and in water at least 200 metres in depth, taking into account the guidelines developed by International Maritime Organisation (IMO); and
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in cases where the ship is unable to conduct ballast water exchange as above, this should be as far from the nearest land as possible, and in all cases at least 50 nautical miles from the nearest land and in water at least 200 metres in depth.
When these requirements cannot be met areas may be designated where ships can conduct ballast water exchange. All ships shall remove and dispose of sediments from spaces designated to carry ballast water in accordance with the provisions of the ships' ballast water management plan (Regulation B-4). Similar ballast water management requirements are outlined in IMO Guidelines for the Control and Management of Ships Ballast Water to Minimize the Transfer of Harmful Aquatic Organisms and Pathogens [Ref 17]. When mitigated where required by compliance with the International Convention for the Control and Management of Ships Ballast Waters and Sediments and the IFC EHS Guidelines for Shipping the impact of ballast waters management in vessel operations is assessed as being of low significance (EPAP ES37). Anti-fouling Paints The use of anti fouling paints to coat ships hulls is required to prevent attachment of barnacles and other organisms and thereby avoid significant loss of speed and fuel efficiency. Historically, paints using biocides or metallic compound such as Tributyltin (TBT) have been used. These organotin compounds are designed to slowly leach and kill organisms that attach themselves to the ship. However, such compounds are endocrine disrupters known to be persistent in the aquatic environment and cause adverse affects e.g. deformations in molluscs. When mitigated by compliance with the IFC EHS Guidelines for Shipping and (where required) by compliance with the International Convention on the Control of Harmful Antifouling Systems on Ships the impact of anti-fouling paints in vessel operations is assessed as being of low significance (EPAP ES38). Accidental discharge of oils and hazardous chemicals To reduce the likelihood of accidental release of hazardous materials, a hazardous material management program will be established. This will include secondary containment, training, provision of personal protective equipment and spill response measures. In unplanned circumstances accidents can result in environmental and/or human harm. The most prominent includes the release of toxic chemicals or oil into the marine environment. Regulation 26 of Annex I of MARPOL 73/78 requires that oil tankers of 150 tons gross tonnage or more and all ships of 400 tons gross tonnage or more carry an approved Shipboard Oil Pollution Emergency Plan (SOPEP).
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The SOPEP shall consist at least of:

the procedure to be followed by the master or other persons having charge of the ship to report an oil pollution incident the list of authorities or persons to be contacted in the event of an oil pollution incident; a detailed description of the action to be taken immediately by persons on board to reduce or control the discharge of oil following the incident; and the procedures and point of contact on the ship for co-ordinating shipboard action with national and local authorities in combating the pollution.
The IFC EHS Guidelines for Shipping and the International Convention on Oil Pollution Preparedness, Response and Co-operation, 1990, also require such a plan for certain ships. When managed where required by compliance with the MARPOL requirements, the International Convention on Oil Pollution Preparedness, Response and Co-operation, and the IFC EHS Guidelines for Shipping, the risk of accidental discharge of oils and hazardous chemicals in vessel operations is acceptable (EPAP ES28, ES30 & ES33). ENVIRONMENTAL IMPACTS (ONSHORE) At each landing location there will be a small amount of construction work and environmental impact associated with the cable installation and construction of the onshore facilities. Much of this impact will be typical of general construction activity, resulting in short term waste generation, nuisance impacts and some disruption to local communities. Cable Laying (habitat alteration, soil erosion and management) Cable laying and associated trenching will cause some environmental harm. To help reduce the magnitude of this harm, the cable route has been selected such that it:

uses existing utility corridors uses previously disturbed areas avoids sensitive areas (including steep slopes, watercourses, sites of archaeological or cultural value, protected areas) minimizes the onshore cable length
In previously undisturbed sections of the onshore route the cable installation will result in physical disturbance of the soil structure and loss of vegetation that lies directly above it. The extent of loss of vegetative cover will be minimal and given the narrow width of the trench natural re-vegetation is expected. However, in order to promote natural revegetation the soil structure should be maintained, and in particular where feasible, top soil will be segregated during trench excavation and replaced on the surface during backfill. In most cases the vegetation will then recover naturally.
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To prevent habitat alteration a number of mitigating measures, in addition to careful route selection, have already been adopted, including:

Revegetation of disturbed areas with native plant species. Management of construction site activities as described in relevant sections of the IFC General EHS Guidelines. Reinstatement of trench material. Where possible and appropriate, top soil will be segregated and replaced on other back fill material to promote regeneration of vegetation.
In areas where vegetative cover is removed, soil erosion (usually during periods of heavy rainfall) can result in the loss of valuable top soil and siltation of nearby watercourses. Soil erosion will be avoided using a number of additional mitigation measures as appropriate.

Scheduling to avoid heavy rainfall periods (to the extent practical) Mulching to stabilise exposed areas Revegetating areas promptly Reducing or preventing off-site sediment transport through use of settlement ponds, silt fences, etc and modifying or suspending activities during extreme rainfall and high winds to the extent practical. Segregating or diverting clean water runoff to prevent it mixing with water containing a high solids content.
When mitigated as indicated above, the impact of onshore construction activities on habitat alteration is assessed as being of low significance (EPAP ES2, ES3, ES4, ES14 & ES15). Waste Construction wastes will be generated during onshore construction. Overall these are expected to be relatively small quantities although they may include some hazardous waste (oily rags, spent fuel cans, batteries etc.). Sound waste management is required to avoid the risk of harm to the environment and human health. These measures include:
Establishing waste management priorities at the outset of activities based on an understanding of potential Environmental, Health, and Safety (EHS) risks and impacts and considering waste generation and its consequences Establishing a waste management hierarchy that considers prevention, reduction, reuse, recovery, recycling, removal and finally disposal of wastes. Avoiding or minimizing the generation waste materials, as far as practicable Where waste generation cannot be avoided but has been minimized, recovering and reusing waste Where waste can not be recovered or reused, treating, destroying, and disposing of it in an environmentally sound manner
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Hazardous waste generation will be minimised by implementing stringent waste segregation to prevent the commingling of non- hazardous and hazardous waste to be managed. Waste contractors handling, treating, and disposing of hazardous waste will be reputable and legitimate enterprises, licensed by the relevant regulatory agencies and following good international industry practice for the waste being handled. Waste management practices will be in compliance with applicable local and international regulations (including Basel Convention on the Control of Transboundary Movements of Hazardous Waste and their Disposal). Hazardous waste will be stored so as to prevent or control accidental releases to air, soil, and water resources in locations where:
Waste is stored in a manner that prevents the commingling or contact between incompatible wastes, and allows for inspection between containers to monitor leaks or spills. Examples include sufficient space between incompatibles or physical separation such as walls or containment curbs. Store in closed containers away from direct sunlight, wind and rain. Secondary containment systems should be constructed with materials appropriate for the wastes being contained and adequate to prevent loss to the environment Secondary containment is included wherever liquid wastes are stored in volumes greater than 220 litres. The available volume of secondary containment should be at least 110 percent of the largest storage container, or 25 percent of the total storage capacity (whichever is greater), in that specific location. Provide adequate ventilation where volatile wastes are stored. Provision of spill containment and clean-up equipment (see hazardous materials below). Waste management practices should be monitored through regular audit of waste segregation and collection practices.
When mitigated as indicated above, and in accordance with the relevant provisions of the IFC General EHS Guidelines, the impact of onshore waste management activities is assessed as being of low significance (EPAP ES7, ES8 & ES9). Noise Construction activities will result in some noisy activities, including noise from vehicle movement/operation, generators, cutting and grinding, use of pneumatic drills etc. The level of impact is dependent on both the sound pressure of each noisy activity and the proximity of noise sensitive receptors, including humans and breeding/nesting wildlife. Noise control measures will include:
Use of noise suppression shields and mufflers.
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Location of noise generating sources away from residential or other noise-sensitive receptors. Compliance with noise emission levels provided in IFC General EHS Guidelines, Plan activities in consultation with local communities so that activities with the greatest potential to generate noise are planned during periods of the day that will result in least disturbance. Avoid or minimise project transportation through community areas.
Noise will also be reduced by minimising construction duration. For instance, the use of pre fabricated containerised cable stations in most locations will have a favourable effect on the duration of noise generating activities. When mitigated as indicated above, and in accordance with the relevant provisions of the IFC General EHS Guidelines and the EHS Guidelines for Telecommunications, noise impacts are assessed as being of low significance (EPAP ES5). Dust Dust is a nuisance impact that typically occurs during excavation and transportation works where construction plant and vehicles are operating in dry non paved areas. Dust suppression techniques, such as increasing the moisture content of excavated materials and roadways by applying water or non toxic chemicals, can be used to reduce the amount of dust in the air, particularly where construction activities are taking place in close proximity to dust sensitive receptors e.g. residential/commercial areas. Other dust management measures include speed restrictions on dust generating vehicles. Impacts from dust are expected to be restricted to small areas over a short timescale. They will be managed in accordance with the mitigation measures set out in the IFC General EHS Guidelines and are therefore assessed to be of low significance (EPAP ES6). Air Quality The local air quality in the close proximity of onshore construction activities will be affected by emissions from mobile (e.g. construction vehicles) and stationary machinery (e.g. portable generators). Emissions from these sources will be managed in accordance with the provisions of the applicable IFC EHS Guidelines (General and Telecommunications). Typical provisions are as follows:

Emissions should not result in pollutant concentrations that reach or exceed relevant ambient quality guidelines and standards by applying national legislated standards Emissions from on-road and off-road vehicles should comply with national or regional programs. In the absence of these regardless of the size or type of vehicle, operators should implement the manufacturer recommended engine maintenance programs
When mitigated as indicated above, and in accordance with the relevant provisions of the IFC General EHS Guidelines and the EHS Guidelines for Telecommunications, air quality impacts are assessed as being of low significance (EPAP ES6).
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Visual / Landscape The onshore facilities will either be buried in the case of beach man holes or small scale i.e. containerised cable stations and therefore little visual impact is envisaged. Nevertheless, efforts will be made to minimise visual impacts, particularly where a Cable Station is to be located in or close to either a scenic area or place of cultural importance. Specific mitigation measures include:

Use of existing facilities (beach man holes and Cable Station buildings) where possible. Sympathetic siting of cable stations. Appropriately coloured containers/building materials and architecture that is selected to blend in with the surrounding environment. Land disturbed by cable laying will be contoured to its original form as part of overall reinstatement.
When mitigated as indicated above, visual (or landscape) impacts are assessed as being of low significance (EPAP ES13). Cultural / Heritage Sites Routing and site selection studies have resulted in the avoidance of direct Project impacts to sites with significant cultural or heritage value. Where necessary (as in the landfall at Mombasa, Kenya), site-specific surveys have been undertaken to determine appropriate mitigation measures and to confirm the acceptability of cable routes and Cable Station sites . When mitigated in this way, cultural/heritage impacts are assessed as being of low significance (EPAP ES13). Hazardous materials Hazardous materials, including paints and fuels will be used in limited quantities during construction. Depending on their nature, poor management of hazardous materials can result in loss of hazardous substances to land and/or waterbodies, land and groundwater contamination or in the case of flammables, fire and injury. Thus good management practices will be used including:
Provision of adequate secondary containment for fuel storage tanks and for the temporary storage of other fluids such as lubricating oils and hydraulic fluids, using impervious surfaces for refuelling areas and other fluid transfer areas. Training workers on the correct transfer and handling of fuels and chemicals and the response to spills. Providing portable spill containment and cleanup equipment on site and training in the equipment deployment. Provision of suitable personal protection equipment. Secure storage and appropriate signage, accompanied with accessible MSDSs.
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When mitigated as indicated above, and in accordance with the relevant provisions of the IFC General EHS Guidelines, impacts due to hazardous materials are assessed to be of low significance (EPAP ES10 & ES11). Wastewater The construction activities will not lead to any significant wastewater effluents, but there will be a need to provide adequate portable or permanent sanitation facilities to all workers at all construction sites. These facilities should be managed in accordance with the IFC General EHS Guidelines which require:

Adequate portable or permanent sanitation facilities serving all workers should be provided at all construction sites. Segregation of wastewater streams to ensure compatibility with selected treatment option (e.g. septic system which can only accept domestic sewage)
When mitigated as indicated above, and in accordance with the relevant provisions of the IFC General EHS Guidelines, impacts due to wastewater are assessed to be of low significance (EPAP ES12). Traffic A small amount of construction traffic will be used during construction activities. This will result in a small increase in the number of slow moving vehicles travelling to and from the site and some inconvenience to other roads users. However, such cases will be infrequent and any inconvenience will be slight and the potential impacts are considered to be of low significance.
SOCIAL IMPACTS Labour Issues All project contractors will comply with the relevant requirements of IFC Performance Standard 2 Labor and Working Conditions, to ensure consistency with the four core labour standards (concerning the use of child labour, forced labour, non-discrimination and freedom of association and collective bargaining). Other areas addressed in PS2 include working conditions and terms of employment, retrenchment, and occupational health and safety issues. Impacts associated with labour issues will be of low significance when subject to compliance with IFC PS2 Labor and Working Conditions (EPAP ES17). Economic Displacement Economic displacement (loss of assets or access to assets that leads to loss of income sources or means of livelihood) will be mitigated in accordance with the provisions of IFC Performance Standard 5 Land Acquisition and Involuntary Resettlement which requires that
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compensation be calculated at market value plus the transaction costs related to restoring the assets. Compensation will result in impacted persons or communities having improved (or at least restored) standards of livings or livelihoods. Standards of compensation will be transparent and consistent within the Project. Economic displacement, if it occurs at all, is likely to be short term in nature and associated with construction activities. It could arise as a result of temporary alienation of fishing grounds during construction activities. All compensation processes will be compliant with the requirements of PS5, and therefore impacts due to economic displacement will be mitigated and are assessed to be of low significance (EPAP ES18, ES44 & ES45). Community Health The influx of a large migrant workforce is recognised to have significant impacts on community health. However, this project will involve a small workforce which will be in place over a short duration. Given the small number of workers and the limited interaction with the community, the risks of significant deterioration of community health is small. Nevertheless, some basic measures are required including:

good site management (security, waste management, storage of hazardous materials) implementation of traffic safety measures communication of risks to the community, and disease prevention measures, including medical fitness checks and immunisation.
Impacts to community health will be of low significance when mitigated as above (EPAP ES1, ES9, ES20, ES21, ES22, ES25, ES47 & ES48). Social Development SEACOM is supporting the African university and research community by providing very attractive capacity on SEACOM.

SEACOM is providing 40 universities, education and research institutions in South Africa with 50 times more bandwidth at the same price currently being paid annually After six years, the institutions will own the capacity for the remaining life of the SEACOM system, resulting in annual savings to the institutions The bandwidth that the institutions will enjoy, is almost equal to that currently available to the entire South African population South African universities can offer distance learning classes to students at universities in neighbouring countries. SEACOM has extended the below cost bandwidth offer to an alliance of Southern and Eastern African Universities called uBhuntuNet. Distance Learning Initiatives will allow virtual classrooms between Africa, Europe and India.
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SEACOMs social development initiative is a positive impact of the Project.
5.3.3 Operations
Following cable installation routine maintenance will be negligible during the 25 year design life of the Project. Unplanned repairs to the system may be required. The cable can be damaged by natural events including submarine land slips, abrasion and by human interference, most commonly fishing nets and ships anchors. These latter incidents not only have the potential to damage the cable but also present a significant risk to those ships involved, particular fishing vessels that can be damaged or lost if their gear becomes entangled with a sub marine cable. The most significant hazard is fishing activity, which by its nature covers a wide area of the seabed. Research indicates that fishing activity accounts for about 40% of all cable faults [Ref 18] with the next most significant hazard being anchoring, which accounts for about 18% of faults in all water depths, but is most significant in water depths of less than 50m. Fault rates in cable systems fell dramatically when widespread burial of cables was adopted in the 1980s. Prior to burial of cables, fault rates were around 5 faults per 1000km per annum. However, as cable systems were increasingly buried, fault rates have fallen to an average of less than 1 per 1000km per year Similar figures are provided by the International Cable Protection Committee [Ref 14] which estimates 70% of all faults are from fishing and anchoring and 10 % result from natural hazards. The majority occur in water depths of less than 200m as a result of human activity. In depths >1000m, the main causes are natural. The most environmentally significant activity during operations will be offshore cable repair in which the cable must be located with a grapnel, recovered to a repair vessel on the surface, spliced with new cable and returned to the seabed and in some circumstances reburied. The environmental impacts are discussed in the paragraph below. ENVIRONMENTAL IMPACTS Operational Cable (normal operating conditions) The cable is manufactured using non toxic and stable materials and therefore will not cause acute or chronic affects on the marine/terrestrial environment. Furthermore, the cable is of sufficiently small diameter (approximating to that of a garden hose over most of the system) that its footprint is negligible once in place. Notably there are also documented examples where the cable actually provides habitat in marine environments for opportunistic species. For example, there is evidence to demonstrate that cables laid on the seabed typically show substantial growth of algae and other marine organisms which use the cable as hard substrate. In shallow areas of high current velocity, there have been some reports of lateral motion of the cable across the seabed in a swath on the order of 0.5 m [Ref 19 and 20]. Such motion
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can only occur where the cable is not buried, and is mitigated by the use of heavier, larger diameter armoured cable. Any sections of shallow, surface-laid cable will be armoured to provide protection against accidental damage, and this use of heavier cable will also reduce the potential for lateral movement. With the application of the mitigation measures noted above any environmental impacts of the cable in normal operating conditions are assessed to be either low (negative impact), or beneficial (EPAP ES23, ES32, ES33, ES34 & ES35). Electromagnetic fields Electrical current is carried by the cable when repeaters are required. This current does not carry communications, but rather provides power for repeaters/amplifiers spaced along the cable to boost the optical communications signals carried by glass, or in exceptional circumstances when locating a fault. There is a weak radial direct current (DC) electric field very near the cable, and a circumferential DC magnetic field surrounding the cable, the intensity of which varies inversely with distance from the cable. The SEACOM cable will not generate alternating current (AC) radiation when in service under normal conditions, however, if an electroding signal is being applied to a cable for fault location purposes, a low level AC signal is generated into the sea water with frequency in the range of 15 to 25 Hertz (Hz). There are a number of theories that suggest cable induced electromagnetic fields can result in behavioural changes in marine life, notably in sharks and rays. More specifically there have been small number of cases of sharks biting cables down to a depth of 1900m, for example, four shark bite induced cable failures on the OPTICAN I cable close to the Canary Islands between 1985 and 1987. Some theories suggest that the magnetic field produced by the DC current exceeds the sharks detection threshold and the shark attacks (when in very close proximity to the cable) because it misinterprets the electrical field disturbances as prey). [Ref 21]. It is thought that the shark response occurs only when the shark is in very close proximity to the cable, the deep water suggesting the attacks take place in darkness. The risks posed to the cable system have been recognised by cable operators and cable designs have since been modified to protect against shark bites. The World Health Organisation has considered the effects on EMF on marine life. It concludes that although all organisms are exposed to the geomagnetic field, marine animals are also exposed to natural electric fields caused by sea currents moving through the geomagnetic field. Electrosensitive fish, such as sharks and rays in oceans, can orient themselves in response to very low electric fields by means of electroreceptive organs. It acknowledges that some investigators have suggested that human-made EMF from undersea power cables could interfere with the prey sensing or navigational abilities of these animals in the immediate vicinity of the sea cables. However, none of the studies performed up to 2005, to assess the impact of undersea cables on migratory fish (e.g. salmon and eels) and all the relatively immobile fauna inhabiting the sea floor (e.g. molluscs), have found any substantial behavioural or biological impact [Ref 22]. The potential impact to marine life from electromagnetic fields is considered to be low.
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Cable Induced Temperature Increases Submarine cables show negligible temperature increase when powered. The heat dissipation is less than one watt per kilometre of cable length [Ref 23] and thus impacts from cable heat dissipation are considered to be low. Exposed cables Cables can become exposed on beaches and in other areas prone to erosion. In addition to the unsightly nature of an exposed cable at low tide, it represents a safety risk to beach users and also substantially increases the risk of cable failure. For beach crossings the cable is typically installed in flexible steel pipe with an outside diameter in the order of 20 cm and buried in a trench 2 m deep dug previously by equipment such as a backhoe. Shore crossings are preferentially located where beach profiles are stable or subject to relatively small variations, and are designed to minimise the risk of exposure. In the unlikely event of severe erosion resulting in the pipe becoming exposed it will be reburied. Similar exposure can occur in the inter tidal zone where the cable crosses hard substrate, as is the case for existing cables crossing a wave cut platform at the Kenya landing location. To avoid exposure and lateral movement of cables in such hard substrate intertidal environments the cable will be laid and sealed into a trench excavated into the hard substrate. An inert backfill material such as concrete will be used, with excavated materials reinstated on the surface of the trench to ensure that it is not visually intrusive. With the application of mitigation measures the potential for unintended exposure of the cable during operations is considered to be minimal and therefore the impact of exposed cables is assessed to be low (EPAP ES34 & ES35). Cable Repair Where a cable fails it will be repaired as a matter of urgency in order to minimise the interruption to communication services. Should communications via the cable be subject to an unplanned interruption the location of the fault will be determined by transmitting a special signal through the power element of the cable. The behaviour of this signal will allow the cable operations staff to localise the fault. If the cable fault is found to be land based the cable will be recovered and the damaged section repaired or replaced in much the same manner as is the case for normal buried utility services. This will involve excavation and subsequent remediation work similar to that described in Section 5.2.2 (Construction impacts). For submarine cable faults the cable will be located, recovered with a grapnel hook (unless in a coral reef when divers will be used), repaired and then returned to the seabed. This process involves a specialist cable repair vessel and seabed disturbance associated with recovery and possible re burial. The impacts and mitigation measures identified in Section 5.2.2. (Construction impacts) will apply.
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Potential impacts due to cable repair activities during Project operations will be mitigated in the same way as construction impacts, and are therefore assessed as being of low significance (EPAP ES39 & ES42). Exclusion Zones Exclusion zones are typically designated to protect cables from accidental interference by seafarers. These restrictions can have a negative impact on commercial activities such as fishing. Should compensation be required in respect of exclusion zones, the compensation process will be compliant with the requirements of PS5, and therefore impacts due to exclusion zones will be mitigated and are assessed to be of low significance (EPAP ES18). SOCIAL IMPACTS The three categories of social impacts identified in respect of Project construction (labour issues, economic displacement and social development) are also applicable during Project operations. Efforts will be made to maximise direct and secondary employment opportunities. Impacts associated with labour issues will be of low significance when subject to compliance with IFC PS2 Labor and Working Conditions (EPAP ES17 & ES19). Economic displacement could occur during operations, leading to a requirement for compensation. All compensation processes will be compliant with the requirements of IFC PS5 Land Acquisition and Involuntary Resettlement, and therefore impacts due to economic displacement will be mitigated and are assessed to be of low significance (EPAP ES18). SEACOMs social development initiative will continue during the operations phase and is a positive impact of the Project.
5.3.4 Decommissioning
At the end of its operational life the SEACOM Cable System will be decommissioned in accordance with applicable industry practice and legislative requirements at that time. Current practice (in 2008) is to abandon the cable in situ, and to properly dispose of Cable Station equipment, leaving the Cable Station infrastructure available for re-use. Future options may include recycling some or all of the cable in some circumstances, but for buried cable, abandonment in-situ is expected to remain the best environmental option. ENVIRONMENTAL IMPACTS (OFFSHORE) The following section describes potential impacts and current best practice guidance issued by the International Cable Protection Commission [Ref 24]. It also acknowledges that such practice can change over time.
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The decommissioning strategy for the cable will be influenced by a number of factors that will result in a decision to either recover the cable or abandon it in-situ. These factors include technical, environmental, economic and safety considerations all of which may change over the cables lifespan. For example:

the ecological value of the cable route can change, either as perceptions change or in real terms due to habitat change or loss of similar habitat elsewhere; legislative requirements imposed by international/national laws may evolve; the cable may represent a hazard to the public, other commercial users and marine biota if the cable becomes exposed and/or damaged; the commercial/environmental incentives to recycle the cable may increase/decrease.
In many cases the influence of these factors will differ from section to section along the length of the cable and some sections could be recovered whilst others are left in-situ. Taken in conjunction with the need for compliance with applicable national laws and regulations, the decommissioning requirements will be determined on a country-by-country (and section by section) basis taking account of the drivers/opportunities present at that time of decommissioning. As part of the overall decommissioning plan the benefits of removal will be balanced against the disadvantages. In some cases there will be clear disadvantages with removal, for example, where cable has resulted in enhanced habitat by providing a hard substrate for immobile biota, or the cable is laid over a coral reef and becomes encapsulated. In other cases the needs of other marine/terrestrial users, notably the fishing industry but also recreational boats (anchor fouling) and divers (injury from damaged and/or corroded cable) in shallow waters must also be assessed. In these circumstances, providing there are no overriding sensitivities, a decision to recover is likely. The ICPC recommends that if the decision is to retain a redundant cable for future use or to leave an out-of-service cable in place, cable owners should consider implementation of the following:

Notification to International & National charting authorities that the cable is no longer in service. Notification to local fishermen and other seabed users of the change in status, and confirmation that any future claims for sacrificed gear will be considered on their merits. Confirmation that the cable owner remains responsible to any party by insurance cover or otherwise for the OOS Cable. Consideration of alternative uses for the cable such as donation to a scientific research body.
Cable Liability There is no legal requirement to recover out of service cable although a coastal nation can require removal of an out of-service cable within its territorial waters. However, any cable or
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component parts of cables or recovery works left on the seabed after a cable is decommissioned remains the property of, and liability of the cable owner [Ref 25]. This includes cable which can not be recovered because it is beneath another active cable or pipeline, and liability remains with the original cable owner unless ownership is legally transferred. Disposal of recovered cable In instances where the cable is recovered it must be disposed of in accordance with good waste management practices, typically involving the recycling of cable components. For those components that can not be recycled, sound waste disposal practices must be applied. Cables should be designed using materials that maximise the recycling potential of the cables constituent parts at the end of its operational life. Any cable that is not recovered should have its ends weighted and buried in the seabed to reduce the likelihood of snagging with fishing nets and the associated risk to fishing vessels. [Ref 24] Potential impacts due to offshore cable decommissioning will depend on the decommissioning methods used at the time of decommissioning. However, provided the cable is decommissioned responsibly the potential impacts will be les significant than those from cable installation and therefore can be conservatively predicted as being of low significance (EPAP ES43).
ENVIRONMENTAL IMPACTS (ONSHORE) It is normal industry practice to leave redundant cable in-situ. The alternative would require recovery and recycling of the cable; however the benefits from recovery of short lengths of terrestrial cable are unlikely to justify the earthworks/disruption and potential impacts associated with recovery. Potential impacts due to onshore cable decommissioning will depend on the decommissioning methods used at the time of decommissioning. However, provided the cable is decommissioned responsibly the potential impacts will be less significant than those from cable installation and therefore can be conservatively predicted as being of low significance (EPAP ES16).
SOCIAL IMPACTS The social impacts associated with decommissioning will vary depending upon the strategy adopted at the end of the cables life but in any event are expected to be minimal. Should recovery of some sections of cable be required this will lead to some minor disruption during actual recovery operations, although this would be of short duration and minor in scale. Employment opportunities created by the project would be lost, but would be expected to be balanced against jobs generated by the communications systems replacing the SEACOM System. The overall positive impact of cable related job creation throughout the life of the project would outweigh any overall loss of employment opportunities, should this occur.
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Impacts resulting from the eventual decommissioning of the SEACOM Project will be managed by adherence to regulatory requirements and industry good practice applicable at the time, so that the mitigated impacts will be of low significance (EPAP ES19). The tables below provide an over summary of the potential impacts from the Project after implementation of the mitigation measures/controls outlined in this section.
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Table 7 Potential environmental impacts post mitigation

Decommissioning (Offshore) Decommissioning (onshore) Cable installation (onshore) Cable installation including PLIB (excl. vessels) Desk top survey (including site selection visits) Marine route survey (excl. vessels) Vessels (all applications) Operations/maintenance Operations/maintenance
P to
Activity
Aspect
Environmental Air quality (local) Water quality Marine ecology Terrestrial ecology Noise Dust Waste Cultural/heritage Traffic Visual/landscape P
Onshore -
Route clearance (excl. vessels)
Onshore construction (BMH/Cable )station)
Offshore -
Positive Negligible/no discernable impact Low Moderate
High
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Table 8 Potential social impacts post mitigation

Decommissioning (Offshore) Decommissioning (onshore) Onshore construction (Cable/BMH/Cable station) Desk top survey (including site selection visits) Vessels (all applications) Operations/maintenance Operations/maintenance -
Activity
Aspect Environmental Local labour conditions Community Health Local employment Economic displacement (fishing/other activities) Physical displacement Impacts to indigenous people P
Onshore to P to P to P -
Offshore construction
Offshore -
Positive Negligible/no discernable impact Low Moderate
High
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Occupational Health and Safety
The consideration of Occupational Health and Safety of workers is required for this Project under Performance Standard 2, Labour and Working Conditions which in turn is guided by a number of International Labour Organisation (ILO) and United Nations (UN) conventions.
Paragraph 16 of Performance Standard 2 states that The client will provide the workers with a safe and healthy work environment, taking into account inherent risks in its particular sector and specific classes of hazards in the clients work areas , including physical, chemical, biological, and radiological hazards. The client will take steps to prevent accidents, injury, and disease arising from, associated with, or occurring in the course of work by minimizing, so far as reasonably practicable, the causes of hazards. In a manner consistent with good international industry practice, the client will address areas, including: the identification of potential hazards to workers, particularly those that may be life-threatening; provision of preventive and protective measures, including modification, substitution, or elimination of hazardous conditions or substances; training of workers; documentation and reporting of occupational accidents, diseases, and incidents; and emergency prevention, preparedness and response arrangements.
The hazards posed to workers health and safety in this Project will be mainly associated with the construction phase. Hazards result from trenching activities (including exposure to existing live cables) and working with fibre optic cables which are specific to telecommunications. There will also be general onshore construction hazards and a number of vessel related hazards.
6.1
Telecommunications
Occupational health and safety hazards specific to the telecommunications industry and this Project include electrical safety and optical fibre safety. The former hazard can occur where workers encounter live wires during construction (trenching) or maintenance. For the later, workers risk permanent eye damage if exposed to laser light during cable inspection and maintenance e.g. during the use of microscope to inspect cable ends. Guidance on the management of these hazards is provided in the IFC EHS Guidelines Telecommunications, April 2007.
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6.2
Safety in General Construction
The types of activity/hazard in this project include:

Moving machinery/vehicles Lifting (over exertion) Trenching/earthworks Falling objects (where buildings will be constructed) Use of hazard materials (limited use anticipated) Working in confined spaces
Guidance on the management of these hazards is provided in the IFC EHS General Guidelines, April 2007
6.3
Vessel related hazards
Working at sea presents a number of unique risks, including the confined nature of vessel spaces, movement of vessels (exacerbating slips and trips), overboard deployment of equipment and emergency situations such as on-board fire. There are further unique hazards when divers are used. As a general safety measures ships should be managed in accordance with the International Safety Management Code, specified under the Safety of Life at Sea (SOLAS) Convention. This requires a Safety Management System that identifies roles and responsibilities, available resources and emergency procedures. Seafarers should be adequately trained to fulfil their roles and responsibilities and provided with appropriate safety equipment, for example, slip resistant footwear. The vessels themselves should comply with internationally applicable requirements for life safety (lifeboats, life jackets etc) specified by the International Life Safety Appliance Code and fire safety in accordance with the International Fire Safety Systems Code. To ensure ships are maintained and managed in a manner that provides a safe environment for crew and potentially affected communities, vessel operations should comply with:
the provision of accommodation and working spaces in line with SOLAS, 1974, the Maritime Labour Convention 2006 and International Labour Organisation, Accident Prevention on Board Ship at Sea and in Port, 1996. Management of ships operations should be in accordance with the International Safety Management Code (under SOLAS), including the preparation of a formal Safety Management System. Seafarers should be trained to manage the types of hazards applicable to their assigned duties, in accordance with the International Convention on Standards of Training, Certification and Watchkeeping for Seafarers, 1978.
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Fire safety should be managed in line with the International Fire Safety Systems Code as required by SOLAS International Life Safety Appliance Code as required by the SOLAS convention.
If divers are used they must be have appropriate internationally recognised commercial diver qualifications. These hazards should be managed by a combination of appropriate training, good signage and housekeeping, protective equipment, safety and emergency procedures. Specific actions and mitigations measures for the management of health and safety hazards outlined above are detailed in the Action Plan.
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Cumulative Impacts
While the summary of impacts presented in Tables 7 and 8 illustrates that, post mitigation, any negative impacts of the SEACOM Cable System Project will be of low significance, IFC Performance Standard 1 Social and Environmental Assessment and Management Systems requires that these impacts also be considered in conjunction with impacts from further planned development of the project, any existing project or condition, and other projectrelated developments that are realistically defined at the time the Social and Environmental Assessment is undertaken in a cumulative impact assessment.
The area of influence does not include potential impacts that would occur without the project or independently of the project. The Performance Standard also indicates that the client is expected to address risks and impacts commensurate to the clients control and influence over third party actions. With reference to the above requirements it should be recognised that there is no further planned development of the Project beyond that described in the Project description. The Project will stimulate economic growth within the project area and other locations, however these can not be predicted and are therefore excluded from this assessment of cumulative impacts. In terms of other planned projects, the EASSy cable project is similar in nature to the SEACOM cable system, landing at some of the SEACOM landing locations and sharing infrastructure and cable corridors. Thus, for the purposes of this assessment cumulative impacts are limited to those: 1. associated with existing projects and conditions, and 2. impacts from the EASSy project where the cable routes coincide. These are further discussed below.
7.1
Cumulative Impacts existing projects and conditions
Section 5 highlights the type and severity of impacts that might result from the project. Of those identified the following result in incremental impacts:

loss of trawl fishing ground - in circumstances where an exclusion zone is declared around the cable, and is additional to one or more zones for other cables emissions and discharges project impacts are small and therefore cumulative impacts are minimal
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These risks/impacts when addressed in isolation are all categorised as low in chapter 5. Consequently the incremental impact for each is also low. The one exception requiring further discussion is the cumulative impact on trawl fishing grounds, where the cable will be protected from third party interference by an exclusion zone in which fishing activities and other recreational/commercial activities will be prohibited. Where present, the exclusion zone will vary from country to country and will remain in force for the duration of the cable operating life. Where possible the cable route has been selected to coincide with existing cables and therefore existing exclusion zones. Using this approach the additional exclusion area is reduced, however, the operational need to separate the cables will in most cases result in an expansion of the exclusion zone. Exclusion zones are planned in respect of the landings in South Africa and Djibouti. As trawl fishing is prohibited throughout Djibouti waters, any cumulative impact is restricted to the Project in South Africa. Should compensation be required in respect of exclusion zones, it will be compliant with the requirements of PS5, and therefore cumulative impacts due to exclusion zones will be mitigated and are assessed to be of low significance.
7.2
Cumulative Impacts future projects
The East African Submarine Cable System (EASSy) is an initiative to construct and operate a submarine fibre optic cable along the east coast of Africa to connect eight coastal countries and island nations to each other and to the rest of the world. The route will be from South Africa to Sudan, covering about 8,500 km, and connecting South Africa, Mozambique, Madagascar, Tanzania, Kenya, Somalia, Djibouti and Sudan. The EASSy cable is scheduled to be operational in 2010. Due to the similar nature of the two projects, and because the two cable routes are similar in places, cumulative impacts will occur. However, the impacts of the EASSy project are also expected to be similar to those from SEACOM, both in terms of their nature and their low significance. Consequently, most do not require further discussion. The only cumulative issue of any significance will be the further increase in cable exclusion zone in the coastal waters of South Africa. This incremental loss of access will persist over the duration of the projects although as with the cumulative impact of the SEACOM Project with the existing cable system (see section 7.1) this loss of resource is expected to be small in comparison to the total available area for trawl fishing activities.
Given the relatively limited area of restricted access, the cumulative significance of the exclusion zone for the SEACOM Project with other exclusion zones (existing and planned) in South African waters is considered to be low.
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Transboundary Impacts
The major positive benefit of the Project in respect of improved transboundary communications The movement of wastes collected at sea Transfer of harmful aquatic organisms in ships ballast waters and ballast sediments.
Transboundary impacts associated with this project are limited to those associated with:
The latter two items are addressed within Chapter 5 (Social and Environmental Impacts and Mitigation Measures). In addition to ships waste generated at sea, waste including potentially hazardous waste, may also be collected by grapnel during route clearance. This waste might be transported across maritime boundaries before disposal. However, the volumes of waste are typically small and provided the waste is disposed of in an environmentally sound manner in line with the requirements of MARPOL, Annex V and the Basel Convention on Transboundary Shipment of Hazardous Wastes (to the extent it applies), the transboundary impact of waste is expected to have low significance. The transboundary transfer of harmful aquatic organisms presents a significant threat to marine ecosystems. This issue is discussed in Chapter 5, Ballast Waters Management, where appropriate mitigation measures are detailed. When mitigated by compliance with the International Convention for the Control and Management of Ships Ballast Waters and Sediments and EHS Guidelines for Shipping the impact from the transboundary transfer of harmful aquatic organisms by the Projects vessel is assessed as being of low significance.
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Analysis of Alternatives
The analysis of alternatives is a fundamental component of the ESIA process. Its purpose is to improve project design, construction and operation decisions based on feasible project alternatives. Early consideration of alternatives during the design phase of a project can result in the avoidance/minimisation of impacts without the need for expensive or time consuming mitigation measures at a later stage. Alternatives can be applied at the macro scale and micro scale; the later should be considered throughout the assessment process. For example, at a macro scale, is a submarine fibre optic cable the best technology to use, and at the micro scale, would deviations from an initial route selection reduce potential impacts.
9.1
Analysis of Alternatives available technologies
The goal of the Project is to provide affordable long distance telecommunications to east Africa. Currently only a small number of modern technologies are available that can meet this goal, namely satellite systems and fibre optic cable systems. In the past satellite systems were the preferred technology for long distance communications, and this still remains the case for many of the countries that will be served by the SEACOM cable system. However, satellite systems remain slow (resulting in the characteristic delay on a telephone line) and unreliable compared to fibre optic cables, making fibre optic cables the preferred technology. Fibre optic cables can be laid in both terrestrial and marine environments, and in both cases some detrimental impacts can occur depending on the route selection. For this Project a marine component is required if India it to be served, supporting the use of a marine system. Furthermore terrestrial cables have been found to have greater installation costs, be less reliable and be prone to malicious and accidental third party interference. On this basis, a well managed marine submarine fibre optic cable system offers the most appropriate approach.
9.2
Analysis of Alternatives route selection
The cable has a small diameter and is designed to be benign in the marine environment. Nevertheless some impacts are likely including:

Disruption to recreational activities Disruption/loss of income to fishing communities Construction related nuisance (noise, dust, exclusion areas) Impact to flora and fauna Environmental and health risks (fuel spills, vessel capsize etc)
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Most of these impacts are addressed through mitigation measures (Section 5). The impact of others, most notably exclusion areas where fishing and anchoring activity is prohibited, can be minimised if existing corridors (with existing exclusion areas) are used. During the early stages of Project design an extensive desk top study was undertaken to identify a preferred route. Throughout this study environmental issues were considered and potential impacts minimised through selection of the best route. For example, at each landing country a number of landing locations, facility locations and approach routes were considered. The general philosophy included:

Avoidance of environmental sensitivities; Use of existing onshore facilities where possible; Installation of pre fabricated facilities where exiting facilities were unavailable; and Use of existing corridors (and existing exclusion areas)
For those potential impacts that remain following selection of an optimal route, appropriate mitigation measures are readily available. Where warranted, further consideration of route selection is provided in the country specific EIAs.
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10 Management Program
As indicated in section 1.3, this EP EIA has been prepared so that mitigation measures identified are incorporated into an Equator Principles Action Plan (EP AP) that will be implemented from the start of Project construction. The EP AP is incorporated as Annex 3. Because of the varying timescales of the national environmental approval processes construction will commence in some landfall countries before national environmental approval processes are complete in others. For this reason the EP EIA addresses generic impacts and mitigations for the Project as a whole, incorporates the EP AP provisions for the Project as a whole, and will be updated to incorporate EP AP provisions for the various landing countries as they are approved by the relevant national environmental regulators. (The Version Control Record on the inside front cover records which landing country provisions are included in this current version of the document.)
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References
Ref 1 The EASSy cable http://www.eassy.org/index.htm Ref 2 Convention for the Protection of Submarine Telegraph Cables (Paris, 14 March 1884) http://www.iscpc.org/information/Convention_on_Protection_of_Cables_1884.pdf Ref 3 Article 2 of the United Nations Convention on the High Seas, Geneva 1958. Ref 4 UNCLOS web site http://www.un.org/Depts/los/LEGISLATIONANDTREATIES/frequently_asked_questions.htm Ref 5 Marine Protected Areas on the High Seas. Foundation for International Environmental Law and Development. January 2008. Ref 6 http://bure.unep-wcmc.org/marine/highseas/viewer.htm Ref 7 Final Scoping Report Proposed Installation of the SEA Cable System, KwaZulu-Natal North Coast, South Africa (EIA reference number: 12/12/20/1100), June 2008. Ref 8 The Status of Natural Resources on the High Seas, Southampton Oceanography Centre, 2001 Ref 9 The InterRidge Hydrothermal Vents Database www.interridge.org ,updated 2008 Ref 10 Encyclopedia of the earth http://www.eoearth.org/image/Volcano_seamount_Sonne.jpg Ref 11 Oceana. Deep Sea Corals, out of sight but no longer out of mind. Ref 12 Guidance on the Interpretation of Major Accidents to the Environment for the Purposes of COMAH Regulations. DETR, June 1999. Ref 13 2007 IUCN Red List of Threatened Species, IUCN Species Survival Commission. http://www.iucnredlist.org/ Ref 14 ICPC presentation About Submarine Telecommunication cables http://www.iscpc.org/ Ref 15 International Convention for the Prevention of Pollution from Ships (MARPOL 73/78). Ref 16 Environment Health and Safety Guidelines Shipping. IFC, April 2007. Ref 17 IMO Guidelines for the Control and Management of Ships Ballast Water to Minimize the Transfer of Harmful Aquatic Organisms and Pathogens.
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Ref 18 Hydrographic Information and the Submarine Cable Industry. P G Allan (SEtech, 2001). Ref 19 Tata Indicom India Singapore Cable System (TIISCS) Environmental Aspects of Submarine Telecommunications Cable Installation S. Drew, R. Rapp, D. Marquis, June 2004. Ref 20 Environmental Impact of the ATOC/Pioneer Seamount Submarine Cable Monterey Bay Aquarium Research Institute and Monterey Bay National Marine Sanctuary, November 2003. Ref 21 Sharkbite on the SL Submarine Lightwave Cable System: history, Causes and Resolution. IEEEE Journal of Oceanic Engineering, Vol 14, No 3 July 1989. Ref 22 International EMF Project Information Sheet, Electromagnetic Fields and Public Health Effects of EMF on the Environment, February 2005. Ref 23 Personal communication, Tyco , March 2008. Ref 24 ICPC recommendation No.1, Management of Redundant and Out of Service Cables, Jan. 2007. Ref 25 The Legal Status of Out-of-Service Submarine Cables, Douglas R. Burnett Paper reprinted from Maritime Studies no. 137, July/August 2004, published by the Australian Centre for Maritime Studies.
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Annex 1: Equator Principles
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Annex 1 Equator Principles

PREAMBLE Project financing, a method of funding in which the lender looks primarily to the revenues generated by a single project both as the source of repayment and as security for the exposure, plays an important role in financing development throughout the world.1 Project financiers may encounter social and environmental issues that are both complex and challenging, particularly with respect to projects in the emerging markets The Equator Principles Financial Institutions (EPFIs) have consequently adopted these Principles in order to ensure that the projects we finance are developed in a manner that is socially responsible and reflect sound environmental management practices. By doing so, negative impacts on project-affected ecosystems and communities should be avoided where possible, and if these impacts are unavoidable, they should be reduced, mitigated and/or compensated for appropriately. We believe that adoption of and adherence to these Principles offers significant benefits to ourselves, our borrowers and local stakeholders through our borrowers engagement with locally affected communities. We therefore recognise that our role as financiers affords us opportunities to promote responsible environmental stewardship and socially responsible development. As such, EPFIs will consider reviewing these Principles from time-to-time based on implementation experience, and in order to reflect ongoing learning and emerging good practice. These Principles are intended to serve as a common baseline and framework for the implementation by each EPFI of its own internal social and environmental policies, procedures and standards related to its project financing activities. We will not provide loans to projects where the borrower will not or is unable to comply with our respective social and environmental policies and procedures that implement the Equator Principles. SCOPE The Principles apply to all new project financings globally with total project capital costs of US$10 million or more, and across all industry sectors. In addition, while the Principles are not intended to be applied retroactively, we will apply them to all project financings covering expansion or upgrade of an existing facility where changes in scale or scope may create significant environmental and/or social impacts, or significantly change the nature or degree of an existing impact. The Principles also extend to project finance advisory activities. In these cases, EPFIs commit to make the client aware of the content, application and benefits of applying the Principles to the anticipated project, and request that the client communicate to the EPFI its intention to adhere to the requirements of the Principles when subsequently seeking financing.
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STATEMENT OF PRINCIPLES EPFIs will only provide loans to projects that conform to Principles 1-9 below: Principle 1: Review and Categorisation When a project is proposed for financing, the EPFI will, as part of its internal social and environmental review and due diligence, categorise such project based on the magnitude of its potential impacts and risks in accordance with the environmental and social screening criteria of the International Finance Corporation (IFC) (Exhibit I). Principle 2: Social and Environmental Assessment For each project assessed as being either Category A or Category B, the borrower has conducted a Social and Environmental Assessment (Assessment) process1 to address, as appropriate and to the EPFIs satisfaction, the relevant social and environmental impacts and risks of the proposed project (which may include, if relevant, the illustrative list of issues as found in Exhibit II). The Assessment should also propose mitigation and management measures relevant and appropriate to the nature and scale of the proposed project. Principle 3: Applicable Social and Environmental Standards For projects located in non-OECD countries, and those located in OECD countries not designated as High-Income, as defined by the World Bank Development Indicators Database, the Assessment will refer to the then applicable IFC Performance Standards (Exhibit III) and the then applicable Industry Specific EHS Guidelines (EHS Guidelines) (Exhibit IV). The Assessment will establish to a participating EPFIs satisfaction the project's overall compliance with, or justified deviation from, the respective Performance Standards and EHS Guidelines. The regulatory, permitting and public comment process requirements in High-Income OECD Countries, as defined by the World Bank Development Indicators Database, generally meet or exceed the requirements of the IFC Performance Standards (Exhibit III) and EHS Guidelines (Exhibit IV). Consequently, to avoid duplication and streamline EPFI's review of these projects, successful completion of an Assessment (or its equivalent) process under and in compliance with local or national law in High-Income OECD Countries is considered to be an acceptable substitute for the IFC Performance Standards, EHS Guidelines and further requirements as detailed in Principles 4, 5 and 6 below. For these projects, however, the EPFI still categorises and reviews the project in accordance with Principles 1 and 2 above. The Assessment process in both cases should address compliance with relevant host Country laws, regulations and permits that pertain to social and environmental matters.
Social and Environmental Assessment is a process that determines the social and environmental impacts and risks (including labour, health, and safety) of a proposed project in its area of influence. For the purposes of Equator Principles compliance, this will be an adequate, accurate and objective evaluation and presentation of the issues, whether prepared by the borrower, consultants or external experts. Depending on the nature and scale of the project, the assessment document may comprise a full-scale social and environmental impact assessment, a limited or focused environmental or social assessment (e.g. audit), or straight-forward application of environmental siting, pollution standards, design criteria, or construction standards. One or more specialised studies may also need to be undertaken.
1
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Principle 4: Action Plan and Management System For all Category A and Category B projects located in non-OECD countries, and those located in OECD countries not designated as High-Income, as defined by the World Bank Development Indicators Database, the borrower has prepared an Action Plan (AP)2 which addresses the relevant findings, and draws on the conclusions of the Assessment. The AP will describe and prioritise the actions needed to implement mitigation measures, corrective actions and monitoring measures necessary to manage the impacts and risks identified in the Assessment. Borrowers will build on, maintain or establish a Social and Environmental Management System that addresses the management of these impacts, risks, and corrective actions required to comply with applicable host country social and environmental laws and regulations, and requirements of the applicable Performance Standards and EHS Guidelines, as defined in the AP. For projects located in High-Income OECD countries, EPFIs may require development of an Action Plan based on relevant permitting and regulatory requirements, and as defined by host-country law. Principle 5: Consultation and Disclosure For all Category A and, as appropriate, Category B projects located in non-OECD countries, and those located in OECD countries not designated as High-Income, as defined by the World Bank Development Indicators Database, the government, borrower or third party expert has consulted with project affected communities in a structured and culturally appropriate manner.3 For projects with significant adverse impacts on affected communities, the process will ensure their free, prior and informed consultation and facilitate their informed participation as a means to establish, to the satisfaction of the EPFI, whether a project has adequately incorporated affected communities concerns.4 In order to accomplish this, the Assessment documentation and AP, or non-technical summaries thereof, will be made available to the public by the borrower for a reasonable minimum period in the relevant local language and in a culturally appropriate manner. The borrower will take account of and document the process and results of the consultation,
The Action Plan may range from a brief description of routine mitigation measures to a series of documents (e.g. resettlement action plan, indigenous peoples plan, emergency preparedness and response plan, decommissioning plan etc). The level of detail and complexity of the Action Plan and the priority of the identified measures and actions will be commensurate with the projects potential impacts and risks. Consistent with Performance Standard 1, the internal Social and Environmental Management System will incorporate the following elements: (i) Social and Environmental Assessment; (ii) management program; (iii) organisational capacity; (iv) training; (v) community engagement; (vi) monitoring; and (vii) reporting.
3 Affected communities are communities of the local population within the projects area of influence who are likely to be adversely affected by the project. Where such consultation needs to be undertaken in a structured manner, EPFIs may require the preparation of a Public Consultation and Disclosure Plan (PCDP). 4 2
Consultation should be free (free of external manipulation, interference or coercion, and intimidation), prior (timely disclosure of information) and informed (relevant, understandable and accessible information), and apply to the entire project process and not to the early stages of the project alone. The borrower will tailor its consultation process to the language preferences of the affected communities, their decision-making processes, and the needs of disadvantaged or vulnerable groups. Consultation with Indigenous Peoples must conform to specific and detailed requirements as found in Performance Standard 7. Furthermore, the special rights of Indigenous Peoples as recognised by host-country legislation will need to be addressed.
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including any actions agreed resulting from the consultation. For projects with adverse social or environmental impacts, disclosure should occur early in the Assessment process and in any event before the project construction commences, and on an ongoing basis. Principle 6: Grievance Mechanism For all Category A and, as appropriate, Category B projects located in non-OECD countries, and those located in OECD countries not designated as High-Income, as defined by the World Bank Development Indicators Database, to ensure that consultation, disclosure and community engagement continues throughout construction and operation of the project, the borrower will, scaled to the risks and adverse impacts of the project, establish a grievance mechanism as part of the management system. This will allow the borrower to receive and facilitate resolution of concerns and grievances about the projects social and environmental performance raised by individuals or groups from among project-affected communities. The borrower will inform the affected communities about the mechanism in the course of its community engagement process and ensure that the mechanism addresses concerns promptly and transparently, in a culturally appropriate manner, and is readily accessible to all segments of the affected communities. Principle 7: Independent Review For all Category A projects and, as appropriate, for Category B projects, an independent social or environmental expert not directly associated with the borrower will review the Assessment, AP and consultation process documentation in order to assist EPFI's due diligence, and assess Equator Principles compliance. Principle 8: Covenants An important strength of the Principles is the incorporation of covenants linked to compliance. For Category A and B projects, the borrower will covenant in financing documentation: a. to comply with all relevant host country social and environmental laws, regulations and permits in all material respects; b. to comply with the AP (where applicable) during the construction and operation of the project in all material respects; c. to provide periodic reports in a format agreed with EPFIs (with the frequency of these reports proportionate to the severity of impacts, or as required by law, but not less than annually), prepared by in-house staff or third party experts, that i) document compliance with the AP (where applicable), and ii) provide representation of compliance with relevant local, state and host country social and environmental laws, regulations and permits; and d) to decommission the facilities, where applicable and appropriate, in accordance with an agreed decommissioning plan. Where a borrower is not in compliance with its social and environmental covenants, EPFIs will work with the borrower to bring it back into compliance to the extent feasible, and if the
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borrower fails to re-establish compliance within an agreed grace period, EPFIs reserve the right to exercise remedies, as they consider appropriate. Principle 9: Independent Monitoring and Reporting To ensure ongoing monitoring and reporting over the life of the loan, EPFIs will, for all Category A projects, and as appropriate, for Category B projects, require appointment of an independent environmental and/or social expert, or require that the borrower retain qualified and experienced external experts to verify its monitoring information which would be shared with EPFIs. Principle 10: EPFI Reporting Each EPFI adopting the Equator Principles commits to report publicly at least annually about its Equator Principles implementation processes and experience, taking into account appropriate confidentiality considerations5.
Such reporting should at a minimum include the number of transactions screened by each EPFI, including the categorisation accorded to transactions (and may include a breakdown by sector or region), and information regarding implementation.
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Annex 2: Example data sets acquired from the marine surveys
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Annex 2 Example data sets acquired from the marine surveys

The marine surveys included Nearshore (20 to 1,000mwd), Deep Sea (>1,000mwd) and Branching Unit (BU) geophysical survey operations and Inshore (3 to 20mwd), Diver Swim and Landing Site surveys Survey scope of work:

A beach landing topographic survey within a survey corridor of 10m from the beach manhole (BMH) to 0m Lowest Astronomical Tide (LAT). A diver swim survey from 0m (LAT) to approximately 3mwd within a 10m corridor, with a minimum of one line along the route. An inshore survey collected bathymetric, side scan sonar (SSS) and sub-bottom profile (SBP) data within a corridor width of 500m from 3 to 20mwd, with a minimum seven primary survey lines (100% SSS overlap) and tie lines at 10 times the primary line spacing with a minimum of two lines. A nearshore survey collected bathymetric, SSS and SBP data within a 500m corridor from approximately 20mwd to the first occurrence of 100mwd. And a corridor width of 1,000m from 100mwd to the end of burial depth (i.e. 1,000mwd, or 300m in Red Sea area). The nearshore survey consisted of a minimum three lines with a 20% bathymetry overlap, a 500m overlap with the inshore survey and 1,000m overlap with the deep sea survey. A deep sea survey along the route collected bathymetric data within a corridor width of at least two times water depth in excess of 1,000mwd, up to a maximum single swath of 10km. It overlapped the nearshore survey by at least 1,000m. A BU survey over an area six times water depth centered over the BU site, with a minimum of two lines (20% bathymetry overlap). A seabed / ground sampling program covered all survey areas and consisted as a minimum of: Landing site survey: bar probing every 25m, Diver survey: bar probing every 25m, (100m Maputo landing) Inshore survey: grab sampling every 500m with a minimum of two attempts, Nearshore survey: piston cores every 10km with a minimum of two attempts, and in the event of core failure, dredge sampling with a minimum of two attempts.
Cable crossing survey to detect existing cables, if not previously identified in water depth <100m using the SSS. Magnetometer search was limited to 200mwd. Note: No cables were crossed during the inshore or nearshore surveys for Phase 1 therefore, no cable crossing surveys were required.
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Pipeline crossing surveys to detect existing pipelines, if not previously identified in water depth <100m using the SSS. Note: No pipelines were crossed during the inshore or nearshore surveys therefore, no pipeline crossing surveys were required. A pipeline is thought to be crossed on the upper beach at the Mtunzini, South Africa landing however the exact position of the pipeline could not be determined. Temperatures and sound velocities through the water column were measured on a daily basis, or more if required, using expendable probes (XBTs). No route development allowance was included in the SEA contract. Any route development requested by client representative on board the vessel was logged, in time, from break off from route to re-commencement of route, including any overlap re-run.
Examples of survey output are shown below.
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Annex 3: Equator Principles Action Plan
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SEACOM Cable System Equator Principles Environmental Action Plan SED 01
Prepared for: SEACOM Prepared by: ENVIRON London, UK Date: March 2009 Project / Issue Number: 61C12704_04
Contract/Proposal No: Issue:
61C12704 03
Author (signature):
Project Manager/Director (signature):
Date:
March 2009
This report has been prepared by ENVIRON with all reasonable skill, care and diligence, and taking account of the Services and the Terms agreed between ENVIRON and the Client. This report is confidential to the client, and ENVIRON accepts no responsibility whatsoever to third parties to whom this report, or any part thereof, is made known, unless formally agreed by ENVIRON beforehand. Any such party relies upon the report at their own risk. ENVIRON disclaims any responsibility to the Client and others in respect of any matters outside the agreed scope of the Services.
VERSION CONTROL RECORD

Issue 01 02 03 04 Description of Status Draft, AP sent to SEACOM plus additional mitigation measures from country specific plans and EP EIA Revised draft Final version, incorporating Kenya Action Plan as Table 3 Final version, incorporating country-specific action plans in Annex 1 Date 30/05/08 09/08/08 03/09/08 06/03/09 Reviewer Initials ND ND ND ND Authors Initials CH CH CH CH
Contents
Page Introduction Table 2a. Table 2b. Project Wide Environmental and Social Action Plan (Onshore) Project Wide Environmental and Social Action Plan (Offshore) 4 7 18
Annex 1 Country-Specific Action Plans & SEACOM Regulatory Approval Documentation South Africa - Environmental Action Plan Mozambique - Environmental Action Plan Tanzania - Environmental Action Plan Kenya - Environmental Action Plan Djibouti - Environmental Action Plan Egypt - Environmental Action Plan
Introduction
This document is the Equator Principles Action Plan (EPAP or Action Plan) that forms part of the Social and Environmental Management System (SEMS) and is referenced in the SEMS Manual. It describes the measures to be applied to the Project in order to minimize potential adverse affects arising from the Project. It is one component of the SEMS and should be used in conjunction with the other elements of the SEMS. The EPAP has been prepared in accordance with the IFC guidance for development of Environmental Action Plans (Performance Standard 1). The EPAP presents Project-wide actions in tabular form with the following requirements of PS1 captured directly by the column headings in the tables: description of actions to implement mitigation measure/requirement (column heading mitigation measure/requirement); prioritisation of actions (column heading priority (H/M/L)); and time-line for implementation (column heading timeframe).
Other column headings have been included to add clarity and detail as described in Table 1. Table 1. Guidance notes/column descriptions EPAP Column Heading [Action] Reference Issue/potential impact Mitigation measure/requirement Document reference Description/Guidance A unique identifier Issue by topic area e.g. soil erosion Summarised action/mitigation measure identified by the EIAs that must be implemented to minimise potential adverse impacts/enhance positive impacts. Reference to the underlying document. This includes relevant sections from within the EP EIA, relevant IFC Performance Standards, EHS guidelines and applicable treaties or conventions. Reference documents are coded from A to N A IFC General EHS Guidelines B IFC EHS Guidelines Telecommunications C International Convention for the Control and Management of Ships Ballast waters and sediments D IMO guidelines for the Control and Management of Ships Ballast Water to Minimize the Transfer of Harmful Aquatic Organisms and Pathogens E MARPOL 73/78 Annex I F MARPOL 73/78 Annex II G MARPOL 73/78 Annex IV H MARPOL 73/78 Annex V I MARPOL 73/78 Annex VI J Equator Principles Environmental Impact Assessment (EP EIA) K IFC Performance Standards 1-8
Monitoring/ verification method Timeframe
Priority (H/M/L)
Responsible Party (organisation)
International Convention on the Control of Harmful Anti-fouling Systems on Ships, 2001 M IFC EHS Guidelines Shipping N UKCPC Guideline No 8, Guidelines for Submarine Cable Decommissioning, 2006 Describes the means of monitoring/verification e.g. reporting requirements and audit programme. Further details on the monitoring programmes are provided in the SEMS (SED 06, SEP 07 & SEP 08). Timeframe during which an action is applicable. This tends to be either the construction [including commissioning], operational or decommissioning phase. Priorities are provided in line with IFC guidance. The priority is categorized as high, medium or low in line with the following definitions: x High (H): Actions relating to significant potential environmental or social impacts identified in the impact assessment process and actions derived from direct legal requirements or project-related permits. Legal requirements include any laws, ordinances, regulations, rules, orders, proclamations, requirements of governmental authorities or treaties. x Medium (M): Other social and environmental commitments defined in the impact assessment process. x Low (L): Additional measures beyond legal / lender requirements e.g. undertaken on a voluntary process. Responsible parties by organisations and job title, recognising that actions may be delegated but overall ownership remains with the entities specified in the responsible party column. Where more than one responsible party is identified the party or parties in parentheses have secondary responsibility.
L
In addition to the Project-wide actions presented in Table 2, country-specific action plans (or environmental management plans) have been prepared where required. These country-specific measures are incorporated into this Equator Principles Action Plan in annex 1, (for South Africa, Mozambique, Tanzania, Kenya, Djibouti and Egypt). The annex also includes the notifications of country-specific environmental approval. Table 2 specifies the measures identified in the project-wide EP EIA. These are categorised under the main headings Onshore and Offshore, with a number of further sub categories. The structure [broadly] aligns with that in the EP EIA as summarised below. Equator principles (project wide) EIA Onshore Activities (Table 2a) x Environmental x Socio-economic x Occupational Health and Safety x Community Health and Safety
Offshore Activities (Table 2b) x Environmental x Socio-economic x Occupational Health and Safety x Community Health and Safety The subdivision of onshore and offshore activities into four sub-categories is consistent with the categorisation within the relevant IFC Environmental, Health and Safety Guidelines, which are listed in Table 1. (The Equator Principles refer to IFC environmental and social review processes, including the use of relevant sectoral EHS Guidelines.) The measures outlined in Table 2 (Projectwide) apply across the Project. Country-specific action plans have been developed under national environmental approvals processes and are applicable only to the country of origin. The country-specific requirements presented in annex 1 are therefore additional to those specified in the Project-wide Action Plan. Following their acceptance by the relevant regulatory authorities in the respective countries the country-specific plans are fixed, whereas the measures in Table 2 (the Project-wide action plan) may be updated from time to time; the EPAP should therefore be considered a live document.
Table 2a. Project Wide Environmental and Social Action Plan (Onshore)
Location Landing Countries Issue/ potential impact Doc Ref. Responsible Party (organisation) Priority (H/M/L) 1 Monitoring/ verification method Non-landing Cs
Corporate
High Seas
Mozambique
Ref
Mitigation measure/ requirement
Timeframe
Tanzania
S. Africa
Djibouti
Onshore activities Environmental ES1 General Implement good management practices through the development environof a social and environmental management system (SEMS), mental and including: social x grievance procedures management x audit programme x stakeholder engagement plan x monitoring plan x training programme x etc. Details of these practices are captured in the Social and Environmental Procedures SEP01 SEP08, which form part of the SEMS. ES2 Route Onshore cable routes selected to minimize adverse impacts by selection preferential selection of a route that: x uses existing utility corridors x uses previously disturbed areas x avoids sensitive areas (including steep slopes, watercourses, sites of archaeological or cultural value, protected areas) x minimizes the onshore cable length ES3 Soil erosion Reducing or preventing erosion by: x Scheduling to avoid heavy rainfall periods (to the extent practical) x Mulching to stabilise exposed areas x Revegetating areas promptly Reducing or preventing off-site sediment transport through use of settlement ponds, silt fences, etc and modifying or suspending activities during extreme rainfall and high winds to the extent practical. Segregating or diverting clean water runoff to prevent it mixing with water containing a high solids content.
SEACOM S&E management representative
Construction and Operations
Internal audit program
SEACOM S&E management representative J (Tyco EHS Manager) Construction M
Contractors monthly reporting against the AP. Internal audit program
9 9 9 9 9 9
A-4.1
Tyco EHS Manager
Construction
9 9
9 9
See definitions for priority in Table 1.
Kenya
Egypt
Corporate
High Seas
Mozambique
Ref
Timeframe
Tanzania
S. Africa
Djibouti
ES4
Soil management Noise and Vibration
ES5
ES6
Air Quality
Reinstatement of cable trench material. Where possible and appropriate top soil will be segregated and replaced on other back fill material to promote regeneration of vegetation. Use of noise suppression shields and mufflers. Locate noise generating sources away from residential or other noise-sensitive receptors. Comply with noise emission levels provided in IFC General EHS Guidelines. Plan activities in consultation with local communities so that activities with the greatest potential to generate noise are planned during periods of the day that will result in least disturbance Avoid or minimise project transportation through community areas. Minimizing dust from open area sources, including storage piles, by using control measures such as installing enclosures and covers, and increasing the moisture content. Dust suppression techniques should be implemented, such as applying water or non-toxic chemicals to minimize dust from vehicle movements Managing emissions from mobile sources as follows: x Emissions do not result in pollutant concentrations that reach or exceed relevant ambient quality guidelines and standards by applying national legislated standards, or in their absence, the current WHO Air Quality Guidelines x Emissions from on-road and off-road vehicles should comply with national or regional programs. In the absence of these regardless of the size or type of vehicle, operators should implement the manufacturer recommended engine maintenance programs Avoiding open burning of solid wastes.
Tyco EHS Manager
Construction
B-1.1 A-4.1
Tyco EHS Manager Construction (SEACOM S&E management representative) H
Contractors monthly reporting against the AP. Landing partner S&E representative Tyco EHS Manager SEACOM S&E management representative.
9 9
9 9
9 9 9 9 9 9
B-1.1 A-4.1 A-1.6
Tyco EHS Manager
Construction
9 9 9 9 9 9
Kenya
Egypt
Corporate
High Seas
Mozambique
Ref
Timeframe
Tanzania
S. Africa
Djibouti
ES7
Solid Waste
Utilise techniques for preventing and controlling non-hazardous and hazardous construction site solid waste, including: x Establishing waste management priorities at the outset of activities based on an understanding of potential Environmental, Health, and Safety (EHS) risks and impacts and considering waste generation and its consequences x Establishing a waste management hierarchy that considers prevention, reduction, reuse, recovery, recycling, removal and finally disposal of wastes. x Avoiding or minimizing the generation waste materials, as far as practicable x Where waste generation cannot be avoided but has been minimized, recovering and reusing waste x Where waste can not be recovered or reused, treating, destroying, and disposing of it in an environmentally sound manner Minimizing hazardous waste generation by implementing stringent waste segregation to prevent the commingling of non- hazardous and hazardous waste to be managed. Ensuring that contractors handling, treating, and disposing of hazardous waste are reputable and legitimate enterprises, licensed by the relevant regulatory agencies and following good international industry practice for the waste being handled. Ensuring compliance with applicable local and international regulations (including Basel Convention on the Control of Transboundary Movements of Hazardous Waste and their Disposal).
A-4.1 A-1.6
Tyco EHS Manager
Construction
9 9 9 9 9 9
Kenya
Egypt
Corporate
High Seas
Mozambique
Ref
Timeframe
Tanzania
S. Africa
Djibouti
ES8
Solid Waste
Hazardous waste should be stored so as to prevent or control accidental releases to air, soil, and water resources in area location where: x Waste is stored in a manner that prevents the commingling or contact between incompatible wastes, and allows for inspection between containers to monitor leaks or spills. Examples include sufficient space between incompatibles or physical separation such as walls or containment curbs. x Store in closed containers away from direct sunlight, wind and rain. x Secondary containment systems should be constructed with materials appropriate for the wastes being contained and adequate to prevent loss to the environment x Secondary containment is included wherever liquid wastes are stored in volumes greater than 220 liters. The available volume of secondary containment should be at least 110 percent of the largest storage container, or 25 percent of the total storage capacity (whichever is greater), in that specific location . x Provide adequate ventilation where volatile wastes are stored. x Provision of spill containment and clean-up equipment (see hazardous materials below). x Waste management practices should be monitored through regular audit of waste segregation and collection practices. All wastes should be collected and removed from the construction site. Food wastes will be contained in a manner that will not attract scavenging animals e.g. bins will have lids. Providing adequate secondary containment for fuel storage tanks and for the temporary storage of other fluids such as lubricating oils and hydraulic fluids, using impervious surfaces for refueling areas and other fluid transfer areas. Training workers on the correct transfer and handling of fuels and chemicals and the response to spills. Providing portable spill containment and cleanup equipment on site and training in the equipment deployment. Provision of suitable personal protection equipment.
A-4.1 A-1.6
Tyco EHS Manager
Construction
9 9 9 9 9 9
ES9
General site management Hazardous Materials
Tyco EHS Manager
Construction
Contractors monthly reporting against the AP.
9 9 9 9 9 9
ES10
Tyco EHS Manager A-4.1 (SEACOM S&E management representative)
Contractors monthly reporting against the AP. Construction H Internal audit program
9 9 9 9 9 9
10
Kenya
Egypt
Corporate
High Seas
Mozambique
Ref
Timeframe
Tanzania
S. Africa
Djibouti
ES11
Hazardous materials Wastewater Discharges
ES12
Hazardous materials should be securely stored and have appropriate signage. They should also be accompanied with accessible MSDSs. Adequate portable or permanent sanitation facilities serving all workers should be provided at all construction sites. Sanitary wastewater in construction and other sites should be managed according to section 1.3 of IFC General EHS Guidelines.
Tyco EHS Manager
Construction
A-4.1
Tyco EHS Manager
Construction
Contractors monthly reporting against the AP. Contractors monthly reporting against the AP. Internal audit program
9 9 9 9 9 9
9 9 9 9 9 9
ES13
Visual impact and cultural heritage
ES14
Terrestrial Habitat Alteration
Use of existing facilities (beach man holes and cable stations) where possible. Sympathetic siting of cable stations e.g. sunken into a hillside. Appropriately coloured containers/building materials and architecture will be selected to blend in with the surrounding environment. Where there is an assessed risk of a site with archaeological/cultural value, surveys will be undertaken to inform the cable route and avoid such sites. Avoidance of construction activities during the breeding season and other sensitive seasons or times of day. Revegetation of disturbed areas with native plant species. Management of construction site activities as described in relevant sections of the IFC General EHS Guidelines (as outlined in this Action Plan) Avoid protected habitats/species where possible. If avoidance is not possible, manage impacts to ensure no overall loss of biodiversity (e.g. translocation, offset arrangement, etc.) Decommissioning should be carried out in accordance with applicable industry practice at the cessation of system operations. Specific measures shall be formulated within a decommissioning plan produced at least 6 months prior to the Projects end of life. Typically this might include the recycling of cable components where possible. Non recyclable components should be disposed in accordance with good waste management practices (see Solid Waste)
Construction
9 9 9 9 9 9
SEACOM S&E management representative B-1.1 (Tyco EHS Manager) SEACOM S&E management representative Construction M
Contractors monthly reporting against the AP. Internal audit program Internal audit program
9 9 9 9 9 9
ES15
Terrestrial habitat Decommissio ning disposal of cable
Construction
9 9 9 9 9 9
ES16
Decommissioning
9 9 9 9 9 9 9 9 9
11
Kenya
Egypt
Corporate
High Seas
Mozambique
Ref
Timeframe
Tanzania
S. Africa
Djibouti
Onshore activities Social ES17 Labour issues
All contractors will comply with relevant requirements of the International Labour Organisation (ILO) to avoid use of child or forced labour. Specifically this includes compliance with: x ILO Forced Labour Convention, No 29 1930 x x x x x x x x ILO Abolition of Forced Labour Convention, No 105 1957 ILO Right to Organise and Collective Bargaining Convention. No. 98.1949 ILO Equal Remuneration Convention. No. 100 1951 ILO Discrimination (Employment and Occupation) Convention, No. 111 1958 ILO Minimum Age Convention, No.138 1973 ILO Worst forms of Child Labour Convention, No. 182 1999 ILO Convention 87 on Freedom of Association and Protection of the Right to Organize UN Convention on the Rights of the Child, Article 32.1, 1989 SEACOM S&E management representative Tyco EHS Manager Tyco EHS Manager (SEACOM S&E management representative) Construction and operations Construction Internal audit program Contractors monthly reporting against the AP Contractors monthly reporting against the AP. Internal audit program K Tyco EHS Manager (SEACOM S&E management representative) Construction H Internal audit program 9 9 9 9 9 9
ES18
Economic displacement
ES19
Social benefits Over-exertion
Avoid or at least minimize physical displacement or adverse economic impact (including loss of assets/resources) where possible. Where unavoidable, promptly compensate for loss of assets or access to assets at full replacement cost. Use of local workforce to maximize direct and secondary local employment opportunities. Training of workers in lifting and materials handling techniques in construction projects, including the placement of weight limits above which mechanical assists or two-person lifts are necessary. Planning work site layout to minimize the need for manual transfer of heavy loads. Selecting tools and designing work stations that reduce force requirements and holding times, and which promote improved postures, including, where applicable, user adjustable work
J, K
9 9 9 9 9 9
J A-4.2
9 9 9 9 9 9
OHS1
Construction
9 9 9 9 9 9
12
Kenya
Egypt
Corporate
High Seas
Mozambique
Ref
Timeframe
Tanzania
S. Africa
Djibouti
stations. Implementing administrative controls into work processes, such as job rotations and rest or stretch breaks. Implementing good house-keeping practices, such as the sorting and placing loose construction materials or demolition debris in established areas away from foot paths. Cleaning up excessive waste debris and liquid spills regularly. Locating electrical cords and ropes in common areas and marked corridors. Use of slip retardant footwear. Development of a fall protection plan which includes one or more of the following aspects, depending on the nature of the fall hazard: x Training and use of temporary fall prevention devices, such as rails or other barriers able to support a weight of 200 pounds, when working at heights equal or greater than two meters or at any height if the risk includes falling into operating machinery, into water or other liquid, into hazardous substances, or through an opening in a work surface x Training and use of personal fall arrest systems, such as full body harnesses and energy absorbing lanyards able to support 5000 pounds, as well as fall rescue procedures to deal with workers whose fall has been successfully arrested. The tie in point of the fall arresting system should also be able to support 5000 pounds x Use of control zones and safety monitoring systems to warn workers of their proximity to fall hazard zones, as well as securing, marking, and labeling covers for openings in floors, roofs, or walking surfaces A-4.2
OHS2
Slips and Falls
Tyco EHS Manager (SEACOM S&E management representative) Construction H
9 9 9 9 9 9
OHS3
Work in Heights
Tyco EHS Manager A-4.2 (SEACOM S&E management representative) Construction H
9 9 9 9 9 9
13
Kenya
Egypt
Corporate
High Seas
Mozambique
Ref
Timeframe
Tanzania
S. Africa
Djibouti
OHS4
Struck by Objects
Using a designated and restricted waste drop or discharge zones, and/or a chute for safe movement of wastes from upper to lower levels. Conducting sawing, cutting, grinding, sanding, chipping or chiseling with proper guards and anchoring as applicable. Maintaining clear traffic ways to avoid driving of heavy equipment over loose scrap. Use of temporary fall protection measures in scaffolds and out edges of elevated work surfaces, such as hand rails and toe boards to prevent materials from being dislodged. Evacuating work areas during blasting operations, and using blast mats or other means of deflection to minimize fly rock or ejection of demolition debris if work is conducted in proximity to people or structures. Wearing appropriate PPE, such as safety glasses with side shields, face shields, hard hats, and safety shoes. Planning and segregating the location of vehicle traffic, machine operation, and walking areas, and controlling vehicle traffic through the use of one-way traffic routes, establishment of speed limits, and on-site trained flag-people wearing high-visibility vests or outer clothing covering to direct traffic Ensuring the visibility of personnel through their use of high visibility vests when working in or walking through heavy equipment operating areas, and training of workers to verify eye contact with equipment operators before approaching the operating vehicle Ensuring moving equipment is outfitted with audible back-up alarms Using inspected and well-maintained lifting devices that are appropriate for the load, such as cranes, and securing loads when lifting them to higher job-site elevations. Dust suppression techniques should be implemented, such as; x applying water or non-toxic chemicals to minimize dust from vehicle movements. x PPE, such as dusk masks, should be used where dust levels are excessive. A-4.2 Tyco EHS Manager (SEACOM S&E management representative) Construction H Contractors monthly reporting against the AP. Internal audit program
9 9 9 9 9 9
OHS5
Moving Machinery
9 9 9 9 9 9
OHS6
Dust
14
Kenya
Egypt
Corporate
High Seas
Mozambique
Ref
Timeframe
Tanzania
S. Africa
Djibouti
OHS7
Confined Spaces and Excavations
Controlling site-specific factors which may contribute to excavation slope instability including, for example, the use of excavation dewatering, side-walls support, and slope gradient adjustments that eliminate or minimize the risk of collapse, entrapment, or drowning. Providing safe means of access and egress from excavations, such as graded slopes, graded access route, or stairs and ladders. Avoiding the operation of combustion equipment for prolonged periods inside excavations areas where other workers are required to enter unless the area is actively ventilated. Only allowing trained and certified workers to install, maintain, or repair electrical equipment. Deactivating and properly grounding live power distribution lines before work is performed on, or in close proximity to, the lines. Ensuring that live-wire work is conducted by trained workers with strict adherence to specific safety and insulation standards. Qualified or trained employees working on transmission or distribution systems should be able to achieve the following: x Distinguish live parts from other parts of the electrical system x Determine the voltage of live parts x Understand the minimum approach distances outlined for specific live line voltages x Ensure proper use of special safety equipment and procedures when working near, or on, exposed energized parts of an electrical system Workers should not approach an exposed, energized or conductive part even if properly trained unless: x The worker is properly insulated from the energized part with gloves or other approved insulation; or x The energized part is properly insulated from the worker and any other conductive object; or x The worker is properly isolated and insulated from any other conductive object (live-line work) Where maintenance and operation is required within minimum setback distances, specific training, safety measures, personal safety devices, and other precautions should be defined in a health and safety plan. A-4.2
9 9 9 9 9 9
OHS8
Electrical Safety
Tyco EHS Manager (SEACOM S&E management representative)
Contractors monthly reporting against the AP. Construction H Internal audit program
B-1.2
9 9 9 9 9 9
15
Kenya
Egypt
Corporate
High Seas
Mozambique
Ref
Timeframe
Tanzania
S. Africa
Djibouti
OHS9
Electrical safety
OHS10
Optical Fiber Safety
Recommendations to prevent, minimize and control injuries related to electrical shock include. x All electrical installations should be performed by certified personnel and supervised by an accredited person. Certification for such work should include theoretical as well as practical education and experience; x Strict procedures for de-energizing and checking of electrical equipment should be in place before any maintenance work is conducted. If de- energizing is not possible, electrical installations should be moved or insulated to minimize the hazardous effects; x Prior to excavation works, all existing underground cable installations should be identified and marked. Drawings and plans should indicate such installations; x All electrical installations or steel structures, such as masts or towers, should be grounded to provide safety as the electrical current chooses the grounded path for electrical discharge. In cases where maintenance work has to be performed on energized equipment, a strict safety procedure should be in place and work should be performed under constant supervision; x Personnel training should be provided in revival techniques for victims of electric shock. Worker training on specific hazards associated with laser lights, including the various classes of low and high power laser lights, and fiber management; Preparation and implementation of laser light safety and fiber management procedures which include: x Switching off laser lights prior to work initiation, when feasible x Use of laser safety glasses during live optical fiber systems installation x Prohibition of intentionally looking into the laser or fiber end or pointing it at another person x Restricting access to the work area, placing warning signs and labeling of areas with potential for exposure to laser radiation, and providing adequate background lighting to account for loss of visibility with the use of protective eyewear x Inspecting the work area for the presence of flammable materials prior to the installation of highpowered laser lights
Tyco EHS Manager B-1.2 (SEACOM S&E management representative) Construction H
9 9 9 9 9 9
Tyco EHS Manager B-1.2 (SEACOM S&E management representative) Construction H
9 9 9 9 9 9
16
Kenya
Egypt
Corporate
High Seas
Mozambique
Ref
Timeframe
Tanzania
S. Africa
Djibouti
Implementation of a medical surveillance program with initial and periodic eye examinations; x Avoiding exposure to fibers through use of protective clothing and separation of work and eating areas. Onshore activities Community Health and Safety ES20 General Site Hazards Restricting access to the site, through a combination of institutional and administrative controls, with a focus on high risk structures or areas depending on site-specific situations, including fencing, signage, and communication of risks to the local community. Removing hazardous conditions on construction sites that cannot be controlled effectively with site access restrictions, such as covering openings to small confined spaces, ensuring means of escape for larger openings such as trenches or excavations. See recommendations for the prevention and control of communicable and vector-borne diseases. Measures include: x medical checks to confirm they are fit or work x immunisation program/use of workers that are immunised against communicable diseases x educating project personnel and area residents on risks, prevention, and available treatment, and x provision of condoms. Education and awareness training Adoption of best transport safety practices across all aspects of project operations with the goal of preventing traffic accidents and minimizing injuries suffered by project personnel and the public. Measures should include: x Emphasizing safety aspects among drivers x Improving driving skills and requiring licensing of drivers x Adopting limits for trip duration and arranging driver rosters to avoid overtiredness x Avoiding dangerous routes and times of day to reduce the risk of accidents x Use of speed control devices (governors) on trucks, and remote monitoring of driver actions Regular maintenance of vehicles and use of manufacturer approved parts to minimize potentially serious accidents caused by equipment malfunction or premature failure.
9 9 9 9 9 9
ES21
Disease Prevention
A-4.3
Tyco EHS Manager
Contractors monthly reporting against the AP. Construction M Internal audit program
9 9 9 9 9 9
ES22
Traffic Safety
9 9 9 9 9 9
17
Kenya
Egypt
Table 2b. Project Wide Environmental and Social Action Plan (Offshore)
Location Landing Countries Issue/ potential impact Doc Ref. Responsible Party (organisation) Priority2 (H/M/L) Monitoring/ verification method Non-landing Cs
Corporate
High Seas
Mozambique 9 9
Ref
Timeframe
Tanzania
S. Africa
Djibouti
Offshore activities Environmental ES23 General management Implement good management practices through the development of a social and environmental management system (SEMS), including: x grievance procedures x audit programme x stakeholder engagement plan x monitoring plan x training programme x etc. Details of these practices are captured in the Social and Environmental Procedures SEP01 SEP08, which form part of the SEMS. Offshore cable routes selected to minimize adverse impacts by preferential selection of a route that: x uses existing utility corridors (where appropriate) x avoids environmental sensitivities (coral reefs, seagrasses, breeding areas or protected areas) x avoids other sensitivities (other commercial and recreational use) A desk-top study and marine survey are required to inform the selected route. Locate noise generating sources away from noise-sensitive receptors. Use of noise suppression shields and mufflers Comply with noise emission levels provided in IFC General EHS Guidelines. Plan activities in consultation with local communities so that activities with the greatest potential to generate noise are planned during periods of the day that will result in least disturbance.
Construction and Operations
ES24
Route selection (offshore)
SEACOM S&E management representative.
Construction
ES25
Noise and Vibration
Tyco EHS Manager B-1.1 A-4.1 (SEACOM S&E management representative) Construction M
Tycos monthly reporting against the AP. Facility audit (vessel)
See definitions for priority in Table 1.
18
Kenya 9 9
Egypt
Corporate
High Seas
Mozambique 9 9
Ref
Timeframe
Tanzania
S. Africa
Djibouti
ES26
Air Quality
Managing emissions from mobile sources according to IFC EHS Guidelines for Shipping and MARPOL 73/78 Annex VI, Prevention of air pollution from ships.
Tyco EHS Manager M, I (SEACOM S&E management representative) Construction M
ES27
Solid Waste
Utilise techniques for preventing and controlling non-hazardous and hazardous construction site solid waste. Waste management practices to include: x Establishing waste management priorities at the outset of activities based on an understanding of potential Environmental, Health, and Safety (EHS) risks and impacts and considering waste generation and its consequences x Establishing a waste management hierarchy that considers prevention, reduction, reuse, recovery, recycling, removal and finally disposal of wastes. x Avoiding or minimizing the generation waste materials, as far as practicable x Where waste generation cannot be avoided but has been minimized, recovering and reusing waste x Where waste can not be recovered or reused, treating, destroying, and disposing of it in an environmentally sound manner Minimizing hazardous waste generation by implementing stringent waste segregation to prevent the commingling of non- hazardous and hazardous waste to be managed. Ensuring that contractors handling, treating, and disposing of hazardous waste are reputable and legitimate enterprises, licensed by the relevant regulatory agencies and following good international industry practice for the waste being handled. Ensuring compliance with applicable local and international regulations (including Basel Convention on the Control of Transboundary Movements of Hazardous Waste and their disposal).
Tyco EHS Manager A-4.1 H, M (SEACOM S&E management representative) Construction M
19
Kenya 9 9
Egypt
Corporate
High Seas
Mozambique 9 9
Ref
Timeframe
Tanzania
S. Africa
Djibouti
ES28
Solid Waste
Hazardous waste should be stored so as to prevent or control accidental releases to air, soil, and water resources in area location where waste is stored in a manner that prevents the commingling or contact between incompatible wastes, and allows for inspection between containers to monitor leaks or spills. Examples include: x sufficient space between incompatibles or physical separation such as walls or containment curbs. x Store in closed containers away from direct sunlight, wind and rain. x Secondary containment systems should be constructed with materials appropriate for the wastes being contained and adequate to prevent loss to the environment. x Secondary containment is included wherever liquid wastes are stored in volumes greater than 220 liters. The available volume of secondary containment should be at least 110 percent of the largest storage container, or 25 percent of the total storage capacity (whichever is greater), in that specific location. x Provide adequate ventilation where volatile wastes are stored. x Provision of spill containment and clean-up equipment (see hazardous materials below). Waste management practices should be monitored through regular audit of waste segregation and collection practices. In addition MARPOL 73/78 Annex V will apply to the management of solid wastes. Develop a waste management procedure that aims to manage wastes by minimising waste generation as far as possible, adopting the waste management hierarchy and disposing/treating wastes in an environmentally sound manner. Manage waste in accordance with MARPOL 73/78. Annex V will apply to the management of solid wastes. Annex V prohibits the disposal to sea of any plastics whilst restricting the discharge of other non hazardous waste in coastal waters and in designated Special Areas. Other specific requirements include: x development of a Garbage Management Plan and Garbage Record Book for all ships of 400 gross tonnage and above and every ship certified to carry 15 persons or more. x Restrictions on the disposal of wastes at sea depending on the nature of the waste and proximity to coastal waters or special areas. For example, disposal of comminuted food wastes is
Tyco EHS Manager A-4.1 H (SEACOM S&E management representative) Construction M
ES29
Solid wastes (MARPOL)
Tyco EHS Manager H, M (SEACOM S&E management representative) Construction M
20
Kenya 9 9
Egypt
Corporate
High Seas
Mozambique 9 9 9
Ref
Timeframe
Tanzania
S. Africa
Djibouti
prohibited within 3 miles of land (outside of special areas) and prohibited within 12 miles if non comminuted (inside special areas). Note. The Red Sea is categorised as special areas for wastes under Annex V. Hazardous wastes should be stored on board the vessel until it can be disposed at a suitably equipped port, respecting the requirements of the Basel Convention on Transboundary Shipment of Hazardous Wastes. ES30 Hazardous Materials Establish management programs that are commensurate with the potential risks present, including: x Provision of adequate secondary containment for fuel storage tanks and for the temporary storage of other fluids such as lubricating oils and hydraulic fluids. x Training workers on the correct transfer and handling of fuels and chemicals and the response to spills. x Preparation of a spill response plan. x Provision of on board portable spill containment and cleanup equipment and training in the deployment of equipment. x Provision of suitable personal protection equipment (see also Section 2b). Compliance with MARPOL 73/78 Annex I, Prevention of pollution by oil and Annex II, Prevention of pollution any noxious liquid substances. Hazardous materials should be securely stored and have appropriate signage. They should also be accompanied with accessible MSDSs. Locating and siting cable routes, and shore access, to avoid critical marine habitats, such as coral reefs and breeding grounds. Burying submarine cables when traversing sensitive intertidal habitat. Monitoring cable laying path for presence of marine mammals. Avoiding laying of submarine cable during fish and marine mammals breeding periods, calving periods, and spawning seasons.
A-4.1 E F
ES31
Hazardous materials Aquatic Habitat Alteration
Tyco EHS Manager
Construction
Contractors monthly reporting against the AP
ES32
Tyco EHS Manager B-1.1 G (SEACOM S&E management representative) Construction H
Tycos monthly reporting against the AP Facility audit (vessel)
21
Kenya 9 9 9
Egypt
Corporate
High Seas
Mozambique 9 9 9 9 9
Ref
Timeframe
Tanzania
S. Africa
Djibouti
ES33
Aquatic habitat alteration Exposure of the cable at shore crossings
Where coral reef is unavoidable, the cable shall be laid on the surface, minimizing impacts to the reef.
Tyco EHS Manager
Construction
Tycos monthly reporting against the AP
ES34
ES35
Exposed cable
ES36
Aqueous discharges (excluding ballast)
ES37
Ballast water management
At all shore crossings the cable shall be buried, either by standard cable lay construction techniques or by special measures. Such special measures include locating the cable in a shallow channel backfilled with an appropriate inert material e.g. concrete to secure the cable and prevent subsequent exposure where the cable shore crossing intersects areas of hard substrate (e.g. wave cut platforms). Implement a Post lay inspection and burial (PLIB) survey to ensure cable is properly buried. Periodic monitoring, particularly in high energy environments where there is a known risk of cable exposure. Implement requirements of relevant international shipping conventions including MARPOL Annex IV, Prevention of Pollution by sewage from ships, including: x No sewage shall be discharged from marine vessels within 4 nautical miles (7 km) of the nearest land, and any sewage discharged between 4 and 12 nautical miles (21 km) shall be macerated and disinfected. Sewage treatment equipment shall be regularly inspected and maintained to ensure optimum operation. x Sewage/grey water from cable lay vessels shall be treated to reduce the concentration of organic material prior to discharges. Food wastes from vessels shall be macerated and discharged to sea. x Potentially contaminated drainage, including drainage from machinery spaces and bilges, shall be treated with an oil/water separator to ensure that oil concentrations meet the standard of 15 ppm maximum without dilution prior to discharge. A ballast water management plan to minimise the potential for the introduction of non native species by project vessels traffic shall be developed and implemented. Where applicable, ballast water will be managed in accordance with the IMO guidelines for the control and management of ships ballast water to minimize the transfer of harmful aquatic organisms and pathogens and the International Convention for the Control and Management of Ships Ballast waters and sediments. Measures should include: x Minimising uptake of harmful organisms. x Minimising the release of ballast water.
Tyco EHS Manager
Construction
Contractors monthly reporting against the AP.
Tyco EHS Manager
Construction and Operation
Tycos monthly reporting against the AP
Tyco EHS Manager B-1.1 G, M (SEACOM S&E management representative) Construction M
Tycos monthly reporting against the AP Facility audit (vessel)
Tyco EHS Manager C, D, M (SEACOM S&E management representative) Construction H
22
Kenya 9 9 9 9 9
Egypt
Corporate
High Seas
Mozambique 9 9 9 9
Ref
Timeframe
Tanzania
S. Africa
Djibouti
ES38
Use of Antifoulants
Routine cleaning of ballast tanks to remove sediment. Implement least environmentally harmful ballast water exchange measures with consideration given to deep water exchange (or inline with regional agreements) or discharge to reception facilities. Ballast water management practices should be recorded (dates, locations, volumes of ballast water exchanged). Cable lay vessels should not be treated with harmful organotin (e.g. TBT) antifouling coatings in line with the International Convention on the Control of Harmful Anti-fouling Systems on Ships and the IFC EHS guideline for shipping, 2007.
x x
Tyco EHS Manager L, D (SEACOM S&E management representative)
Construction and Operations M
Tycos monthly reporting against the AP. Facility audit (vessel) 9 9 9 9 9 9 9
ES39
Impacts from cable repair/ replacement
ES40
Turbidity
Environmental management during repair/maintenance will generally be the same as for construction, with the following additional measures: x Excess cable will be minimized. x Damaged cable on the seabed will be recovered where practical x In coral areas, a dive survey will determine the extent that the cable is encapsulated by coral. Where recovery will damage the coral, the damaged cable will be left in situ. Turbidity will be minimsed during cable lay operations by minimising the duration and extent of physical seabed disturbance using a sea plough method where possible (in preference to jetting) to reduce release of loose sediments
Tyco EHS Manager J (SEACOM S&E management representative) Tyco EHS Manager J (SEACOM S&E management representative) Construction M Operations M
Tycos monthly reporting against the AP.
ES41
Impact on other users
Cables will be positioned in existing corridors/exclusion zones where possible. Cables will be buried in water depths of less than 1000m to prevent entanglement with fishing nets and anchors (and marine mammals). Slack cable will be minimised. Other commercial users will be avoided e.g. oil and gas concession areas. Desk-top study and marine survey works are required to inform the selected route.
Tyco EHS Manager J (SEACOM S&E management representative) Construction M
23
Kenya 9 9 9
Egypt
Corporate
High Seas
Mozambique 9 9 9 9
Ref
Timeframe
Tanzania
S. Africa
Djibouti
ES42
Cable repair/ replacement
Use of state of the art armoured cable design in high energy abrasive locations. Use of divers, rather than grapnel, in sensitive areas (coral reefs) to locate the cable where possible.
Tyco EHS Manager J (SEACOM S&E management representative) Construction M
ES43
Decommissio ning cable recover
Decommissioning should be carried in accordance with ICPC recommendations and applicable industry practice at the end of the Projects lifespan. Specific measures shall be formulated within a decommissioning plan produced at least 6 months prior to the Projects end of life. The approach is likely to be decided on a case by case situation taken technical, safety and environmental issues into consideration. Cable left in situ should have its end weighted and buried to reduce the chances of snagging. Where recovered, cable components should be recycled if possible. Non recyclable components should be disposed in accordance with good waste management practices (see Solid Waste) Fishing representatives to be informed of cable laying schedule and exclusion zones.
Decommissio -ning
Offshore activities Social ES44 Commercial fisheries
Tyco EHS Manager J (SEACOM S&E management representative) Tyco EHS Manager (SEACOM S&E management representative) Tyco EHS Manager K (SEACOM S&E management representative) Construction and operations H Construction H
Tycos monthly reporting against the AP. Internal audit program Tycos monthly reporting against the AP. Internal audit program
ES45
Other users
Community stakeholders to be informed of cable laying schedule and exclusion zones. J
Construction
ES46
Labour issues
All contractors will comply with relevant requirements of the International Labour Organisation (ILO) to avoid use of child or forced labour. Specifically this includes compliance with: x ILO Forced Labour Convention, No 29 1930 x x ILO Abolition of Forced Labour Convention, No 105 1957 ILO Right to Organise and Collective Bargaining Convention. No. 98.1949
24
Kenya 9 9 9 9
Egypt
Corporate
High Seas
Mozambique 9 9
Ref
Timeframe
Tanzania
S. Africa
Djibouti
x x x x x x
ILO Equal Remuneration Convention. No. 100 1951 ILO Discrimination (Employment and Occupation) Convention, No. 111 1958 ILO Minimum Age Convention, No.138 1973 ILO Worst forms of Child Labour Convention, No. 182 1999 ILO Convention 87 on Freedom of Association and Protection of the Right to Organize UN Convention on the Rights of the Child, Article 32.1, 1989
Offshore activities Occupational Health and Safety OHS11 Over-exertion x Training of workers in lifting and materials handling techniques in construction projects, including the placement of weight limits above which mechanical assists or two-person lifts are necessary. x Planning work site layout to minimize the need for manual transfer of heavy loads. x Selecting tools and designing work stations that reduce force requirements and holding times, and which promote improved postures, including, where applicable, user adjustable work stations. x Implementing administrative controls into work processes, such as job rotations and rest or stretch breaks. Implementing good house-keeping practices, such as the sorting and placing loose construction materials debris in established areas away from walkways. Cleaning up excessive waste debris and liquid spills regularly. Locating electrical cords and ropes in common areas and marked corridors. Use of slip retardant footwear.
Construction and Operations H
OHS12
Slips and Falls
25
Kenya 9 9
Egypt
Corporate
High Seas
Mozambique 9 9
Ref
Timeframe
Tanzania
S. Africa
Djibouti
OHS13
Work in Heights
OHS14
Struck by Objects
Development of a fall protection plan which includes one or more of the following aspects, depending on the nature of the fall hazard: x Training and use of temporary fall prevention devices, such as rails or other barriers able to support a weight of 200 pounds, when working at heights equal or greater than two meters or at any height if the risk includes falling into operating machinery, into water or other liquid, into hazardous substances, or through an opening in a work surface. x Training and use of personal fall arrest systems, such as full body harnesses and energy absorbing lanyards able to support 5000 pounds, as well as fall rescue procedures to deal with workers whose fall has been successfully arrested. The tie in point of the fall arresting system should also be able to support 5000 pounds. x Use of control zones and safety monitoring systems to warn workers of their proximity to fall hazard zones, as well as securing, marking, and labeling covers for openings in floors, roofs, or walking surfaces. Using a designated and restricted waste drop or discharge zones, and/or a chute for safe movement of wastes from upper to lower levels. Conducting sawing, cutting, grinding, sanding, chipping or chiseling with proper guards and anchoring as applicable. Maintaining clear traffic ways to avoid driving of heavy equipment over loose scrap. Use of temporary fall protection measures in scaffolds and out edges of elevated work surfaces, such as hand rails and toe boards to prevent materials from being dislodged. Wearing appropriate PPE, such as safety glasses with side shields, face shields, hard hats, and safety shoes.
Tycos monthly reporting against the AP. Facility audit (vessel).
26
Kenya 9 9
Egypt
Corporate
High Seas
Mozambique 9 9 9
Ref
Timeframe
Tanzania
S. Africa
Djibouti
OHS15
Moving Machinery
Planning and segregating the location of machine operation, and walking areas. Ensuring the visibility of personnel through their use of high visibility vests when working in or walking through heavy equipment operating areas, and training of workers to verify eye contact with equipment operators (e.g. cranes) before approaching the operating vehicle. Using inspected and well-maintained lifting devices that are appropriate for the load, such as cranes, and securing loads when lifting them to higher job-site elevations. Dust suppression techniques should be implemented, such as dust masks, where dust levels are excessive. A-4.2 Tyco EHS Manager A-4.2 (SEACOM S&E management representative) Construction and Operations maintenance H Tycos monthly reporting against the AP. Facility audit (vessel)
OHS16
Dust
Tyco EHS Manager (SEACOM S&E management representative)
Construction H
OHS17
Electrical Safety
Only allowing trained and certified workers to install, maintain, or repair electrical equipment; Deactivating and properly grounding live power distribution lines before work is performed on, or in close proximity to, the lines; Ensuring that live-wire work is conducted by trained workers with strict adherence to specific safety and insulation standards. Qualified or trained employees working on transmission or distribution systems should be able to achieve the following: x Distinguish live parts from other parts of the electrical system x Determine the voltage of live parts x Understand the minimum approach distances outlined for specific live line voltages x Ensure proper use of special safety equipment and procedures when working near, or on, exposed energized parts of an electrical system x Workers should not approach an exposed, energized or conductive part even if properly trained unless: x The worker is properly insulated from the energized part with gloves or other approved insulation; or x The energized part is properly insulated from the worker and any other conductive object; or
Tyco EHS Manager B-1.2 (SEACOM S&E management representative)
27
Kenya 9 9 9
Egypt
Corporate
High Seas
Mozambique 9 9
Ref
Timeframe
Tanzania
S. Africa
Djibouti
OHS18
Optical Fiber Safety
OHS19
Safety at sea
The worker is properly isolated and insulated from any other conductive object (live-line work) Where maintenance and operation is required within minimum setback distances, specific training, safety measures, personal safety devices, and other precautions should be defined in a health and safety plan; x Recommendations to prevent, minimize and control injuries related to electrical shock, as presented in IFC EHS Guidelines -Telecoms section 1.2 Worker training on specific hazards associated with laser lights, including the various classes of low and high power laser lights, and fiber management; Preparation and implementation of laser light safety and fiber management procedures which include: x Switching off laser lights prior to work initiation, when feasible x Use of laser safety glasses during live optical fiber systems installation x Prohibition of intentionally looking into the laser or fiber end or pointing it at another person x Restricting access to the work area, placing warning signs and labeling of areas with potential for exposure to laser radiation, and providing adequate background lighting to account for loss of visibility with the use of protective eyewear x Inspecting the work area for the presence of flammable materials prior to the installation of highpowered laser lights Implementation of a medical surveillance program with initial and periodic eye examinations; Avoiding exposure to fibers through use of protective clothing and separation of work and eating areas. Project vessels will safely operate in accordance with the requirements of : x International Loadline Convention, 1966 x International Convention on Standards of Training Certification and Watchkeeping for Seafarers (STEW), and x Convention on the International Regulations for Preventing Collisions at Sea, (COLREGs).
Tyco EHS Manager B-1.2 (SEACOM S&E management representative)
Tyco EHS Manager J (SEACOM S&E management representative)
Construction and Operations H Facility audit (vessel) 9 9 9 9 9 9 9
28
Kenya 9
Egypt
Corporate
High Seas
Mozambique 9 9 9
Ref
Timeframe
Tanzania
S. Africa
Djibouti
x Training of workers in lifting and materials handling techniques in construction projects, including the placement of weight limits above which mechanical assists or two-person lifts are necessary. x Planning work site layout to minimize the need for manual transfer of heavy loads. x Selecting tools and designing work stations that reduce force requirements and holding times, and which promote improved postures, including, where applicable, user adjustable work stations. Implementing administrative controls into work processes, such as job rotations and rest or stretch breaks. Offshore activities Community Health and Safety OHS20 General seagoing operations ES47 General Hazards Restricting access to the work area, through a combination of institutional and administrative controls, with a focus on high risk areas depending on specific situations, including communication of risks to the local community
Tyco EHS Manager M (SEACOM S&E management representative)
Construction and Operations H Facility audit (vessel) 9 9 9 9 9 9 9
Tyco EHS Manager A-4.3 (SEACOM S&E management representative) Tyco EHS Manager J (SEACOM S&E management representative)
Construction and Operations M Facility audit (vessel) 9 9 9 9 9 9 9
ES48
Risk to fishing and other vessels
Fishermen and other sea users will be informed about the location of the cables. An exclusion zone will be established where for fishing and anchoring will be prohibited. Cables routes and exclusion areas will be clearly marked on navigational charts. The cable will be buried where possible in water depths of up to 1000m to reduce the risks of snagging and therefore risk to human safety.
Pre Operations
29
Kenya 9
Egypt
Annex 1 Country-Specific Action Plans & SEACOM Regulatory Approval Documentation
South Africa - Environmental Action Plan
Draft Environmental Management Plan
Proposed Installation of the SEA Cable System, KwaZulu-Natal North Coast, South Africa
(EIA reference number: 12/12/20/1100)
Report prepared for
SEACOM Ltd.
Report No. 386520

August 2008
SRK Consulting SEA Cable System Draft EMP
Page i
Draft Environmental Management Plan Proposed Installation of the SEA Cable System, KwaZulu-Natal North Coast, South Africa
(EIA reference number: 12/12/20/1100)
SEACOM Ltd. SRK Consulting

2A IBM House 54 Norfolk Terrace Westville, 3630 South Africa
P O Box 1969 Westville 3630 South Africa
Tel: (031) 279-1200 Fax: (031 279-1204
mvahuyssteen@srk.co.za
August 2008
Compiled by: M. van Huyssteen L. Allan _________________________ Project Consultants _________________________ Partner Reviewed by: V.S. Reddy
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August 2008
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Table of Contents
1 Introduction and Scope of Report ................................................................................ 2 2 General objectives and purpose of the EMP ............................................................... 2 3 Roles and responsibilities ............................................................................................. 2 4 Legislative Requirements .............................................................................................. 5 5 Construction / installation EMP .................................................................................... 5
5.1 General terrestrial construction (i.e. Cable station) ............................................................. 6
5.1.1 5.1.2 5.1.3 5.1.4 5.1.5 5.1.6 5.1.7 5.1.8 5.1.9 5.1.10 5.1.11 5.1.12 5.1.13 5.1.14 5.1.8 5.1.9 5.1.10 5.1.11 5.1.12 5.1.13 5.1.14 5.1.15 5.1.16 5.1.17 5.1.18 5.1.19 5.1.20 5.1.21 5.1.22 5.1.23 5.1.24 5.1.25 5.1.26 5.1.27 5.1.28 5.1.29 5.2.1 5.2.2 5.2.3 5.2.4 5.2.5 5.2.6 5.2.7 5.2.8 5.2.9 5.2.10
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Method Statements ............................................................................................................... 6 Construction initiation ............................................................................................................ 6 Labour .................................................................................................................................. 6 Worker Conduct on Site ........................................................................................................ 7 Safety ................................................................................................................................... 7 Security ................................................................................................................................. 8 Construction Camp ............................................................................................................... 8 Ablution facilities ................................................................................................................... 9 Eating / break areas .............................................................................................................. 9 Waste management ............................................................................................................ 10 Vegetation management ..................................................................................................... 10 Wildlife Management .......................................................................................................... 11 No go Areas ..................................................................................................................... 11 Surface and ground water management ............................................................................. 11 Soil ...................................................................................................................................... 12 Excavation .......................................................................................................................... 13 Stockpiles ........................................................................................................................... 13 Importation of fill/ soil/ sand materials ................................................................................. 14 Materials Delivery ............................................................................................................... 14 Storage Areas ..................................................................................................................... 14 Hazardous Substances and Materials................................................................................. 15 Fuel Storage and Dispensing .............................................................................................. 15 Concrete and Cement Batching .......................................................................................... 16 Maintenance ....................................................................................................................... 16 Dust .................................................................................................................................... 17 Erosion................................................................................................................................ 17 Traffic .................................................................................................................................. 18 Access ................................................................................................................................ 18 Noise .................................................................................................................................. 19 Visual Impact ...................................................................................................................... 19 Heritage Resources ............................................................................................................ 20 Social .................................................................................................................................. 20 Fire Control ......................................................................................................................... 20 Rehabilitation ...................................................................................................................... 21 Daily Site Closure ............................................................................................................... 21 Post Construction Activities................................................................................................. 22 Method Statements ............................................................................................................. 23 Discharge of drilling fluid ..................................................................................................... 23 On-site observations during construction ............................................................................ 23 Response to inadvertent returns ......................................................................................... 24 Containment ....................................................................................................................... 25 Notification .......................................................................................................................... 26 Clean-up ............................................................................................................................. 26 Umlalazi Nature Reserve protocol....................................................................................... 27 Beach access and trenching ............................................................................................... 27 Public beach use................................................................................................................. 28
386520-alle-Draft_EMP August 2008
5.2 HDD and beach trenching ................................................................................................. 23
Page iii
5.2.11 Post construction activities .................................................................................................. 28
5.3 Offshore installation ........................................................................................................... 29

5.3.1 5.3.2 5.3.3 5.3.4 5.3.5 5.3.6 5.3.7 5.3.8 5.3.9 5.4.1 5.4.2 Method Statements ............................................................................................................. 29 Marine Environment ............................................................................................................ 29 Shallow water cable laying .................................................................................................. 30 Deep marine waters ............................................................................................................ 30 Aqueous discharges (excluding ballast) .............................................................................. 31 Ballast water management.................................................................................................. 31 Turbidity .............................................................................................................................. 31 Commerical fisheries .......................................................................................................... 32 Safety at sea ....................................................................................................................... 32 Optical Fiber Safety ............................................................................................................ 32 Electrical Safety .................................................................................................................. 32
5.4 Fibre Optic Safety .............................................................................................................. 32
6 Auditing ......................................................................................................................... 33 7 Corrective action .......................................................................................................... 33 8 Amendments ................................................................................................................. 34 SRK Report Distribution Record ...................................................................................... 36
List of Tables
Table 3.1: Roles and Responsibilities ................................................................................................ 3
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Section A, 2nd Floor IBM House 54 Norfolk Terrace, off Blair Atholl Drive 3630 WESTVILLE PO Box 1969 3630, WESTVILLE e-Mail: durban@srk.co.za URL: http://www.srk.co.za Tel: +27 (0) 31 279 1200 Fax: +27 (0) 31 279 1204
August 2008 386520 Draft Environmental Management Plan: Proposed Installation of the SEA Cable System, KwaZulu-Natal North Coast, South Africa
Introduction and Scope of Report

Neotel (Pty) Ltd. on behalf of SEACOM Ltd. (SEACOM) recently applied for authorisation, in terms of the Environmental Impact Assessment (EIA) Regulations as promulgated under the National Environmental Management Act (No. 107 of 1998) (NEMA), for the installation of the SEA Cable System, KwaZulu-Natal north coast, South Africa. The EIA being undertaken by SRK includes activities related to the proposed new fibre-optic telecommunications cable that is proposed to land on the beach within the Umlalazi Nature Reserve, Mtunzini. The SEA Cable System would decrease the monetary cost of bandwidth to several countries along the east African coastline, thus benefiting business, institutions, communities and individuals. The intention of this Environmental Management Plan (EMP) is to ensure that the installation of the SEA Cable System is undertaken in a controlled and organised manner, thereby managing and minimising potential environmental impacts during this phase of the life of the cable. A precautionary approach has been adopted in this EMP and mitigation measures and recommendations identified during the course of the EIA process are included to ensure they are adopted and implemented. In addition, the EMP is designed to assist SEACOM/Neotel and their contractor/s to plan and implement effective site-specific strategies that will minimise the environmental impacts associated with installation and operation and maintain compliance with environmental legislative requirements.
Partners JCJ Boshoff, MJ Braune, JM Brown, JAC Cowan, CD Dalgliesh, JR Dixon, DM Duthe, T Hart, PR Labrum, DJ Mahlangu, RRW McNeill, HAC Meintjes, BJ Middleton, MJ Morris, GP Murray, GP Nel, VS Reddy, PN Rosewarne, PE Schmidt, PJ Shepherd, VM Simposya, AA Smithen, PJ Terbrugge, KM Uderstadt, DJ Venter, HG Waldeck, A Wood Directors AJ Barrett, S Mayekiso, BJ Middleton, MJ Morris, PE Schmidt, PJ Terbrugge Associates AN Birtles, BM Engelsman, R Gardiner, WC Joughin, SA McDonald, WA Naismith, D Visser, AC White, ML Wertz Consultants AC Burger, BSc (Hons); IS Cameron-Clarke, PrSci Nat, MSc; JH de Beer, PrSci Nat, MSc; GA Jones, PrEng, PhD; MEng, TR Stacey, PrEng, DSc; OKH Steffen, PrEng, PhD; RJ Stuart, PrTech Eng, GDE; DW Warwick, PrSci Nat, BSc (Hons) Corporate Shareholder: Kagiso Enterprises (Pty) Ltd SRK Consulting (South Africa) (Pty) Ltd Reg No.: 1995.012890.07 Cape Town Durban East London Johannesburg Kimberley Pietermaritzburg Port Elizabeth Pretoria Rustenburg Dar-es-Salaam Harare +27 (0) 21 659 3060 +27 (0) 31 279 1200 +27 (0) 43 748 6292 +27 (0) 11 441 1111 +27 (0) 53 861 5798 +27 (0) 33 345 6311 +27 (0) 41 581 1911 +27 (0) 12 361 9821 +27 (0) 14 594 1280 +25 (5) 22 260 1881 +263 (4) 49 6182
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General objectives and purpose of the EMP

The objective of the EMP is to mitigate and manage construction activities relating to the installation of the SEA Cable System in order to minimise the impacts on the surrounding environment. This EMP serves as a stand-alone document to be disseminated to and used by the contractor/s during the construction phase of the SEA Cable System. By its very nature, the EMP is a dynamic document and updating may be required. The purpose of the EMP is to:
x x x x
Outline SEACOM/Neotels environmental management commitments for the site during construction; Ensure adherence to all relevant environmental, health and safety legislation; Act as a performance standard that activities can be audited against; and Ensure that appropriate monitoring is undertaken.
SEACOM/Neotel is responsible for ensuring adherence to the conditions detailed in the EMP and the environmental authorisation issued by the DEAT. The project manager, contractor(s) etc., are all bound to the EMP and must use this document as a guide to minimise and manage environmental impacts.
Roles and responsibilities

The successful implementation of this EMP requires co-operation between the various parties involved in Project construction, and particularly between the project proponents (SEACOM/Neotel) and the Project contractors. Key personnel for EMP implementation are SEACOM/Neotels appointed project manager, the contractor(s) construction manager, sub contractor(s) construction manager, the SEACOM/Neotel occupational health and safety officer (HSO) and the SEACOM/Neotel environmental manager (EM). [Note: The identified roles and responsibilties of the HSO, as well as the EM, may be delegated to individuals that share various other responsibilities within the construction programme]. The general roles and responsibilities for various personnel are outlined within this document. x SEACOM/Neotels EM and/or HSO must ensure that the mitigation measures and other requirements set forth in the EMP are adhered to. The EM should undertake regular compliance inspections and should provide regular feedback to the project manager (e.g. at weekly/monthly planning meetings) and SEACOM/Neotel management. The SEACOM/Neotel project manager, in conjunction with the EM shall ensure that all staff, contractor construction managers, sub contractor, suppliers, etc. are familiar with, understand and adhere to the EMP. The project manager, although holding the ultimate responsibility for
386520-alle-Draft_EMP August 2008
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all construction operations through the construction lifecycle, will have the authority to delegate activities to contractor construction managers as seen fit/appropriate. The EM, any formally appointed external auditor or DEAT compliance officer may bring any instance of EMP non-compliance to the attention of the SEACOM/Neotel project manager, who is obliged to take immediate action to correct the non-compliance. If the instance of non-compliance cannot be immediately corrected, the project manager is obliged to order the immediate cessation of the work activities associated with the non-compliance, until such time as work can resume in full compliance with the provisions of the EMP.. The table below outlines, but does not limit, the main roles and responsibilities for all the parties involved in the installation of the cable system. Table 3.1: Roles and Responsibilities
Responsible Agent
SEACOM/Neotel
Role / Responsibility
x
Responsible for compliance with the provisions for duty of care and remediation of damage in accordance with Section 28 of the National Environmental Management Act (NEMA), (No. 107 of 1998) and its obligations regarding the control of emergency incidents in terms of Section 30 of NEMA. Notify the DEAT of any incident as defined in subsection 30(1) (a) of NEMA. Continue to build relations with the local community, businesses and organisations. Appoint appropriately qualified Contractor to co-ordinate, supervise and expedite the different tasks. standards relevant to the operation of the cable.
x x x
x Ensure adherence to the DEAT conditions of authorisation and any other laws and x
SEACOM/Neotel Project Manager (PM) Ensure all facets of the work undertaken are properly and competently directed, guided and executed.
x Overall responsibility and accountability for the site during the construction phase. x Construction of the facility to contractual specifications. x Responsible and accountable to the PM for all contractor and sub-contractor site
activities during the installation of the cable.
Contractor Construction Manager and SubContractor Construction Manager
x Manage and operate their organisations activities with due care and diligence. x Avoid and/or limit any adverse impacts their organisations may have on the
environment by the proper design and implementation of the required machinery.
x Report back to the PM on issues / non-conformances. x Control predicted impacts that may occur so as to meet acceptable standards, both as
a legal and a moral responsibility to the environment within which their organisations operate.
x Ensure transparency in their organisations operation and environmental management. x Ensure that all facets of the work undertaken are properly and competently directed,
guided and executed.
x Ensure adherence to laws and standards relevant to the development of the cable
system.
x Ensure adherence to the DEAT conditions of authorisation. x Ensure adherence to statutory safety, health and environment (SHE) standards and
ensure their organisations activities comply with the EMP.
x Implement any new mitigation measures or amendments to existing mitigation

measures so as to address areas of concern, as necessary.
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Responsible Agent
SEACOM/Neotel Environmental Manager (EM)
Role / Responsibility
x Determination of the conformance of the site with the EMP criteria and compliance with
the DEAT conditions of authorisation.
x Liaison person with the DEAT, ECA and IAPs, if required. x Identification of possible areas of improvement. x Assessment of the suitability or effectiveness of the EMP. x Undertake ongoing monitoring of the site through regular site visits and record key
findings. This includes photographic monitoring.
x Monitor implementation of the EMP by the contractor/s. x Advise the PM on actions or issues impacting on the environment and provide
appropriate recommendations to address and rectify these matters.
x Ensure that the contractor/s has a copy of the EMP and all agreed Method Statements. x Ensure that the conditions stipulated in the DEAT conditions of authorisation and any
other laws and standards relevant to the project are being complied with.
x Update and revise the EMP as necessary in liaison with IAPs and other affected parties
and authorities as required.
x The EM shall advise the PM to suspend part or all of the works if the contractor and/or
any sub-Contractor, suppliers, etc. fail to comply with both the EMP and establishment procedures supplied (which are to be agreed upon between the contractor and PM prior to construction). Environmental Compliance Auditor (ECA)
x A suitably qualified and experienced independent environmental consultant/auditor to

undertake audits of construction activities to ensure compliance with this EMP, the environmental authorisation and any other relevant legislation.
x Submission of audit reports to the DEAT and DAEA. x Advise the EM, PM and/or SEACOM/Neotel on actions or issues impacting on the
environment and provide appropriate recommendations to address and rectify these matters.
x Assess suitability of the EMPs effectiveness and identify possible areas of

improvement. Health and Safety Officer (HSO)
x Provide support to the PM in monitoring the execution of the EMP with respect to health
and safety.
x Undertake routine site inspections and provide information to EM. x Monitoring activities as specified by the EMP. x Immediately
investigate any recommendations to the PM. lost-time accidents, and provide report and
x Maintain incident register and report back at monthly site meetings.
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Legislative Requirements
The installation of the SEA Cable System constitutes a listed activity under NEMA and, as such, an environmental impact assessment (EIA) was undertaken for the project. SEACOM/Neotel is responsible for compliance with the provisions for duty of care and remediation of damage in accordance with Section 28 of NEMA and its obligations regarding the control of emergency incidents in terms of Section 30. Accordingly, the DEAT must immediately be notified of an incident as defined in subsection 30(1) (a) of NEMA. The implementation of a construction EMP for the proposed activity is a requirement of the NEMA EIA Regulations and is likely to similarly be a condition in the Environmental Authorisation (assuming such), issued by the DEAT. As such, failure to comply with this EMP will constitute an offence and SEACOM/Neotel and/or their Contractor may be liable to penalties and/or legal action. Therefore, it is important for all the responsible parties to understand their duties and undertake them with duty and care.
Construction / installation EMP

The EMP tabulated below details the potential impacts and mitigation measures identified for the project and delegates responsibilities for implementation of the mitigation activities. The establishment of the necessary infrastructure and machinery on site will be done by Contractor who will be responsible for implementing the majority of the activities under the management of the PM. All activities to be managed, mitigation and management measures to be implemented, and the responsible individuals/organisations who should implement these measures, are detailed in subsections which follow. This information is the core of this EMP and should be adhered to at all times. The subsections which follow may be updated as necessary.
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5.1
General terrestrial construction (i.e. Cable station)

5.1.1 Method Statements
The site establishment activities must be in accordance with the final design submitted (e.g. for the Cable Station). The following activities must be planned for and a method statement provided. The method statement must detail the activity and the procedure for fulfilling the required task to minimise impacts as a result of the procedure, relevant for terrestrial installation. a) b) c) d) e) Construction camp establishment (if required); Traffic management and access routes; Waste management; Storage of hazardous materials and emergency plans; and Fuels and fuel spills, including bentonite spills.
Implementation
Contractor Construction Manager, PM
Monitoring
EM / ECA
5.1.2 Construction initiation

a) b) c) d) e) Ensure all construction personnel are aware of the provisions contained in the EMP and environmental authorisation (i.e. construction induction); The working area must be clearly demarcated and no work should be done outside of the demarcated area unless discussed and agreed upon by the PM and EM; Designate and use only existing access roads to access the site; Inform personnel that encroachments into surrounding areas (i.e. beyond the demarcated construction area) will carry severe penalties; and The cable-laying process and timing could also be usefully described in the local Mtunzini media in order to inform as many people as possible.
Implementation
Contractor Construction Manager ; PM; EM
Monitoring
EM, ECA
5.1.3 Labour
All Contractors will comply with relevant requirements of the International Labour Organisation (ILO) to avoid use of child or forced labour. a) b) c) Where possible, award contracts to local businesses that are competitive in quality and price, to enhance direct benefits to the community; Where possible, hire members of the local community for job opportunities associated with the construction phase; and Ensure that there is a labour dispute mechanism in place in the event that such occurs.
Implementation
Contractor Construction Manager
Monitoring
EMECA
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5.1.4 Worker Conduct on Site

A general regard for the social and ecological well being of the site and adjacent areas is expected of the site staff. Workers need to be made aware of the following general rules: a) b) c) d) e) No alcohol / drugs are permitted on site; No firearms allowed on site, except for security personnel; Prevention of excessive noise and unsocial behavior; Trespassing on private properties adjoining the site is forbidden; and Other than any pre-approved security and construction staff, no workers are allowed to live on site.
Implementation
Monitoring
EM, ECA
5.1.5 Safety
Construction sites are potentially hazardous environments as the activities that take place can affect the health and safety of the workers. a) b) c) d) e) f) g) h) In the event of an emergency, the Contractor shall contact the emergency services in the area; Telephone numbers of emergency services, including the local fire fighting service, must be posted conspicuously on the construction site; Potentially hazardous areas, such as trenches, are to be demarcated with danger tape; Material stockpiles, such as pipes, must be stable and well secured to avoid collapse and possible injury; No materials are to be stored in unstable or high-risk areas, such as on steep slopes; Obstruction to drivers line of site due to stockpiles and stacked materials is to be avoided, especially at intersections and sharp corners; Flammable materials must be stored as far as possible from adjacent residents, and must be clearly marked and stored appropriately; and All Interested and Affected Parties (IAPs) shall be notified in advance (24 hrs) of any known potentially significant risks associated with the construction site and the activities on it.
Implementation
Contractor Construction Manager; EM
Monitoring
ECA
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5.1.6 Security
The site must be secured in order to reduce the opportunity for criminal activity both on, and in the locality of the construction site, and prevent access by the general public. a) b) c) d) e) f) The construction site must be fenced and manned to control the access of persons, including children and/or animals to the site; If necessary, a security service should be employed to monitor access to the site over weekends; The storage area shall be securely fenced by means of portable fences or danger tape; The integrity of the fencing must be regularly checked and any damage repaired; Where possible, construction equipment / materials are to be stored in locked immoveble containers within the storage area; and Employees may not loiter at the entrance to the site or on access roads.
Implementation
Monitoring
ECA
5.1.7 Construction Camp

a) Provide EM with a layout of the site indicating the position of all of the following, as applicable: ablution facilities, storage areas, ready-mix areas, stockpile areas, waste disposal facilities, hazardous substances storage area, etc. prior to the site establishment, for acceptance. Designate the boundaries of the active construction site at start-up by using barrier tape; Attend to drainage of the camp site to avoid standing water and / or sheet erosion; Designate and use only existing site entrances and roads to access the site; Inform personnel that encroachments into areas beyond the site boundary will carry severe penalties; Adequate parking must be provided for site staff. This must be incorporated into the site plan; All wastes should be collected and removed from the construction camp; and Food wastes will be contained in a manner that will not attract scavenging animals e.g. bins will have lids.
Implementation
Contractor Construction Manager; PM
Monitoring
ECA; EM
b) c) d) e) f) g) h)
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5.1.8 Ablution facilities

a) b) c) d) e) f) g) h) i) Ablution facilities must be available for all on site staff; Where waterborne sewerage is not available, the EM must designate an area within the boundaries of the site for the erection of portable chemical toilets. A company, as approved by SEACOM/Neotel, must then provide temporary chemical toilets; Toilet facilities shall occur at a minimum ratio of 1 toilet per 25 workers (preferred 1:15); Toilets must be located no less than 30 m from any natural water body; The construction of long drop toilets is forbidden; Under no circumstances may open areas or the surrounding vegetation be used as toilet facilities; All temporary / portable toilets shall be secured to the ground to the satisfaction of the EM to prevent them toppling due to wind or any other cause; The entrances to the toilets must be adequately screened from public view and, where possible, toilets should be positioned out of sight; and Toilets, permanent or portable/temporary, shall be maintained in a hygienic state and serviced regularly. Portable toilets, should they be required, should be serviced by a reputable contractor and the contents shall be removed to a licensed disposal facility. No spillage is to occur when portable toilets are cleaned or emptied.
Implementation
Monitoring
ECA; EM
5.1.9 Eating / break areas

a) b) c) An area must be designated for staff and workers to eat during breaks; The Contractor must ensure alternative arrangements for cooking and/or heating requirements, other than fires, are made available. LPG cookers can be used, provided all safety requirements are followed; and Sufficient weather and vermin proof bins shall be provided.
Implementation
Monitoring
EM
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5.1.10 Waste management

General waste
All general waste must be collected and disposed of at a terrestrial licensed landfill site. Appointing a reliable waste collection and recycling company is recommended. This will ensure that the waste is collected timeously and disposed of appropriately. a) b) c) d) e) f) Provide bins and / or skips at convenient intervals for disposal of waste. The bins must be of sufficient weight to ensure that they are not blown over by wind; Recycling and the provision of separate waste receptacles for different types of waste should be encouraged; Ensure bins are emptied daily / regularly and the contents disposed of to a licensed waste disposal facility. Proof of disposal (certificates / waybills) must be maintained for auditing purposes; Ensure that waste is not burned on site. This constitutes a serious offence; The excavation and use of rubbish pits is forbidden; and Littering on site or at sea is forbidden.
Implementation
Monitoring
EM; ECA
Hazardous waste
A waste control and removal system must be implemented for hazardous wastes in order to prevent pollution of the surrounding environment and to ensure appropriate disposal. a) b) Hazardous wastes must be separated from general wastes, stored separately in appropriate containers and disposed of at a licensed hazardous waste disposal facility or certified recycling facility; and Certificates of hazardous waste disposal (waybills) are to be retained for auditing purposes.
EM; ECA
5.1.11 Vegetation management

a) b) c) d) e) f) Vegetation clearing results in unprotected areas that are susceptible to erosion and therefore clearance must be kept to the absolute minimum, and if practically possible it should occur at the last instance prior to excavation and construction; The EM must approve and direct any clearing of vegetated areas within the construction site, and no clearing may occur without the EM being present; Protected and indigenous tree species in the vicinity of the construction site should be marked with danger tape. Wherever possible, disturbance to such species should be avoided; Where protected tree species are required to be relocated, trimmed or removed, permission for such will be applied for from the EKZNW and / or the Department of Water Affairs and Forestry (DWAF); Planting and re-planting of vegetation is to take place as soon as feasibly possible; and Care must be taken to avoid introducing alien plant species to the site and surrounding areas, and all areas that have been disturbed by construction activities must be cleared of alien vegetation.
Implementation
Monitoring
EM; ECA
Vhuy/Alle
August 2008
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5.1.12 Wildlife Management

a) Due to the sensitivity of the surrounding area and the abundance of wildlife (mammals, reptiles, birds, etc; )it must be ensured that excavation activities are undertaken with care to minimize the risk of wildlife injury or mortality during vegetation clearing and excavation; Killing, snaring or injury to animals are strictly prohibited; Should any wild animal (e.g. snakes) pose a threat to workers then the EM must be informed immediately. The PM will contact the relevant Contractor and / or authorities to address the situation (if required); and Should any animal habitat (e.g. for mammal, bird, reptiles other vertebrates) be found on the site, necessary arrangements must be made with the EM to relocate these animals.
Implementation
Monitoring
EM; ECA
b) c) d)
5.1.13 No go Areas
No Go areas include any area outside the boundary of the construction site and access route and are strictly out of bounds to theContractor and workers. a) b) c) Encroachment onto adjacent properties, Natures Way Backpackers and the Siyaya River is strictly forbidden (i.e. unless absolutely nessesary and with permission from relevant parties); Any, employees or representatives of the Contractor found outside of the construction site boundaries or reported seen outside the boundary, will face disciplinary action; and Encroachment on any area classified as a wetland, (classification as per the Department of Water Affairs and Forestrys guideline entitled A Practical field procedure for the identification and delineation of wetlands and riparian areas, Edition 1, September 2005), is strictly forbidden. Should such an area be found to exist, on or in close proximity to the site, a wetland specialist must be appointed to assist with the issue.
Implementation
Monitoring
EM; ECA
5.1.14 Surface and ground water management

Surface Contaminated Water: Water quality is affected by the incorrect handling of substances and materials resulting in spillages, soil erosion, and the mismanagement of polluted run-off. Discharge into natural drainage areas must therefore be controlled to prevent environmental effects downstream. a) b) The discharge of any pollutants such as cement, concrete, lime, chemicals and fuels into any water sources and the stormwater system must be prevented; Water runoff from any fuel storage areas and concrete swills must be directed towards a collection point and collected using drums or buckets and stored before disposal at a site or facility approved by the PM and local authority. The Contractor must request waybills for those deliveries and submit them to the PM; and
Implementation
Monitoring
EM; ECA
Vhuy/Alle
August 2008
Page 12
c)
The contaminated water, run-off, or waste water may also require analysis prior to disposal and must follow the relevant South African Water Quality Guidelines as implemented by DWAF. The PM must be aware of DWAFs and the Municipal waste water departments procedures and protocols. Contractor Construction Manager; EM EM; ECA
Storm water: Efficient measures need to be implemented during excavation and construction to manage stormwater flow and reduce its erosive potential. a) b) All water flow must be directed through controlled management into an existing drainage system. The contractor must ensure that no erosion and siltation of existing drainage system occurs, as a result of construction / development activities; and During site establishment, stormwater culverts and drains are to be located and covered with metal grids to prevent blockages if deemed necessary by the PM/EM. All existing stormwater culverts drains and pipes must be repaired and upgraded to facilitate the requirement of the construction and operational phases of the development and silt traps must be constructed where necessary.
Groundwater: Groundwater may be contaminated through percolation of contaminants and is affected by the incorrect handling of substances and materials resulting in spillages, soil erosion, and the mismanagement of polluted run-off. a) Contaminated areas to be properly rehabilitated.
EM; ECA
5.1.8 Soil
Loss of topsoil through land disturbance and improper stockpiling: a) In areas to be affected by construction activities, topsoil (minimum of 300mm of the top layer) to be removed and stored/stockpiled separately from other fill material. Protect stockpiled topsoil by preventing compaction (vehicle movement), contamination and mixing with any other material. Institute wind and water erosion-control measures to prevent loss of topsoil. This stockpiled topsoil should be used during site rehabilitation and subsequent to the backfill of trenches.
Implementation
Monitoring
EM; ECA
Soil may become compacted through heavy machinery movement and constant construction vehicle traffic: a) Compacted areas to be ripped to allow for penetration of root systems.
Contractor Construction Manager Contractor Construction Manager
EM; ECA
Soil erosion can occur from construction activities. Prevent or reduce erosion potential by: a) b) c) d) e)
Vhuy/Alle
EM; ECA
Scheduling construction activities to avoid heavy rainfall periods (to the extent practical); Mulching to stabilise exposed areas; Revegetating areas promptly; Reducing or preventing off-site sediment transport through use of settlement ponds, silt fences, etc. and modifying or suspending activities during extreme rainfall and high winds to the extent practical; Segregating or diverting clean water runoff to prevent it mixing with water containing a high solids content; and
August 2008
Page 13
f)
Rehabilitation to ensure sufficient vegetative ground cover to prevent erosion. Additional measures (e.g. berms, gabions) to be employed to provide soil stabilisation where necessary. Contractor Construction Manager EM; ECA
Soil management: a) Reinstatement of trench material. Where possible and appropriate top soil will be segregated and replaced on other back fill material to promote regeneration of vegetation.
5.1.9 Excavation
Excavation activities must be properly managed to minimise impacts to the surrounding environment and allow for rehabilitation to occur. Improper excavation management affects worker safety, construction efficiency and quality, and can become a nuisance to the surrounding residents, in addition to having detrimental environmental impacts. a) b) c) d) e) Clearing of areas and removal of vegetation must be limited until such time as earthmoving and construction commence Unnecessarily exposed areas must be revegetated to prevent wind and water erosion Topsoil is to be removed and stockpiled separately in a designated area; Excavated material must not be dumped outside the designated material storage area without authorisation from the PM and may, under no circumstance, be dumped outside the boundaries of the construction site; and Any excess material must be removed from site on completion of construction and disposed of appropriately.
Implementation
Monitoring
EM; ECA
5.1.10 Stockpiles
Stockpiles, including those of soil, rubble, excavated materials and cleared vegetation, are susceptible to collapse and extensive erosion if not constructed to the correct gradient and height, or located correctly. a) The PM must direct stockpiling of materials and designate a formal stockpile area. Considering the slope gradient, the positioning of stockpiles is important in ensuring stockpiles are not placed in water flow streams or where they can be a danger to worker safety; Stockpiles are not to exceed 2m in height unless otherwise permitted by an Engineer; The height and gradient of stockpiles must be sufficiently shallow to prevent slumping or rock falls; Stockpiles must not be situated such that they obstruct water pathways; Stockpiling is prohibited below the environment line or outside the property; and Stockpiles are to be secured using danger tape.
Implementation
Monitoring
EM; ECA
b) c) d) e) f)
Vhuy/Alle
August 2008
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5.1.11 Importation of fill/ soil/ sand materials

Imported materials must be properly managed to ensure appropriate storage and stockpiling as they may contain potentially contaminating material which may negatively impact on the site, construction activities or the natural environment. a) b) c) Ensure imported materials are free of weeds, litter and contaminants; Sources of imported materials must be approved by the PM; and The PM shall approve stockpile areas before stockpiling commences.
Implementation
Monitoring
EM; ECA
5.1.12 Materials Delivery

All materials must be delivered to the site in an orderly fashion to ensure proper management and prevent accidents and spillage. a) b) c) d) e) An appointed representative of the PM or Contractor must supervise all deliveries, particularly those of a hazardous nature; Ensure that subContractor and delivery companies are informed of delivery procedures and are made aware of restrictions, in terms of where materials can be located; All loads must be secured to prevent spillage during transport; All vehicles must adhere to the speed limit; and The Contractor shall be responsible for the clean up of spillages should the subContractor not properly secure materials.
Implementation
Monitoring
EM; ECA
5.1.13 Storage Areas

Storage areas are designated areas where all construction equipment, construction materials and hazardous materials can be safely and securely stored. Storage areas can, however, be hazardous, unsightly and sources of pollution if not designed and managed properly. a) b) c) d) e) f) Valuable and hazardous materials must be kept under lock and key; Sighting of a storage area must take into account prevailing winds, distance to water bodies and general on-site topography; Storage areas shall be designated, demarcated and fenced if necessary; Storage areas must be secure so as to minimise the risk of crime, and prevent access by children and/or animals; Those storage areas containing hazardous substances / materials must have the appropriate signage; Hazardous storage and refuelling areas must be bunded with an impermeable liner to protect groundwater quality and must comply with the relevant SANS codes;
Implementation
Monitoring
ECA; EM
Vhuy/Alle
August 2008
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g)
Storage areas are to be roofed with impervious material, with the ingress of wind-blown rain avoided by sufficient roof overhang or sides of sufficient height. Rainwater run-off shall be channelled or piped away from the area into channels or catchpits; and Fire prevention facilities must be present at all storage facilities.
h)
5.1.14 Hazardous Substances and Materials

Hazardous substances and materials are those that are potentially poisonous, flammable, carcinogenic or toxic. Examples of these include: diesel; petroleum; oil; bituminous products; cement; solvent based paints and lubricants. Such substances, utilised in whatever form on-site, must be properly managed. a) b) A register of all hazardous substances stored on the site must be maintained; Relevant Material Safety Data Sheets (MSDS) must be available on the site for all potentially hazardous substances (as defined in the regulations for Hazardous Chemical Substances). In the event of an emergency, procedures detailed in the MSDS shall be implemented; All hazardous substances are to be stored within secondary containment in a suitable storage facility. Major stocks of hazardous materials other than fuel should, where possible, be stored off-site; No hazardous substance is to be disposed of on site; In the event of a fuel spill, all unusable fuel and contaminated soil must be removed and disposed of at a licensed hazardous waste facility. Waybills must be retained with the Contractor; Soil / fuel that cannot be removed shall be treated in situ with an appropriate remedial agent. The services of an expert, in this instance, may be required; and All spills greater than 200 litres must be reported to Department of Water Affairs and Forestry (DWAF) and the local authority.
Implementation
Constractors Construction Manager; EM
Monitoring
ECA
c) d) e) f) g)
5.1.15 Fuel Storage and Dispensing

The PM must demarcate an area for fuel storage tanks, should they be required during construction. This is due to the highly flammable nature of the fuel and the associated high risk to the health and safety of all staff, in addition to the potentially significant enviromental impacts associated with the spillage or leakage of fuels into water sources and soils. a) Fuel must be stored in accordance with relevant SANS specifications and all fuel storage tanks are to have adequate bunding (110% of the largest tank). The bund floor shall be impermeable and sloped to a sump to enable removal of spilled fuel and contaminated water; All plant equipment shall be refuelled at a designated refuelling area, designed to prevent potential pollution (e.g. bunding); To adequately manage an emergency spill, a quantity of a material capable of encapsulating / containing a hydrocarbon spill (e.g. peat sorb) must be available at the fuel storage area and refuelling area. The material is to be capable of handling a spill of at least 200 litres; and
Implementation Contractor Construction Manager
Monitoring EM; ECA
b) c)
Vhuy/Alle
August 2008
Page 16
d)
Adequate fire-fighting equipment must be provided at fuel storage and dispensing areas.
5.1.16 Concrete and Cement Batching

Concrete used in construction has the potential to contaminate soils and surface and groundwater sources if not correctly utilised. All bulk concrete requirements must be imported to the site to minimise the risk of contamination. a) b) Small scale cement batching shall only be allowed with the consent of the PM, in areas designated by the PM; Run-off from batching operations must be contained and sediments allowed to settle. Following settling out of sediments, runoff may be disposed of at the nearest waste water treatment works. Contaminated run-off shall not be allowed to discharge off site or into the stormwater system, as it will result in the contamination of nearby water bodies. This is an offence in terms of the National Water Act (No. 36 of 1998). No run-off from batching operations will be allowed to seep into the surrounding soil; and Cement bags are to be disposed of as waste to a licensed waste disposal facility.
Implementation
Monitoring
EM; ECA
c)
5.1.17 Maintenance
Maintenance of all equipment, particularly earthmoving equipment, must be conducted off site to prevent pollution to the surrounding environment, unless it is physically not feasible to move a machine. a) b) c) d) All reasonable measures are to be taken to ensure waste oils and lubricants are contained (e.g. use of drip trays); All waste oils must be stored in a designated, bunded area and removed by an approved recycling contractor or disposed of to an appropriate licensed waste disposal facility; A demarcated area shall be provided for the parking of Contractor vehicles / equipment not in use; and All equipment / vehicles are to be regularly serviced and maintained in good working order. All leaks are to be repaired when identified.
Implementation
Monitoring
EM; ECA
Vhuy/Alle
August 2008
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5.1.18 Dust
All reasonable measures to minimise the generation of dust as a result of construction activities must be implemented to the satisfaction of the PM so as to prevent air pollution and minimise complaints from the surrounding residents. a) b) c) During high wind conditions, the PM must evaluate the situation and make recommendations as to whether dust-damping measures are adequate, or whether working will cease altogether until the wind speed reduces to an acceptable level; Excavation, handling and transport of erodible materials shall be avoided under high wind conditions or during heavy rains; Appropriate dust suppression measures are to be used when dust generation is unavoidable, e.g. dampening with water, particularly during prolonged periods of dry weather in summer. Such measures shall also include the use of temporary stabilising measures (e.g. chemical soil binders, straw, brush packs, chipping etc.); Where dust is unavoidable in residential areas, screening will be required utilising wooden supports and shade cloth; Where possible, soil stockpiles must be located in sheltered areas where they are not exposed to the erosive effects of wind. Where erosion of stockpiles becomes a problem, erosion control measures are to be implemented at the discretion of the PM; and Removal of vegetation must be avoided until such time as soil stripping is required and similarly exposed surfaces shall be revegetated or stabilised as soon as is practically possible.
Implementation
Monitoring
EM; ECA
d) e)
f)
5.1.19 Erosion
Stabilisation of cleared areas to prevent and control erosion must be actively managed in order to prevent the loss of valuable topsoil, and subsequent water pollution by sediment. Soil erosion can also negatively impact on the development construction and stability. a) b) c) The method of stabilisation shall be determined in consultation with the PM and EM; Excavated material, other than topsoil, can be utilised for erosion control, for example stone, rubble etc.; Anti-erosion methods must be used. These shall comprise an organic or inorganic material to bind soil particles together and must be a proven product able to suppress dust and erosion. The material used shall be of such a quality that grass seeds may germinate and not prohibit growth. Hydo-seeding can also be used as a method of surface water dissipation and erosion control; and Traffic and movement over stabilised areas must be restricted and controlled in order to prevent damage, and any damage to stabilized areas shall be repaired and maintained to the satisfaction of the PM.
Implementation
Monitoring
EM; ECA
d)
Vhuy/Alle
August 2008
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5.1.20 Traffic
Construction traffic can disrupt the normal traffic flow in the project area, thus the following are to be complied with: a) b) c) d) e) f) g) Relevant traffic authorities to be contacted prior to any anticipated disruption to normal traffic; Compliance with Southern African Road Traffic Signs Manual; Necessary safety measures to be implemented for working within/alongside roads; Necessary arrangements to be made to provide access to properties (where/if necessary); No heavy vehicles to travel on main roads during peak hours (if possible); Speed limits as stipulated in Mtunzini Town and Umlalazi Nature Reserve to be abided by at all times; and Drivers are to take cognisance of potential fauna which could be on the roads and thus be mindful of such.
Implementation
Monitoring
EM; ECA
5.1.21 Access
All vehicles shall be confined to the existing access road so as to minimise disturbance to the environment, and not become a nuisance to the surrounding neighbours. a) b) c) d) e) f) g) Unnecessary compaction of soils by heavy vehicles must be avoided; Excavated access driveways should have stormwater control furrows to control and direct any surface water flow across the driveways, which could result in erosion and destabilization; Access roads are to be maintained in a good condition, by attending to potholes, corrugations and stormwater damage as soon as they develop; If necessary, staff shall be employed to clean surfaced roads adjacent to the site where materials have been spilt; Cognisance of vehicle weight / dimensions must be taken when using access roads constructed of certain materials, for example, paved surfaces, cobbled entranceways, gravel and dirt roads; No unauthorised tracks or footpaths are allowed outside of the demarcated access routes or roads; and Employees must use the designated entrance point only.
Implementation
Monitoring
EM; ECA
Vhuy/Alle
August 2008
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5.1.22 Noise
Noise during construction can be a nuisance to the surrounding homes and mitigation measures must be implemented to reduce noise. a) b) c) d) Construction shall only occur from Mondays to Fridays between the hours of 7:00 am and 6:00 pm; Construction vehicles are to be fitted with standard silencers prior to the commencement of construction; Equipment that is fitted with noise reduction facilities will be used as per operating instructions and maintained properly during site operations; and The use of radios, television sets and other such equipment by workers must be controlled and noise levels kept to a level that does not disturb the neighbouring residents.
Implementation
Monitoring
EM; ECA
The genators required to be oused at the cable station will produce noise when operational. In this instance the following mitigation measures must be implemented. a) b) c) d) e) f) g) Generators are housed in a sound-attenuated enclosure (already included in cable station design); Generators housed in building with acoustic louvers (already included in cable station design); Exhaust louver to be directed towards the north-east i.e. away from human receptors (already included in cable station design); Generators are fitted with exhaust silencers; Indigenous vegetative screening to be planted around enclosure; Generator only used as a back-up power supply should there be a break in supply from national regulator; and Post construction, a noise investigation by a suitably qualified specialist should be undertake for the generator at full operation in order to ascertain compliance with SANS 10103.
EM; ECA
5.1.23 Visual Impact

Construction activities cause disruption of the landscape, which may become unsightly unless properly managed. a) b) c) Storage facilities, elevated tanks and other temporary structures on site must be located such that they have minimal impact on local residents; All lighting on the site should be directed downwards and away from oncoming traffic and adjacent residences; and Special attention is to be given to the screening of highly reflective or unsightly materials on site.
Implementation
Monitoring
EM; ECA
Vhuy/Alle
August 2008
Page 20
5.1.24 Heritage Resources

Damage and/or loss to heritage resources can occur during construction activities if they are not identified and reported. a) b) All finds of human remains to be reported to the nearest police station i.e. Mtunzini Police Station; Should any historically significant finds (e.g. artefacts, human remains or sites of cultural or archaeological importance) be located, work must cease and the South African Heritage and Resource Agency (SAHRA), including AMAFA KwaZulu-Natali must be contacted immediately. Work in the area can only be resumed once the site has been completely investigated; and Under no circumstance may any worker destroy or interfere with archaeological sites or finds. A fence at least 2m outside the extremities of the site must be erected to protect archaeological sites.
Implementation
Monitoring
EM; ECA
c)
5.1.25 Social
The surrounding homes in the residential area can be negatively affected by construction activities on site and, as such, consideration must be given to ensure the activities are appropriately managed. a) Preventative measures, such as screening, muffling, dust control, timing and pre-notification of IAPs are recommended to minimize complaints regarding dust, noise and vibration nuisances.
Implementation
Monitoring
EM; ECA
5.1.26 Fire Control

Fire can pose a threat to the health and safety of on-site staff and the surrounding residential area, in addition to being a nuisance impact (e.g. due to smoke). Reasonable and active steps must therefore be taken to avoid increasing the risk of fire through worker activities on site. a) b) c) d) Sufficient fire-fighting equipment must be maintained on site at all times, to the satisfaction of the local fire services; No fires are allowed on site except for the burning of firebreaks; Smoking shall not be permitted in those areas that pose a fire hazard. Such areas include fuel storage areas and areas where vegetation occur such that a fire may spread rapidly e.g. vegetation stockpiles; Necessary precautions must be taken when working with welding or grinding equipment near potential sources of combustion. Such precautions include using welding curtains and having a suitable, tested and approved fire extinguisher immediately at hand; and A fire officer must be appointed for coordinating rapid and appropriate responses in the event of a fire.
Implementation
Monitoring
EM; HSO; ECA
e)
Vhuy/Alle
August 2008
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5.1.27 Rehabilitation
Proper reinstatement and rehabilitation is vital after construction activities a) b) During the reinstatement, non-developed area (e.g. construction camp and storage/stockpile areas) must be returned to their original state (i.e. prior to construction), or better, as far as is reasonable / practical; Reinstatement tasks must include (but is not restricted to) the following: Any damage caused by construction-related activities must be repaired; The site must be cleaned, and all construction-related material and waste must be removed from site; All cement residues must be cleaned; All borrow pits (if applicable) must be filled and rehabilitated; and Areas where spillages of liquid waste (e.g. paint, oil, fuel) occurred must be cleaned appropriately. c) d) e) f) Temporary buildings must be demolished and the concomitant material must be removed from site; Site-specific rehabilitation measures need to be determined in consultation with the EM and ECA; Stockpiled topsoil should be replaced as the final soil layer; The grass mix, shrubs and trees used for rehabilitation must be compatible with the surrounding indigenous species; and
Implementation
Monitoring
EM; ECA
5.1.28 Daily Site Closure

At the closure of site every day the Contractors Safety Officers (as defined by the Occupational Health and Safety Act, No. 85 of 1993) must check the site and ensure the following conditions pertain and report on compliance with these clauses: a) b) c) d) e) f) g) All fuels / flammables / hazardous materials are securely stored in bunded areas and locked in the designated storage area; Site safety checks have been carried out by the safety officer in accordance with the Occupational Health and Safety Act (No. 85 of 1993) prior to site closure; All trenches and manholes are secure; Fencing and barriers are in place in accordance with the Occupational Health and Safety Act (No. 85 of 1993); Applicable notice boards are in place and secured; Emergency and management contact details are prominently displayed; Night hazard indicators such as reflectors, traffic signage etc. have been checked (if these are required);
Implementation
Monitoring
EM; HSO
Vhuy/Alle
August 2008
Page 22
h) i) j) k)
Wind and dust mitigation measures such as straw, brush packs, irrigation etc. are in place.; Excavated and filled slopes and stockpiles are at a stable angle and capable of accommodating normal expected water flows should there be overnight rain; Toilets are secured; and Refuse bins are secured.
5.1.29 Post Construction Activities

Land Rehabilitation: a) On completion of the construction activities, all remaining open areas not rehabilitated during construction must be rehabilitated and landscaped to minimise any further environmental impacts, particularly soil erosion and bank slumping. Landscaping also improves the aesthetic view of the development; All rubble must be removed to an approved disposal site. Burying of rubble on site is prohibited; The site is to be cleared of all litter; All soil surfaces hardened due to construction activities must be ripped, and any imported materials removed; Any runnels or erosion channels developed during the construction period or during the vegetation establishment period shall be backfilled and compacted and the areas restored to a proper condition; All watercourses must be free from building rubble, spoil materials and waste materials; All embankments are to be trimmed, shaped and replanted to the satisfaction of the PM; and Open areas are to be re-planted according to the revegetation specification.
Implementation
Monitoring
EM; ECA
b) c) d) e) f) g) h)
Materials and Infrastructure: Fences, barriers and demarcations associated with construction are to be removed from site, unless otherwise stipulated by the PM. a) b) c) d) All remaining building materials must be removed from the site; Residual stockpiles must be removed or spread on site as directed by the PM; Any damage that construction has caused to neighbouring properties must be repaired; and If the boundary fence has been damaged or removed during construction, it must be repaired or replaced with the same or similar type of material.
EM; ECA
General: a) b) All areas where temporary services were installed are to be rehabilitated to the satisfaction of the PM; and A meeting must be held on site between the PM, EM and the Contractor to approve all remediation activities, and to ensure the site has been restored to a condition approved by the PM.
EM; ECA
Vhuy/Alle
August 2008
Page 23
5.2
HDD and beach trenching

The following activities must be planned for and a method statement provided. The method statement must detail the activity and the procedure for fulfilling the required task to minimise impacts as a result of the procedure, relevant for terrestrial installation. x x x x HDD method statement; Traffic management and access routes i.e. for Umlalazi Nature Reserve and beach access; Fuels and fuel spills, including bentonite spills (e.g. on beach or at cable station site); and Beach trenching and cable laying
Implementation
Monitoring
EM; HSO; ECA
5.2.2 Discharge of drilling fluid

Discharge of drilling fluid can create erosion to surrounding sites and pollute soil through the discharge of contaminated water. a) b) c) d) No potentially harmful additives may be used without prior approval from the PM and EM; Water emitted during drilling will be allowed to settle prior to being discharged into the environment so that no erosion takes place; High temperature water emitted will require temporary storage before being discharged; and Measures to slow the flow rates from water strikes will be implemented, as and if required.
Implementation
Monitoring
EM; ECA
5.2.3 On-site observations during construction

During HDD drilling, the SEA Cable System construction personnel will monitor the cable route throughout the process as follows: a) b) c) On-site observation is to be conducted during active drilling with mud circulation; HDD observers will be briefed on what to watch for and will be made aware of the importance of timely detection and response to any release of drilling mud; HDD observers will have appropriate, operational communication equipment (e.g. radio, cell phones) available at all times during installation of the directionally drilled crossing (i.e. between start and end points), with the ability to communicate directly with the HDD operations control centre; If the HDD operator realises a sustained loss in fluid pressure or loss of circulation, the operator will notify the HDD observers of the assumed position of the drill head; and
Implementation
Monitoring
EM; ECA; PM
d)
Vhuy/Alle
August 2008
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e)
HDD observers will have the authority to order installation of containment structures, if needed, and to require additional response measures if deemed appropriate.
5.2.4 Response to inadvertent returns

In the event an inadvertent drilling mud return is observed during the HDD drilling, the return will be assessed to determine the amount of drilling mud being released and potential for the release to reach watercourses or wetlands. Response measures will vary based on inadvertent return as discussed below: a) On land locations b) Evaluate the release to determine if containment structures are warranted and it they will effectively contain the release; Order installation of containment as needed to prevent an uncontrolled release of drilling mud; and Initiate immediate suspension of drilling operation if the mud release cannot be controlled, until appropriate containment is in place.
Implementation
Monitoring
EM; ECA; PM
In-stream locations Document and monitor release; Initiate immediate suspension of drilling operation if released volume is determined to pose a threat to human health and safety, as well as fauna and flora;; If released volume is determined to pose a threat to human health and safety provide notification as per section 5.2.6; and inform the ECA and Ezemvelo KZN Wildlife of release immediately.
EM; ECA; PM
c)
Beach Document and monitor release; Initiate immediate suspension of drilling operation if released volume is determined to pose a threat to human health and safety, as well as fauna and flora; Initiate immediate suspension of drilling operation until appropriate evaluation and containment measures are completed; If released volume is determined to pose a threat to human health and safety, as well as fauna and flora, provide notification as per section 5.2.6 below; and Inform the ECA and Ezemvelo KZN Wildlife of release immediately.
EM; ECA; PM
Vhuy/Alle
August 2008
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5.2.5 Containment
Containment, response and clean-up equipment will be required to be immediately available at the HDD punch in and punch out locations. Such equipment for clean-up may include: Plastic sheeting, shovels, squeegees, pails, push brooms, pumps and sufficient hose, mud storage tanks, vacuum truck on 24-hour call, light plant/generator a) On land locations b) Deploy appropriate containment measures to contain and recover drilling mud as feasible; and Remove excess mud at a rate sufficient to prevent an uncontrolled release.
Implementation
Contractor Construction Manager Contractor Construction Manager
Monitoring
EM; ECA; PM
EM; ECA; PM
Beach In the event of a mud release on the beach / into the ocean: o o o o Drilling operations are to be suspended immediately; Notifications are to be made as per Section 5.2.6 ; The discharge is to be evaluated, and appropriate response and containment measures are to be deployed; and Physical collection from the affected area, if feasible;
EM; ECA; PM
If the amount of the surface return exceeds that which can be completely contained with hand-placed barriers, small collection sumps (less than 5 cubic yards) may be used to remove released drilling mud, if feasible; If the amount of the surface return exceeds that which can be contained and collected using small sumps, drilling operations shall be suspended until surface return volumes can be brought under control; Excess mud will be held within the containment area and removed using pumps or other appropriate measures at a rate sufficient to maintain secure containment;and The mud will be stored in a temporary holding tank or other suitable structure away from the ocean for reuse or eventual disposal in an approved disposal facility. Contractor Construction Manager EM; ECA; PM
c) -
In-stream locations Observers will document and monitor release; In general, containment is not feasible for in-stream releases. However, conditions are to be assessed as to whether handplaced containment, recovery or other measures, such as silt curtains, would be effective and beneficial at the specific release site; Drilling operations will not be suspended unless the returns pose a threat to human health and safety, as well as to fauna and flora; and Notification will be made per 5.2.6.
Vhuy/Alle
August 2008
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5.2.6 Notification
For all drilling mud release during HDD drillings, the Contractor will notify the ECA. If the ECA determines the release affects the ocean or in-stream areas, he or she will immediately notify SEACOM/Neotel after discovery of the release, as well as Ezemvelo KZN Wildlife and the Reserve Manager.
Implementation
Monitoring
EM; ECA; PM
5.2.7 Clean-up
Clean-up measures will be developed following mud releases on land or in the ocean. The following measures are to be considered as appropriate: a) Drilling mud will be cleaned up by hand using hand shovels, buckets and soft-bristled brooms as possible without causing extensive ancillary damage to existing vegetation. Fresh water washes are also to be employed if deemed beneficial and feasible; Containment structures will be pumped out and the ground surface scraped to bare soil without causing undue loss of topsoil or ancillary damage to existing vegetation. In the beach environment, the amount of beach sand contaminated will be removed via shovel and disposed of appropriately at a registered land fill site; Material will be collected in containers for temporary storage prior to removal form the site; Potential for secondary impact form the clean-up process is to be regularly evaluated and clean-up activities terminated if physical damage to the site is deemed to exceed the benefits of removal activities; and In general, no clean-up measures will be initiated for in-stream releases. If site-specific conditions are such that containment and clean up may be feasible and beneficial, fresh water washes or other low-impact steps may be employed without undue disturbance to the stream banks and bed.
Implementation
Monitoring
EM; PM; ECA
b)
c) d) e)
Sealing and abandonment of the drill hole: The following measures will be implemented in the event that drilling cannot continue along the designated drill path due to excessive leakage: a) b) c) Beginning from a point behind where the leakage occurred, the hole will be redrilled along a different alignment path; The initial drill hole will be abandoned if continued drilling along a new alignment is not possible. This will be accomplished by filling the hole with the bentonite slurry used for the initial drilling and plugging the surface opening with a cement grout; and In case of abandonment an additional attempt at completing the horizontal directional drill may be made in proximity to the previous route. A new hole would be drilled in the same general area as the initial drill hole. No alternative crossing methods would be implemented (i.e. wet trench) without the proper agency notification and approvals.
EM; PM; ECA
Vhuy/Alle
August 2008
Page 27
5.2.8 Umlalazi Nature Reserve protocol

In light of Ezemvelo KZN Wildlifes protocol, the Umlalazi Nature Reserves Conservation Manager is to be notified when any operations are scheduled in the Reserve: a) b) c) The Contractor is to notify the Conservation Manager, of their intention to enter the Reserve in order to commence construction work; The Contractor is to notify the Conservation Manager of the proposed duration that works will take (e.g. five days), and the times at which the construction crew would enter and exit the Reserve for every day of construction; and All construction workers are to abide by the Umlalazi Nature Reserves rules and regulations i.e. maintain stated speed limit, observe opening / closing times etc.
Implementation
Monitoring
EM; Reserve Manager; ECA
5.2.9 Beach access and trenching

Vegetation and invertebrate beach fauna could be disturbed and/or destroyed during the beach access by construction staff, vehicles and machinery as well as trenching and sediment stockpiling. a) b) c) d) e) f) g) h) i) j) k) Beach access by construction staff, vehicles and machinery to be by arrangement with the Umlalazi Nature Reserve manager; All personnel and vehicles to use disturbed vehicle access track only. Obtain clearance from DEAT for beach vehicle driving permit; During beach driving, all vehicles should aim to drive in the tracks of the precieding construction vehicle in order to limit the area disturbed by construction vehicles; Construction related vehicles accessing the beach should do so in a responsible manner (e.g. drive in the previous vehicles tracks) and in accordance with the relevant MCM regulations; Care should be taken to minimise the area disturbed by construction related activities on the beach and offshore; The area to be disturbed by trenching and stockpiling activities should minimised as far as is practical; Where ever possible, excavated trenches should be back filled as soon as possible and the beach profile restored to its previous condition; Disturbance to the fore dunes and pioneer sea shore vegetation occurring on them must be avoided; Cable laying and back filling of the beach trench should take place as soon after excavation as is practically feasible in order to limit longer term beach disturbance; Ideally, beach excavation and cable-laying should be carried out in non-holiday periods, and during the week, to reduce impacts on shore anglers and recreational skiboat fishers; and Appropriate remedial action to be implemented subsequent to cable laying and back filling.
Implementation
Monitoring
EM; ECA; Reserve Manager
Vhuy/Alle
August 2008
Page 28
5.2.10 Public beach use

Protection of the public must be considered when performing construction activities on the beach. In this regard the following must be taken heed of: a) b) c) The area of cable landing must be cordoned off with construction / barrier tape at a safe / appropriate distance considered by the Contractor. This marking will prevent the public from entering a potentially dangerous construction site on the beach; Construction is preferred to take place during the week and not weekends so as to limit any disturbance to beach users over the weekend (including vehicle access for launching/retrieving of fishing boats); and Permission to drive construction vehicles on the beach to be obtained from the Department of Environmental Affairs and Tourism, Marine and Coastal Management, prior to beach access/construction activities.
Implementation
Monitoring
EM; Reserve Manager; ECA
5.2.11 Post construction activities

Beach rehabilitation: a) b) c) d) e) f) g) On completion of the beach HDD punch out and cable laying activities, the disturbed areas must be rehabilitated to minimise any further environmental impacts; All rubble must be removed to an approved disposal site. Burying of rubble on site is prohibited; The site is to be cleared of all litter; All remaining building materials, fences, barriers and demarcations associated with construction must be removed from the site; Residual stockpiles must be removed or spread on site as directed by the PM; Any damage that construction has caused to neighbouring properties or the Umlalazi Nature Reserve must be repaired; and A meeting must be held on site between the PM, EM, the Contractor and the Reserves Manager to approve all remediation activities, and to ensure the site has been restored to an appropriate condition.
Implementation
Contractor Construction Manager; PM; EM
Monitoring
EM; ECA; Reserve Manager
Vhuy/Alle
August 2008
Page 29
5.3
Offshore installation
The following activities must be planned for and a method statement provided. The method statement must detail the activity and the procedure for fulfilling the required task to minimise impacts as a result of the procedure, relevant for off shore installation. x x x x Cable laying operations onboard the Tyco vessel, both in deep and shallow marine waters; Cable landing procedure from marine environment into terrestrial environment i.e. beaching of cable; Waste management on board the Tyco vessel; and Storage of hazardous materials, and emergency plans.
Implementation
Tyco EM ECA
Monitoring
5.3.2 Marine Environment

It is common practice that during cable installation a representative of the cable laying vessel acts as the ECA. The duties of the Tyco ECA will include: a) b) c) d) e) f) g) h) i) j) Conducting a pre-mobilisation check of the cable laying vessel, thus ensuring that the cable laying vessel is competent at performing the designated task; Ensuring that all safety requirements are covered on the cable laying vessel; The cable-laying vessel should meet international maritime standards of operation; Monitoring the adequacy of the cable laying operation; Across the Thukela and prawn trawl areas, burial of the cable should be implemented where ever practically feasible; Where reef crossings are unavoidable, the shortest crossing route should be considered and areas of high reef profile should be avoided where ever practically possible; In areas of high cable risk, armoured cable should be deployed for greater protection; Where the cable route is forced to traverse off shore rock outcrop / reef, care should be taken to minimise disturbance to biological organisms; Notification of the intention to begin laying the cable should be well communicated, via the Notices to Mariners which are transmitted regularly to ships at sea, as well via Richards Bay, Meerensee and Mtunzini skiboat clubs ; and Where the cable route is forced to traverse off shore rock outcrop / reef, care should be taken to minimise disturbance to biological organisms (refer to Section for an assessment of the marine biological considerations).
Implementation
Tyco EM
Monitoring
ECA
Vhuy/Alle
August 2008
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k)
In terms of monitoring compliance of the cable installation in the marine environment, it is impractical for the ECA to be onboard the vessel during cable installation activities, In this regard, the Tyco Environmental Manager is to document all activities as discussed in the sections to follow, in addition to providing the ECA access to all relevant documentation pertinent to the cable installation acitivities upon request. This documentation will provide the basis on which the ECA may audit against.
5.3.3 Shallow water cable laying

This stage of the cable laying has the most potential to cause impacts and therefore requires continuous monitoring by suitable qualified/experienced on board personnel. a) The contractor is to ensure that any unacceptable damage to the shallow water environment, as well as to the beach environment is avoided. The contractor is to familiarise himself with the EMP (this document) as well as adopt appropriate method management techniques known to the industry which will minimise disturbance to the shallow marine environment i.e. best practice methods are to be adopted; Maintain good communication with SEACOM, as well as the relevant authorities should it be requested; Installation/construction should occur during daylight hours as far as is is practical; If the cable is laid during the months of August to February, when no shallow water trawling is permitted, direct interference with shallow-water trawling operations will be avoided; and EKZN Wildlife (i.e. the Umlalazi Nature Reserve Manager) is to be informed of when the cable is to be laid in shallow waters and consequently when beach installation/construction operations begin.
Implementation
Tyco EM
Monitoring
ECA; Manager Reserve
b) c) d) e)
5.3.4 Deep marine waters

The impacts likely to be generated in the cable laying operation in deep offshore water are expected to be minimal. a) b) c) No impacts are expected on fisheries or shipping activities providing normal international marine activity procedures are followed, thus no additional recommendations are provided in the EMP; In deep water there is potential for discharges of waste and foul water from the vessel. The Tyco cable laying vessel is to comply with International laws on vessel discharge and pollution; and Good working practice, health and safety management, and minimal environmental disturbance principles are to be adopted upon the cable laying vessel.
Implementation
Tyco EM
Monitoring
ECA
Vhuy/Alle
August 2008
Page 31
5.3.5 Aqueous discharges (excluding ballast)

Implement requirements of relevant international shipping conventions, including: a) No sewage shall be discharged from marine vessels within 4 nautical miles (7 km) of the nearest land, and any sewage discharged between 4 and 12 nautical miles (21 km) shall be macerated and disinfected. Sewage treatment equipment should be regularly inspected and maintained to ensure optimum operation; Sewage/grey water from cable lay vessels shall be treated to reduce the concentration of organic material prior to discharges. Food wastes from vessels shall be macerated and discharged to sea; and Potentially contaminated drainage, including drainage from machinery spaces and bilges, shall be treated with an oil/water separator to ensure that oil concentrations meet the standard of 15 ppm maximum without dilution prior to discharge.
Implementation
Tyco EM
Monitoring
ECA
b) c)
5.3.6 Ballast water management

A ballast water management plan to minimise the potential for the introduction of non native species by project vessels traffic shall be developed and implemented. Where applicable, ballast water will be managed in accordance with the IMO guidelines for the control and management of ships ballast water to minimize the transfer of harmful aquatic organisms and pathogens and the International Convention for the Control and Management of Ships Ballast waters and sediments. Measures should include: a) b) c) d) e) Minimising uptake of harmful organisms; Minimising the release of ballast water; Routine cleaning of ballast tanks to remove sediment; Implement least environmentally harmful ballast water exchange measures with consideration given to deep water exchange (or inline with regional agreements) or discharge to reception facilities; and Ballast water management practices should be recorded (dates, locations, volumes of ballast water exchanged).
Implementation
Tyco EM
Monitoring
ECA
5.3.7 Turbidity
Turbidity will be minimsed during cable lay operations by minimising the duration and extent of physical seabed disturbance using a sea plough method where possible (in preference to jetting) to reduce release of loose sediments
Implementation
Tyco EM
Monitoring
ECA
Vhuy/Alle
August 2008
Page 32
5.3.8 Commerical fisheries

a) b) c) d) e) Fishing representatives to be informed of cable laying schedule and exclusion zones; Local fishermen and other sea users will be informed about the presence of the cable vessel and location of the cables; Reducing the time taken to lay the cable would reduce the impact on fishing activities; Commerical skiboaters are to be informed of cable laying activities; and The cable route will be clearly marked on navigational charts.
Implementation
Tyco EM
Monitoring
ECA
5.3.9 Safety at sea

Project vessels will safely operate in accordance with the requirements of : a) b) c) International Loadline Convention, 1966; International Convention on Standards of Training Certification and Watchkeeping for Seafarers (STEW); and Convention on the International Regulations for Preventing Collisions at Sea, (COLREGs).
Implementation
Tyco EM
Monitoring
ECA
5.4
Fibre Optic Safety

5.4.1 Optical Fiber Safety
a) b) Worker training on specific hazards associated with laser lights, including the various classes of low and high power laser lights, and fiber management should be provided where necessary; and Where appropriate / required, implementation of a medical surveillance program with initial and periodic eye examinations
Implementation
Monitoring
ECA
5.4.2 Electrical Safety

Only trained and certified workers are permitted to install, maintain, or repair electrical equipment.
Implementation
Monitoring
ECA
Vhuy/Alle
August 2008
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Auditing
The key to a successful EMP is appropriate monitoring and review to ensure effective functioning of the EMP and to identify and implement corrective measures in a timely manner. In the event where discrepancies are identified, the problem must be investigated and attended to. All the results obtained during environmental monitoring must be documented for audit purposes. SEACOM is to appoint an independent auditor to undertake such audits i.e. the ECA. An audit of the environmental monitoring and management actions undertaken is essential to ensure that it is effective in operation, is meeting specified goals, and performs in accordance with relevant regulations and standards. Audits should be conducted during the construction phase of the project to ensure adherence to the management measures contained in the EMP. The following construction audit schedule is proposed for all environments however, the marine audit will be conducted via the checking of compliance waybills/records from the Tyco EM, whereas the terrestrial audits will follow a similar process of physical record monitoring, as well as conducting visual inspections to determine compliance with the EMP:
x x x
One audit at commencement of construction / cable installation activities; Two audits during the construction and cable installation phase (or as other wise indicated by the relevant authorities); and One post-construction or close-out audit.
The frequency of the construction audits may vary and will be synchronised with the construction schedule.
Corrective action
Performance measurement is an essential part of the EMP. Key purposes of performance measures are to:
x x x x
Determine whether the EMP has been implemented appropriately; Check that risk controls have been implemented and are effective; Learn from the system failures through incident investigations; and Provide information that can be used to review and, where necessary, improve aspects of the system.
There are several levels at which corrective action can be implemented. These are listed and described below: i) Verbal Instruction Verbal instructions are likely to be the most frequently used form of corrective action and are given in response to minor transgressions that are evident during routine site inspections. Verbal instructions are also used to create further awareness amongst Contractor workforce, as often the transgressions are a function of ignorance rather than vindictiveness.
Vhuy/Alle
August 2008
Page 34
ii) Written Instructions Written instructions will be given following an audit. The written instructions will indicate the source or sources of the problems and proposed solutions to those problems. The implementation of these solutions will be assessed in a follow-up audit and further written instructions issued if required. At the employer representatives sole discretion, a penalty shall be deducted to remedy issues if written instructions are ignored. Should a contractor not remedy and rehabilitate impacted areas after an environmental incident to the satisfaction of the employers representative, then the employers representative shall carry out the necessary actions. Costs to remedy environmental incidents as well as rehabilitation of impacted areas shall be paid by the Contractor/s concerned. iii) Contract Notice A contract notice is a more extreme form of written notice because it reflects the transgressions as a potential breach of contract. If there is not an adequate response to a contract notice, then the next step can be to have the contractor removed from the site and the contract cancelled.
Amendments
Amendments to the EMP may be required as the project phases proceed. Any proposed amendments to the EMP, as may be specified in the audit reports, will be confirmed with the EM prior to being issued as a formal amendment, subsequent to approval by the DEAT. Copies of the amendments will be issued to recipients of this report as detailed in the report record at the end of this document and forwarded to the DEAT.
Mr. M. van Huyssteen Environmental Scientist
Mr. N. Holdcroft Principal Scientist
Ms. L. Allan Environmental Scientist
Mr. V. S. Reddy Pr. Sci. Nat. Partner
For SRK Consulting
Vhuy/Alle
August 2008
Mozambique - Environmental Action Plan
Table of contents
2 3 4
5 6
Introduction.............................................................................................................. 2 1.1 Scope of the EMP ........................................................................................... 2 1.2 Objective and Purpose.................................................................................... 2 1.3 EMP Organizational structure and Management ............................................ 3 1.4 Client Details................................................................................................... 3 Legal Framework..................................................................................................... 4 Roles and Responsibilities ...................................................................................... 5 Environmental Management Specifications ............................................................ 8 4.1 Methods Statement for Construction/Installation ............................................ 8 4.2 Project Environment Specifications ................................................................ 9 Construction/Installation Monitoring Plan .............................................................. 15 Contingency plan................................................................................................... 17 6.1 Response strategy ........................................................................................ 17 6.2 Prevention..................................................................................................... 18 6.3 Communications, duties and responsibilities during Construction/Installation activities .................................................................................................................... 19 Regulatory Agencies ............................................................................................. 19 Role and responsibilities........................................................................................ 19 6.3.1 Communication ......................................................................................... 20 Communication Plan ............................................................................................. 21 7.1 Communications, duties and responsibilities during Construction/Installation activities .................................................................................................................... 22 Regulatory Agencies ............................................................................................. 22 Role and responsibilities........................................................................................ 22 Expenses............................................................................................................... 23
Mozambique Fibre optic Submarine cable Telecommunication Project Draft EMP, June 2008
Introduction
The present document constitutes an Environment Management Plan (EMP), foreseen in the Environment Impact Assessment Process Regulation (decree n 45/2004, 29th of September) on the Environment Impact Study scope. EMP has as purpose to minimize the negative impacts and enhance the positive ones during the implementation and operation of the SEACOM Submarine Fibre Optical Cable System. This EMP is part of the Environmental Impact Report (EIS) carried out by CONSULTEC Consultores Associados, Lda.
1.1
Scope of the EMP
This EMP defines the Environment Specifications (ES) to be applied during the Construction/Installation and Operation phases. The EMP is structured in accordance with the schedule activities, beginning with the Mozambican Legal context, Client details, and responsibilities of each and every actor in the different phases, Environment Specifications for the activities, monitoring and support measures and emergency and contingency plan. Effective implementation of the EMP will ensure that: x During project design all mitigation measures identified during the EIA are considered during the detailed design phase x During Construction/Installation all constrains, restrictions and actions required to minimise impacts are implemented x The entire project will be conducted and managed in an environmentally sound and responsible manner. The good implementation of this study aims for the Stakeholders knowledge of the ES as a minimization measure to global and regional environmental and social impacts. As the project will continually develop and therefore the specific and detailed technical and procedural requirements for achieving the proposed mitigation measures outlined in the EMP will also continue to be developed. Therefore, the EMP described in this document is part of a larger environmental management program, which will continue to evolve as the project develops, and will be reviewed internally and updated periodically. This document is dynamic and should be updated whenever changes are made to the project or better mitigation measures are established.
1.2
Objective and Purpose
The Environmental Management Plan (EMP) aims to safeguard the quality of the environment and the needs of those affected during Construction/Installation and operation of this project, contributing to its environmental sustainability. In addition, the EMP intends to ensure that the project activities comply with the Environmental Law in force.
In the EMP all measures are systematized to minimise, monitor and mitigate the impacts identified in the EIS, identifying when they should be implemented and who are the entities responsible for its implementation. The objectives of this EMP are to monitor and minimize the potential negative environmental impacts of the project and enhance the positive environmental impacts. It is expected that the EMP: x Ensure continued compliance with applicable requirements and standards set by existing legislation in the Republic of Mozambique, on the environment; x Provide the initial mechanisms to ensure that the measures identified in the EIS, in order to mitigate potentially adverse impacts, are implemented; x Provide an action plan for mitigation of impacts that can not be predicted or identified until the Construction/Installation and operation activities are underway; and x Provide assurance to regulators and stakeholders about the satisfaction of their demands regarding the environmental and social performance.
1.3
EMP Organizational structure and Management
The EMP provides mitigation and management principles for the Construction/Installation and Operational Phase of the project. Environmental actions, procedures and responsibilities as required within these phases are specified. These specifications shall form part of the contract documentation and, therefore, the Contractor will be required to comply with the specifications to the satisfaction of the Project Manager and Environmental Control Officer, in terms of the Construction/Installation contract. The Contractor is required to comply with all relevant environmental legislation for all phases of the project. This list is intended to serve as a guideline only for the Contractor and is not exhaustive. As referred before, the EMP is a dynamic document which should be updated as required on a continuous basis. Any amendments made must be submitted to both EDM Environmental Control Officer and Project Manager for approval prior to implementation.
1.4
Client Details
CAPITEL, Ltd. is the holder of the fibre optical cable project within the Mozambican territorial waters, linking Mozambique to a global telecommunications network - SEA Cable System (SEACOM). CAPITEL is based in Maputo, in Av. Ho Chi Min n43,1 andar.
1.4 Statement
Capitel Ltd and the Contractor(s) are committed on undertake the works respecting the local community and natural resources. Furthermore, the Contractor will manage the activities protecting health and security of workers and public in general.
Legal Framework
The National Environmental Policy, approved by Resolution Nr. 5/95, dated 6th December 1995, establishes the basis for all environmental legislation. According to Article 2.1, the main goal of this policy is to ensure sustainable development in order to maintain an acceptable commitment between socio-economic development and environmental protection. In order to reach this goal, this policy must ensure, among other aspects, the management of the countrys natural resources and the environment in general in order to preserve its functional and productive capacity for present and future generations. The Environment Law (Law Nr. 20/97, of 7 October 1997) defines the legal basis for the sound use and management of the environment as a means to safeguard sustainable development in the country. The Law applies to all activities in the public or private sectors that may directly or indirectly affect the environment. The issuing of an environmental license shall precede any other required legal licenses. The Ministry for the Coordination of Environment Affairs (MICOA) through the National Directorate for Environmental Impact Assessment (DNAIA) is the authority responsible for the EIA evaluation and Environmental licensing of activities. The proposed project was classified by MICOA as an A Category project, and so it needs an EMP as a condition for the Environment Licence. As stated on the Regulation for the Elaboration of an EIS (Ministerial Diploma 129/2006, 19th of July) the EMP should include the following elements: x Monitor Programme: It requires the measurement of parameters relating to environmental factors affected, before and after implementation of the project. It should give up the places of measurement, the frequency and the maximum permissibility Program for emergencies control: to discuss different risks of accidents, their causes, consequences, frequency or probability expected prevention and risk reduction and emergency plans envisaged. Maintenance Actions: identify and minimize the impacts arising from the maintenance of buildings and equipment. Environmental Education Program: For cases of projects located in fragile areas or affecting the conservation areas or zones of protection, it is important that people have access or receive information from the premises, on the care they should take to protect natural resources.
x x x
In accordance with the requirements laid by MICOA, the EMP should be implemented by the Contractor, by operators and sub operators to ensure an integrated implementation in accordance with the Environmental Law requirements. The specifications defined within the EMP should apply to all activities carried out by the Contractor, Constructor and operator responsible for this project and for everyone involved, including consultants, subcontractor, workers, tourists, visitors and suppliers. The EMP comes to establish identifiable and measurable procedures and protocols of environmental management that ensure that the Construction/Installation and operation of the Submarine Fibre Optical Cable avoid or at least minimize the impact on the receiver environment.
Roles and Responsibilities
In order to ensure the proper development and effective implementation of the EMP, it will be necessary to identify and define the responsibilities and duties of various stakeholders and organizations involved in the two phases of the project. The following entities will be directly involved in the present EMP according to the structure below:
Function CAPITEL Project manager Contractor Env. Site Control Officer (ESCO) Overall Role Overall management of project and EMP implementation and oversees site works and liaison with Contractor Implementation and compliance with recommendations and conditions of the EMP. Implementation of EMP, interaction with local community, environmental control of site actions and monitoring.
CAPITEL and the Contractor must commit themselves to comply with the relevant provisions of the applicable environmental legislation and associated regulations promulgated in terms of these laws. CAPITEL, as the project proponent will be accountable for: x x x x x x x Contractor selection and performance and Legal requirements. Ensure that this EMP forms part of any contractual agreements with the Contractor for the execution of the proposed project Appointing an Environmental Site Control Officer (ESCO) which is responsible for supervising the work and to ensure compliance with this EMP. Establishing and maintaining a regular communication with ESCO and the Contractor. Applying the Contractors penalties in case of non-compliance with the EMP. Presenting a report to MICOA on the implementation of the EMP, by the end often Construction/Installation phase. Ensuring the implementation of a the Communication Plan according to EMP specifications
CAPITEL as the overall responsible for Cable operation and maintenance will also be responsible to ensure the appliance of EMP in case of maintenance requirements or different decommissioning practices than the current plan. With the commitment of restricting access to no more than one kilometre along the cable route at any time, together with the provision to all interested and affected parties of regular early warnings of movement restrictions along the cable route, no significant impacts are foreseen to other seafarers such as artisanal fishermen. However, in the unlikely event that any such impacts should occur, CAPITEL will provide compensation in accordance with the principles of the World Bank Group and Equator Principles.
The Contractor will have the following responsibilities: x x x Be familiar with the EMP contents. Comply with the Environmental Specifications on this EMP and the subsequent revisions, as well as the Technical Environmental Specifications, specified in material/equipment suppliers instructions. Before works initiation, submitting a Work Plan, indicating location of camp site, borrow pits, spoil and storage areas (if applicable), beach and road access areas; Methods of Statements for wastewater management, waste management and workforce for approval by the ESCO. Monitor constantly the implementation and compliance of Environmental Specifications. Examine the workplace inspection report and take note of information / recommendations contained therein. Immediately notify the ESCO, orally and in writing, in the event of any incidental breach of the Environmental specifications and ensure that required remedial actions are taken. Restore all areas affected by the Construction/Installation activities to the original state, as determined by the ESCO. Restore services, facilities, properties private / public and other areas adversely affected by the Construction/Installation or Operation activities out of bounds and demarcated in accordance with the instructions of the ESCO. Communicate frequently and openly and contact the ESCO to ensure an effective and proactive environmental management, with the aim of preventing or reducing negative environmental impacts. Ensure environmental awareness of their employees and the workforce so they are aware of issues and understand the need for environmental specifications. Keep a record of complaints received from the public and inform the ESCO and the Contractor. Submitting a report at each site meeting which will document all incidents that have occurred during the period before the site meeting
x x x x x x x x
The Contractor should also do its own management system to ensure and monitor the implementation of the EMP and Environmental Specifications associated with him. This system should at least allow: x The preparation of Method Statement as required by the EMP; x The effective and transparent management of Construction/Installation and operation activities related to environmental specifications; x The recording, in writing, of all communication / correspondence of environmental issues with all relevant stakeholders and other parties; x The development of emergency and contingency plan for major incidents and emergencies that may be associated with this project. The Contractor shall ensure that the correct equipment for Construction/Installation purposes is available at all times to ensure Construction/Installation proceeds without unnecessary damage to the environment. Should alternative methods be used, it requires approval from site staff and the ESCO must be informed to ensure environmental issues are addressed. The contractor must also monitor the performance of the Construction/Installation team from time to time to ensure compliance with the requirements of this EMP.
Environmental Site Control Officer (ESCO) to be appointed by CAPITEL, will be responsible for monitoring the effective implementation of the EMP, and will have the following role: x x x x x Review and approve the Methods of Statement done by the Contractor and / or operator on the EMP; Oversee compliance with the EMP by Contractor and / or operator; Liaise with the Contractor and / or operator and, where necessary, with the CAPITEL, as well as engineering issues that have environmental and social impact; Advise the Contractor and / or operator in the interpretation and enforcement of environmental specifications, including discussions on the failure of the same; The ESCO monitors the work throughout the Construction/Installation phase, doing daily workplace inspection reports to CAPITEL for the record.
It is required that the ESCO: x Be familiar with the contents of the EMP. x Have working experience as Environment Control Officer and environmental knowledge about emergency procedures in case of spills. x Review and approve the Method Statement prepared by Contractor and / or operator, so that all rules are complied with security and preserving the environment in activities considered most at risk. x Make a damage assessment following the occurrence of incidents, accidents and serious offences relating to the Construction/Installation, inside / outside the place of Construction/Installation. x Monitor physical damages caused to the environment by Construction/Installation activities as evidence of beach erosion, trees damage, etc. x Ensure environmental awareness among employees, sub-contractors and work force in order for them to understand the Environmental Specifications and their purpose. x Define and facilitate the implementation of communication channels including communication with the local beach users, local authorities and other interested and/or affected parties. x Make a connection with the Contractor on the implementation level, the Contractor and / or operator of the EMP on a regular basis throughout the stage of operation. x Advise the Contractor in writing about the violation of Environmental Specifications and notify the manufacturer and / or operator under indication of the Contractor. x Review and approve all the areas to be rehabilitated by the Contractor. x Maintain a registry of public complaints and report them to the Contractor and to the Proponent. x Accompany visits by MICOA and Local Authorities representatives. Before the start of each Construction/Installation operation the ESCO should make a site inspection, in order to: x Identify the environmental sensitivity of the area; x Identify problems of specific environmental or operation of the site; x Identify services whose installation is required (e.g. electricity); x Identify local storage or disposal of waste;
Environmental Management Specifications
During the EIA phase, several impacts were identified in the cable corridor proposed as a consequence of project activities. For those impacts mitigation measures were proposed, to be followed by the Contractors during the Construction/Installation and operational phases activities. Although some mitigation measures are specific to minimize potential negative impacts/enhance potential positive impacts, others are regarded as Good Practice (according to International Guidelines) to be followed. This EMP includes a set of Environmental Specifications that, in order to facilitate the use of it, are presented in accordance with the sequence of the different project phases: x Construction/Installation of the BMH x Installation of the cable between the BMH and the shoreline x Cable laying in Mozambique waters x Project operations
4.1
Methods Statement for Construction/Installation
The Contractor must submit Methods Statements of the following activities for ESCOs approval: o Construction/Installation camp activities o Diver Burial Operations o Pre Laid Shore End Vessel activities The Methods Statement should indicate what will be done to fulfil the Environmental Specifications requirements, specifying: x Timing and location of activities; x Requirements of materials, equipment and personnel; x Means of transport materials and / or equipment, inside and outside the enterprise; x Places for materials and equipment storage. x Emergency procedures. x The process of Construction/Installation and operation proposed and designed to implement the relevant environmental specifications. x Other information considered important by ESCO. The Methods Statement should be submitted at least ten days before the start of works planned to allow the analysis of the ESCO and its adoption. The activities of operation should not begin without the statements being adopted.
4.2
Project Environment Specifications
Table 1: Planning phase of the project. Phase ES Actions 1. Obtain all licences needed for each Construction/installation activity before the beginning of the works. 2. Submit required activities in the Method Statement to ESCO 3. Develop an emergency and contingency plan for major incidents and emergencies that may be associated with this project. 4. Develop a Communication Plan to prevent marine users, especially fishermen, of the foreseen activities. 5. Inform the following actors, according to the Communication plan, about schedule and traffic limitations of the project: a. Local Authorities on the work schedule so they can be site present. b. Key stakeholders, as Maputo Port, fishing centres, fishing institutes and Maritime Administration of the works and affected fishing areas. 6. Inform CFM/Port authorities, Maritime Administration and relevant marine traffic controllers of the foreseen activities, schedule and exclusion zones. 7. Develop Communication Plan for broadcasting vessel position to other marine users. 8. Responsible Contractor Contractor Contractor
Contractor
Planning
Capitel Capitel
Minimise planning Construction/Installation work in the beach during busy days as weekends and holidays to Contractor minimise use conflicts. ESCO Capitel 9. Beach working area should be as small as possible. Contractor 10. Whenever possible, structures should be prefabricated outside beach works area. 11. Plan work site layout with defined provisory material store, sanitary (a chemical toilet and clean water supply) and parking areas. 12. Storage requirements inside the vessel and on beach works: a. Fuel storage tank with adequate secondary containment and for temporary storage of other fluids such as lubricating oils and hydraulic fluids
Infra-structure planning
Phase
ES Actions 13. Develop a waste and sewage management plan for the beach and marine works. 14. Establishing a waste management hierarchy that considers prevention, reduction, reuse, recovery, recycling removal and finally disposal of wastes. 15. Avoiding and minimizing the generation of waste materials, as far as practicable. 16. Where waste generation can not be avoided but has been minimized, recovering and reusing waste. 17. Where waste can not be recovered or reused, treating, destroying, and disposing of it in an environmentally sound manner. 18. Providing portable spill containment and cleanup equipment on site and training in the equipment deployment. 19. Provision of suitable personal protection equipment. 20. storage: a. Hazardous wastes should be securely stored and have appropriate signage so as to prevent or control incidental releases to air, soil and water resources and in a location that prevents commingling with other incompatible wastes. Use physical separations if needed. b. Store in closed containers away from direct sunlight, wind and rain. c. Put in place secondary containment systems, with appropriate materials to contain wastes whenever ESCO considers necessary 21. The contractor should use as much as possible local vessels, equipment and local workforce. 22. Where feasible, use local workforce to maximize direct and secondary local employment opportunities. 23. Contractors will comply with the Mozambican Labour Law as well as relevant requirements of the International Labour Organization (ILO) to avoid use of child or forced labour. Specifically this includes compliance with: a. ILO Forced Labour Convention, No 29 1930 b. ILO Abolition of Forced Labour Convention, No 105 1957 c. ILO Right to Organise and Collective Bargaining Convention. No. 98.1949 d. ILO Equal Remuneration Convention. No. 100 1951 e. ILO Discrimination (Employment and Occupation) Convention, No. 111 1958 f. ILO Minimum Age Convention, No.138 1973 g. ILO Worst forms of Child Labour Convention, No. 182 1999 h. ILO Convention 87 on Freedom of Association and Protection of the Right to Organize i. UN Convention on the Rights of the Child, Article 32.1, 1989
Responsible Contractor
Contractor Capitel Contractor
Labour planning
10
Table 2: Construction/Installation phase of the project. Phase ES Actions 24. Explain all the ES and the measures included on the emergency and contingency plan to all the workers before the Construction/Installation activities begin. 25. Signalize and fence the Construction/Installation area. 26. Built protections in case of existing open trenches during the night. 27. Whenever possible, do the Construction/Installation works during the day, especially noisy activities. 28. Trench remainders should backfill open trenches. 29. Drip trays shall be used to collect the waste oil and lubricants during servicing and shall also be provided in construction areas. 30. Avoid or minimize the generation of wastes. 31. All the rubbish and refuse should be fitly placed in the containers in place for that purpose. 32. It is prohibit to burn solid wastes. 33. Waste should be stored in closed containers away from direct sunlight, wind or rain. 34. Ensure daily final disposal of waste generated each day. 35. Ensure handling, treating, and disposal of hazardous waste are reputable and legitimate enterprises, licensed by the relevant regulatory agencies, as Mavoco Industrial Landfill. 36. Offsite site disposal of spoil material (e.g. sand from the beach manhole) to be approved by ESCO and Maputo Municipality. 37. No material or equipment should be washed in the sea or out of appropriate places for the purpose. 38. Ensure that moving equipment is outfitted with audio back-up alarms. 39. Take all possible measures to avoid fuel, lubricant or other hazardous substances spills or leaks. 40. Verify if equipment and vehicles are operating correctly prior to construction work starts. 41. Equipments or vehicles refuel on site is not allowed. 42. Training workers on the correct transfer and handling of fuels and chemicals. 43. In case of oil and/or fuel spills that pollute the sand, that sand should be removed and disposed in an Responsible Contractor Contractor Contractor Contractor Contractor Contractor Contractor ESCO
Construction/Installation phase
Beach works
Contractor Contractor Contractor
11
Phase
ES Actions appropriate place as Mavoco Industrial Landfill. 44. Provision of suitable personal protection equipment. 45. Casuarinas tress should not be removed and avoid tree roots destruction through mitigation measures like manual working. 46. Minimize vegetation disturbance. Plants that need removal shall be kept apart for later replanting on site. 47. No go areas for the public should be limited. 48. Access and passage areas should be created for beach users 49. All traffic interference activities should only be done in low traffic-hours and with the presence of traffic Policemen. 50. Signalize properly access roads to minimize traffic interference 51. All damages caused by construction or related activities to services or other local infrastructures should be immediately remedied. 52. Built protection barriers and signalize in the areas with activity restrictions due to the new infrastructures, e.g. forbidden excavate. 53. Rehabilitate the construction area before leaving, with revegetation as the original site environment with native plant species. 54. Explain all the ES and the measures included on the emergency and contingency plan to all the workers before the Construction/Installation activities begin. 55. Implement a strong Communication Plan to prevent and encourage fishermen to remove their fishing equipment as nets and gears. 56. The boat traffic restriction corridor during marine operations cant be longer than 1km. 57. Sea operations should take as little time as possible. 58. Traffic boat restrictions should, as much as possible, be done in spring high tides in the afternoons/nights (which would be the less productive fishing period) to minimize fishing disturbances. 59. Minimise offshore Construction/Installation activities during whales peak migration period (June- November) or when a high number of dolphins is present. 60. Minimise Construction/Installation activities during low tide near Xefina Island to avoid disturbance of the marine birds. 61. Trenching and digging should be limited to the strictly necessary and no large sand movements should happen outside the site area.
Responsible
Contractor
Contractor
Contractor Contractor Contractor Contractor Capitel Contractor
Marine Works
Contractor
12
Phase
ES Actions 62. Wherever possible, bury the cable (to a target depth of 1m below the seabed). 63. Minimise working in neap tide conditions, to promote sediment dispersion. 64. Take all possible measures to minimize the resuspension of sediments during diver and PLSE burial as: a. Dont do sudden movements while excavating; b. Place and displace the PLSE and excavating equipments genteelly 65. All the rubbish and refuse should be treated according to the Waste Management Plan, approved by ESCO. 66. It is strictly prohibit dumping liquid or solid wastes to the sea. 67. Hazardous and domestic wastes should be stored on board the vessel until it can be appropriately disposed at a suitably equipped port, respecting requirements of the Basel Convention on Transboundery Shipment of Hazardous Wastes. 68. Implement requirements of relevant international shipping conventions including MARPOL Annex IV, Prevention of Pollution by sewage from ships, including: a. No sewage shall be discharged from marine vessels inside Maputo Bay or within 4 nautical miles (7km) of the nearest land, and any sewage discharged between 4 and 12 nautical miles (21km) shall be macerated and disinfected. Sewage equipment shall be regularly inspected and maintained to ensure optimum operation. b. Sewage/Grey water from cable lay vessels shall be macerated and discharged to the sea outside Maputo Bay. c. Potentially contaminated drainage, including drainage from machinery spaces and bilges should be treated with an oil/water separator to ensure that oil concentrations meet the standard of 15ppm maximum without dilution prior to discharge. 69. Signalize properly the prohibit navigation areas due to cable exposure or fluctuation; require the marine authorities help whenever possible. 70. In case of an incidental leak or spills take immediate action, according to the emergency and contingency plan. 71. No material or equipment should be washed in the sea or out of appropriate places for the purpose. 72. Minimize ship air pollution emissions in accordance with constructor specifications. 73. Cleaning up excessive waste debris and liquid spills regularly. 74. Issue Radio Navigational Warning and Notices to Mariners through the Maritime Administration and Maputo Port two days in advance of activities commencement.
Responsible
Contractor
Contractor
Contractor
Contractor Contractor Contractor Contractor Contractor Contractor
13
Phase
ES Actions 75. Verify that all equipment is maintained and operated according to manufactures specifications before go into work site area. 76. Ensure that the vessels navigational and communication equipment is working and adequately maintained to prevent collisions. 77. Project vessels will safely operate in accordance with the requirements of : a. International Loadline Convention, 1966 b. International Convention on Standards of Training Certification and Watchkeeping for Seafarers (STEW), and c. Convention on the International Regulations for Preventing Collisions at Sea, (COLREGs).
Responsible
14
Operation phase of the project There are no planned maintenance activities during operations. Physical intervention will only occur in the event of a need to repair a fault in the cable. In that case the ES to implement should follow the same ES as for Construction/Installation phase, beach works in case of the damage location in the beach and marine works in case of damage undersea. Decommissioning phase of the project Decommissioning is to be conducted in accordance with industry worldwide practices at the time: current practice is for cables to be abandoned in situ, and it is likely that this practice will continue. If so, there is no need to develop a decommissioning ES. However, if this presupposition changes the EMP should be updated accordingly.
Construction/Installation Monitoring Plan
The monitoring Plan is a requirement of Mozambican law as referred above. Monitoring should be done during the Construction/Installation phase by an environment expert, ESCO, who is familiar with EMP specifications. ESCO should accompany Construction/Installation works and take note in daily workplace inspection reports about the following issues. The monitoring results should appear in end of Construction/Installation report that is going to MICOA.
Indicator Vegetation removal
Methodology Natural Resources Verify the correct minimization of vegetation damages and replantante the original vegetation Direct observation of the existence of staining spots on the working areas Verify the circumstances of areas where incidents were reported Verify oil and lubricator work sources locations Verify existence of a complete spills contengency plan and relating equipments, according to EMP Specifications
Periodicity Once before and another in the end of the beach works Daily
Responsability ESCO
Oil and lubricator spots
ESCO and Contractor
Whenever there ESCO and is an incident Contractor Daily Just before the project begin and once a week during all project Every two days during beach works ESCO ESCO
Soil contamination
Besides the measures above stated, verify areas like waste disposal sites or cleaning areas
ESCO
15
Indicator Methodology Periodicity Contamination Verify the good implementation of sewage Once a week of waters managment plan Apply oil and lubricator spill control mitigation Once a week measures Solid wastes Direct observation of waste presence on the Daily work place Verify the good implementation of wastes managment plan (Collection and segregation) Verify the correct storage of the different types of wastes Soil erosion Verify beach landscape perturbation and signs of erosion Once a week
Responsability ESCO ESCO ESCO ESCO
Every two days
ESCO
Once before and another in the end of the beach works Human resources and socio economics features Daily As required
ESCO and Contractor
Fishermen disturbances
Verify if there are expressive constrains/disturbances in fishing activities Verify the need for compensations as a result of either lost work days or fishing gear damages Verify workers conditions and satisfaction levels
ESCO and Contractor ESCO and Contractor
Workers
Emergency prevention
Verify existence of a complete emergency programme and relating equipments, according to EMP Specifications
Twice; at start ESCO and finish of Construction/Ins tallation Just before the ESCO project begin and once a week during all project
16
Contingency plan
This programme tends to calculate the risk resulting from all the activities foreseen in the SEA Cable System project. Potential environment risk situations could be related with the marine activities (environment contamination through spills or leaks resulting from large vessels collision) and costal activities (risk of accidents in the construction area). However, due to constructions small extent, either in marine or beach works, the risk is considered to be low. Environment Specifications included in this EMP contains measures that tend to decrease this risk even further. After becoming clear that all the project components did not constitute any potential risk to Maputos Bay and its ecological balance based in size of the vessels involved in this project and the fact that they will follow all TDM installation/construction procedures there was no need for a deeper analysis of eventual contaminations inside the Bay through dispersion models. Potential risk situations could be specifically related with: a) Risk of seawater contamination Marine contamination can be related with the following activities: refuelling of support ad installation vessels and associated potential spills; and traffic collisions. Knowing that the amount of fuel stored aboard is similar as a recreational or fishing boats commonly present in Maputo Bay, the risk of marine accidents is considered to be low e easily mitigated with a correct communication channel between vessels In the other hand, the refuelling of the vessels, considered to be the higher risk operation, should only be done in the Port installations, lowering the risk of spills. b) Risk of Fire As mentioned above, the risk of fire in the Construction/Installation phase may be associated with the handling of flammable products such as petroleum products in the area of supply of fuel. This risk can be reduced to unlikely, but of medium to high magnitude, can be minimized with appropriate security measures as Navigation and Civil works Guidelines.
6.1
Response strategy
Although the environment risks resulting from marine and beach works are considered to be low, some response strategies should be planned and implemented correctly in the event of an accident. The main objectives of the response strategy are: x Ensure the safety of staff directly involved in the Construction/Installation activities and guarantee the security and protection of the area natural in which the project falls. x Minimize the possibility of a spill through the adoption of precautionary measures; x Monitor slicks of fuel, lubricating or oils where there is risk of soil and water contamination;
17
x x x
Contain the spills through Construction/Installation of ponds and spills retention drains in working areas. Drain any liquids from the washing areas, fuel, oils and lubricants supply and vehicles and machines maintenance for a decanting tank to then proceed with the oils separation to be deposited in the appropriate locations. In the case of incidents resulting in leakage of flammable products of greater scale, there should be coordination between the transit/marine police, firefighters, and local authorities of the event to ensure a speedy intervention to contain the spill.
The strategies choice will depend on their applicability, the availability of equipment and the opportunity for the various options. The response strategy that will be taken in the event of a spill of petroleum products will be dependent on a number of factors: x the spill extension and characteristics; x the environment characteristics where the spill occurred; x In their alleged behaviour on the spot; x Other factors incidental and weather conditions at the time of the accident, and x Balancing the environmental sensitivities in the path of the spill. Independently of any responding strategy to be used it should be applied the principle of Best Available Technology Without Excessive Cost Imposition (BATWECI). If any small spill occur during vessels operations (considered being the higher risk situations), those must be immediately solved using local and vessel means. All incidents must be communicated to the competent authorities. Amongst the options of response floating barriers, skimmers and absorbing materials can be used. The crew must be prepared and trained to the correct use of this equipments and respond immediately to any detected spill. The installations and supporting vessels should have an internal Contingency Plan specific of their own activities and should comply with the Mozambique National Oil Spills Contingency Plan.
6.2
Prevention
Precautionary measures are considered to be of most relevance in this situation so to restrain accidents and environment risks. Some precautionary measures recommended in the EIS and EMP includes the following: a) Handling of products - The Contractor shall take into account the environmental quality standards and emission of effluents specified in the Decree nr. 18/2004. b) Deposition of toxic products - It is forbidden for employees of the Contractor to deposit any substance that could contaminate the water (including oil) or deposit solid waste. c) Solid waste deposition- the Contractor Solid wastes shall be deposited in a deposition place approved by the ESCO and local authorities - already included in the tender documents for Contractor.
18
d) Fire plan The Contractor should comply with all the EMP measures and have adequate equipment in an adequate number to immediately stop fire in case of accidents. e) Good communication with other Maritime controllers Maritime controllers shall be notified in advance on the operation activities, through usual communication channels and be kept informed about ongoing activities and vessels locations. By constantly informing marine controllers, potential accidents could be prevented. f) Vessels navigability all vessels should be properly certified and comply with National and International security procedures, implementing the stated measures and specifications to retrench marine accidental risks.
6.3
Communications, duties and responsibilities during Construction/Installation activities
Regulatory Agencies MICOA is responsible for monitoring, inspection and review before, during and after the implementation of projects (in accordance with Decree 45/2004). MICOA Governmental Agency is also responsible for handling and management of waste, emissions and waste water management. The Institute of Maritime Navigation (INAMAR) and Maritime Administration are the overall responsible for monitoring any navigation activity within territorial waters and inside Maputo bay. Maputo Port/CFM and Institute of Navigation and Hydrograph (INAHINA) are also responsible for safe navigation inside the Bay Local Authorities have a responsibility to ensure road and sea safety through the monitoring of compliance of traffic regulations in force in Mozambique. The National Fire Service, have responsibility of intervention assistance in case of fire or other accident, so as to minimise the loss of human and infrastructural. Role and responsibilities CAPITEL, is responsible for managing the submarine fibre optical cable as well as to promote integration, participation and empowerment of public and private stakeholders. CAPITEL as the general responsible for conducting this project should ensure that all Construction/Installation activities are safely conducted and in accordance with the EMP proposed for the project and the spills contingency plan. To this end, the CAPITEL will carry out regular inspections, along with an independent consultant, and provide daily reports allowing monitor and assess the "performance" of the contractor and monitoring of security measures, during Construction/Installation works. CAPITEL should submit a work report to MICOA, at end of Construction/Installation phase.
19
In the event of an incident of leakage or fire, CAPITEL has the responsibility of full disclosure of all incidents to MICOA and other stakeholders, to alert civil authorities and other companies and organizations, if necessary.
The Contractor for the Construction/Installation should be suitably qualified to follow the recommendations made in the EIS and EMP. The contractor must comply with the EMP requirements and it is expected also to demonstrate commitment to the EMP at all levels in its own management structure. The contractor should have its own emergency equipment and support, and plan to mount a response in case of incidents by leakage or in case of fire. The equipment must be in good condition and ready for immediate use. The contractor must identify their individual responsibility for all matters of environment, health and safety during operations and implement relevant training for its staff to ensure they are fully qualified, with sufficient experience to respond to any emergency. The contractor should perform regular inspections to the environment, health and safety and provide reports to enable CAPITEL monitor and evaluate its "performance" on measures and targets reached at EIS and the EMP.
6.3.1 Communication
In the event of a spill and / or fire occurrence, the contractor and / or CAPITEL should properly report the incident details to authorities. The contractor and CAPITEL should designate the persons responsible for communication with related institutions.
20
7 Communication Plan
The Communication Plan aim is to inform fishermen and other marine users over the activities to take place, to prevent as much as possible the interference with their normal activity.. This Plan should be CAPITELs responsibility and all expenses should be assured. The Communications Plan should be implemented 2 weeks before the foreseen date for the beginning of the marine activities. It should involve, but not be limited, to the following stakeholders: Local Authorities (Marine and land authorities) Maputo CFM/Port authorities, Maritime Administration and relevant marine traffic controllers Fishermen (through fishing Centres and Local leaders) and fishing institutes as IIP and IDPPE Sea users (sports practising and leisure) Recreational boats Commerce vessels going to Maputo Port during marine activities Some of these tasks are considered to be standard procedures for the marine contractors. The Communication Plan should include at least the following activities: Clarification meeting to present project construction/installation activities in the overall scope of the project. Provide communication officers in the support vessels Advertise in the official navigation system CAPITEL should nominate at least one Communication Officer (CO) responsible for the implementation of all the above mentioned activities. The CO should maintain a record of meeting minutes and take pictures of the above mentioned activities implementation. The CO should at least: - Be familiar with the Communication Plan - Be familiar with local communities and fishermen activities within the Bay - Be a local resident or local authority whenever possible. - Should speak Portuguese and local languages clearly - Be able to communicate and explain traffic restrictions, activity schedule, and clarify possible doubts and listen to new suggestions. The CO should register and take into account stakeholders expectations, worries and suggestions especially from fishermen. CO should inform CAPITEL and the Contractor of those worries and suggestions and the Contractor should apply them whenever possible. The Communication Plan should be approved by independent Officers, as ESCO. CAPITEL should present to MICOA an implementation report of the Communication Plan, as a final Construction/Installation report annex.
21
7.1
Communications, duties and responsibilities during Construction/Installation activities
Regulatory Agencies MICOA is responsible for monitoring, inspection and review before, during and after the implementation of projects (in accordance with Decree 45/2004). The Maritime Administration and Maputo Port/CFM are the overall responsible for the radio broadcasting to ensure safe navigation inside the Bay. Local Authorities have a responsibility to ensure road and sea safety through the monitoring of compliance of traffic regulations in force in Mozambique. The National Fire Service, have responsibility of intervention assistance in case of fire or other accident, so as to minimise the loss of human and infrastructural. Role and responsibilities CAPITEL as the general responsible for conducting this project should ensure that the Communication Plan is implemented accordingly to what was established in terms of marine traffic restrictions and communication measures and as a result, no complains or compensation needs arises from the Construction/Installation activities. To this end, the CAPITEL will carry out regular inspections, along with an independent consultant, and provide daily reports allowing monitor and assess the "performance" of the contractor and monitoring of communication measures, during Construction/Installation works. CAPITEL should submit a work report to MICOA, at end of Construction/Installation phase. The Contractor should follow recommendations made in the EIS, the Contractor for the Construction/Installation should be suitably qualified to execute this project. The contractor must comply with the EMP and Communication Plan requirements and it is expected also to demonstrate commitment to those at all levels in its own management structure. The contractor should inform CO of all the foreseen activities and its schedule. The contractor should also cooperate with the CO as much as possible, allowing the Officer to patrol the area around the vessel exclusion zones and surroundings to assure that the area is clear of marine users before the vessel start its work. The contractor should perform regular inspections to marine and beach activities, and take note of stakeholders disturbances and accommodate suggestions, as far as possible, and provide reports to enable CAPITEL monitor and evaluate its "performance" on the Communication Plan measures and targets.
22
Expenses
The project should include in workforce costs the daily presence of an Environmental Site Control Officer (ESCO) and a Communication Officer (CO) during beach and marine works. The monitor programme should be assured by the ESCO and CO and the Contractor so there will be no need for additional costs.
23
Tanzania - Environmental Action Plan
ENVIRONMENTAL AND SOCIAL IMPACT STATEMENT SEACOM CABLE PROJECT January 2009
7-1
7 7.1
ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN Environmental and Social Management Framework
The Environmental and Social Management Plan is presented in full in section 7.3 below. The following discussion centres on the methods of implementation of the Management Plan. It is clear that the marine management (and monitoring) procedures apply to the construction phase and in a possible decommissioning phase (although it is not possible to plan in detail for a decommissioning management plan which is foreseen 25 years in the future). In the operation phase environmental management and monitoring will only be required in the case of emergency cable repairs. For all construction-related impacts (marine or terrestrial), the contractor will be required to adopt recognised industry good practice measures. Onshore environmental and social management during the operation phase is not anticipated, but if it proves to be necessary it will most likely relate to alterations in usage of the Cable Station, or increases in its capacity, and these will be dealt with on a case-by-case basis as and when they arise. The Environmental and Social Management Plan for the Project will be implemented at a number of levels, relating to Project phase, anticipated impacts, mitigation requirements and degree of follow-up monitoring required. With respect to the four project phases: o No management actions are required in respect of pre-construction o The majority of management actions relate to construction (and are further discussed below) o Management actions in the operation phase are only anticipated if repairs to the cable system are required o Any management actions in respect of the decommissioning phase will be specified in a Decommissioning Plan. SEACOM has included appropriate budget provisions for environmental and social management in all construction contracts (and will include such provisions in all future contracts, including those for repair and maintenance during the Project operation phase). SEACOM has also made provision for the implementation of its own environmental and social management commitments. In addition, SEACOM accepts full and overall financial responsibility for the implementation of the SEACOM Environmental and Social Management Plan for Tanzania and the SEACOM Environmental and Social Monitoring Plan for Tanzania.
7-2
7.2
Construction-related elements of the Environmental and Social Management Plan
The environmental and social management plan details the constructionphase commitments necessary for the proponent and construction contractors to meet the relevant environmental guidelines in line with the recommendations in the ESIA. The construction-related elements are summarised here. This component specific plan therefore provides details of construction-related methods and procedures that achieve compliance with the guidance contained in the ESIA. The plan follows the principles of ISO 14001 (1996) related to Environmental Management Systems, and provides a structure for the development, implementation and review of management actions and a process which ensures continuous improvement in the environmental management of construction activities. The plan: x x x x Includes an Environmental Policy statement; Addresses contractual and regulatory requirements; Provides procedures developed to address the environmental aspects and risks related to the construction; Provides for the implementation and operation of the management actions to ensure that structure and responsibilities are assigned; staff is trained, aware and competent; and that there is proper communication, documentation, operational control and emergency preparedness and response. Provides clear and precise organisational and technical procedures for implementation of the management actions which ensure that construction activities associated with potential environmental impacts are carried out in a controlled and responsible way. Provides checking and corrective action through monitoring and measurement (via the associated Environmental and Social Monitoring Plan). Provides records collection and storage, and programme audit;
x x
7.3 SEACOM Cable System Environmental and Social Management Plan
Sections 5 and 6 of this Environmental and Social Impact Assessment (ESIA) identify and address all aspects of the environment which will be affected by the SEA cable system. SEACOMs guiding principles for environmental and social management are embodied in the SEACOM Project Social and Environmental Policy, which is reproduced below:
7-3
SEACOM Project Social and Environmental Policy SEACOM is committed to designing, constructing and operating the SEA Cable System Project in a manner that ensures environmental protection and minimises social impacts and is in line with the Equator Principles. This commitment is central to the Projects Social and Environmental Management System (SEMS), which provides the framework for social and environmental management. In line with this commitment SEACOM will endeavour to: undertake its activities in line with applicable international standards and industry good practice; meet the requirements of national legislation in all the countries through whose territory the cable passes; manage construction activities, which SEACOM recognises as the main potential source of social and environmental impacts, in a sustainable manner in order to minimise such impacts; ensure social and environmental impacts during operation of the project are avoided or reduced as far as practicable; communicate and work closely with its contractors to ensure their understanding and shared commitment to conformance with this policy; provide training in social and environmental matters to key employees and contractor representatives where appropriate; and Implement all reasonable precautions to protect the health and safety of its employees and promote the health and safety of contracted workers.
These objectives shall be met via provision of adequate resources by top management within SEACOM to support the implementation of the SEMS. This policy and other elements of the SEMS shall be regularly reviewed and updated in order to ensure its continued applicability to the activities of the SEA Cable Project.
Source: SEACOM Social and Environmental Management System
7-4
7.3.1. Project Elements Requiring Specific Management Measures The ESIA concludes that there are six aspects which have an impact on the environment where control and mitigation measures are called for, namely: o The operation of laying the cable in waters of 50m depth and more, o The operation of laying the cable in the shallow water area between the marine reserves of Mbudya and Fungu Yasin, outside their 800m buffer zones o The operation of crossing the outer and inner reefs offshore on the approach to Kunduchi north of Dar es Salaam o The operation of trenching the cable from the low tide mark to dry land o The works involved in constructing the Cable Station o Any works involved in repairing damage to the cable at any point and at any time during the projected 25 year life of the project
7.3.2. Environmental Aspects The environmental aspects which may be impacted by the project are those which will be directly affected during cable laying activities, and are therefore located in the immediate vicinity of the cable route. Practically all such impacts will occur within a few metres of the cable itself, and any impacts occurring outside a corridor extending 100m on either side of the cable route will be minor in scale and/or transient in nature. The environmental aspects that may be impacted are: o The benthic fauna and flora o The pelagic and planktonic fauna and flora o The fauna and flora of the reefs to be crossed o The activities of fishermen close to the path of the cable o Other maritime activities such as commercial shipping, tourism and recreational boating and diving.
7-5
7.3.3. Management and Mitigation Measures for Specific Impacts A matrix of impacts and their severity is presented in section 5. The method of controlling and mitigating these impacts is essentially planning and management. The mitigation measures to be implemented via the Projects social and environmental management system are presented in tabular form as Table 7-1 and are also discussed below: Where Project construction, operations or decommissioning will directly impact significant benthic habitats, including reefs deemed to be of biological importance and requiring special conservation measures, the environmental baseline in such areas will established before any project activities are begun. A marine survey exercise will be conducted immediately before activities commence and in order to assess if the Project activities have had any measurable impact, a marine survey will be conducted within one month after activities in the area are completed. Cable laying will be monitored to minimize environmental impacts and safeguard the coral and seagrasses as follows: o During cable laying over reef, the cable will first be floated with buoys over the reef itself. By incremental decoupling of the buoys the cable will be carefully lowered onto the reef, and will be guided into position by divers while they monitor its position to minimize any potential damage to the reef. o During cable burial by diver hand jetting, divers will also monitor the process to ensure environmental impacts to seagrasses and coral as a result of sediment in the water column will be minimized.
During the operational phase of the Project, if repairs are required as a result of a fault or damage to the cable they will need to be implemented in the shortest possible time in view of the economic and social importance to the country of returning the cable system to operations. The protocol for any marine surveys that may be required is presented in Table 7-2.
7-6
Table 7-1: SEACOM Cable System Environmental Management Plan for Tanzania
Item No.
Project Phase
Activity
Potential Direct Impact
Applicable Location
Priority (H/M/L)
Cost (TSh)
Responsible Parties
Construction
Marine Cable Laying
Spill of fuel, oils etc.
Provision of adequate secondary containment for fuel storage tanks and for the temporary storage of other fluids such as lubricating oils and hydraulic fluids. Training workers on the correct transfer and handling of fuels and chemicals and the response to spills. Preparation of a spill response plan.
Entire marine cable route in Tanzanian waters
Included in Construction Contract Included in Construction Contract Included in Construction Contract Included in Construction Contract Included in Construction Contract Included in SEACOMs environment al and social managemen t program
Construction Contractor EHS Manager Construction Contractor EHS Manager Construction Contractor EHS Manager Construction Contractor EHS Manager Construction Contractor EHS Manager SEACOM
Construction
Marine Cable Laying Marine Cable Laying Marine Cable Laying Marine Cable Laying
Spill of fuel, oils etc. Spill of fuel, oils etc. Spill of fuel, oils etc. Spill of fuel, oils etc.
Entire marine cable route in Tanzanian waters Entire marine cable route in Tanzanian waters Entire marine cable route in Tanzanian waters Entire marine cable route in Tanzanian waters
Construction
Construction
Provision of on board portable spill containment and cleanup equipment and training in the deployment of equipment. Provision of suitable personal protection equipment.
Construction
Construction
Marine Cable Laying
Disruption to activities of fishermen and other seafarers
Maintain consultation with fishermen potentially affected during the cable laying operations and procedures and maintain consultation with other potentially affected parties such as tourist traffic and marine transport and shipping (for details see Table:73)
7-7
Item No.
Project Phase
Activity
Applicable Location
Priority (H/M/L)
Cost (TSh)
Responsible Parties
Construction
Marine Cable Laying
Adverse effects on the marine environment
Establish baseline conditions prior to start of cable laying and conditions after completion of cable laying (for details see Table: 7-2)
10 points within 500m of reef crossing points + one point every 20km along route within Tanzanian territorial waters
10,000,000 indicative budget
SEACOM
Construction
Marine Cable Laying
Accidents involving other seafarers Accidents involving other seafarers Construction emissions (e.g. SO2, CO2 and NOx) leading to impaired air quality and possible acid precipitation during rains Temporary water quality effects resulting from suspended sediments
Mitigated by cable installation design, careful supervision, and compliance with

SUMATRA requirements regarding safety in Tanzanian waters Maintenance of comprehensive insurance cover Use of such low emission SO2 emission fuels as are available in Tanzania.
Included in Construction Contract Included in Construction Contract Included in Construction Contract
Construction Contractor EHS Manager Construction Contractor EHS Manager Construction Contractor EHS Manager
Construction
Marine Cable Laying Marine Cable Laying
Entire marine cable route in Tanzanian waters Entire marine cable route in Tanzanian waters
10
Construction
12
Construction
Marine Cable Laying
No mitigation required (other than use of industry good practice) due to insignificant nature of impact (less than 24hrs)
Included in Construction Contract
Construction Contractor EHS Manager
7-8
Item No.
Project Phase
Activity
Applicable Location
Priority (H/M/L)
Cost (TSh)
Responsible Parties
13
Construction
Marine Cable Laying
14
Construction
Marine Cable Laying
15
Construction
Marine Cable Laying
16
Construction
Marine Cable Laying
Disturbance to seagrasses and other feeding and nursery habitats Interaction with other infrastructure on the seabed, e.g., pipelines and cable crossings Cable placement in relation to anchorages, shipping/dred ge channels Noise from construction equipment and vessel
Spill of fuel, oils etc.
No mitigation required (other than use of industry good practice) due to insignificant nature of impact (less than 24hrs)
Sound cable installation design and careful supervision
Sound cable installation design, careful supervision and adherence to industry and international standards
Equipment and vessel will conform to international standards for noise and emissions
Provision of adequate secondary containment for fuel storage tanks and for the temporary storage of other fluids such as lubricating oils and hydraulic fluids.
Included in Construction Contract Included in Repair Contract
Construction Contractor EHS Manager Repair Contractor EHS Manager
17
Operation
Marine Cable Repair (if required)
7-9
Item No.
Project Phase
Activity
Applicable Location
Priority (H/M/L)
Cost (TSh)
Responsible Parties
18
Operation
19
Operation
20
Operation
21
Operation
22
Operation
Marine Cable Repair (if required) Marine Cable Repair (if required) Marine Cable Repair (if required) Marine Cable Repair (if required) Marine Cable Repair (if required)
Spill of fuel, oils etc. Spill of fuel, oils etc. Spill of fuel, oils etc. Spill of fuel, oils etc. Disruption to activities of fishermen and other seafarers
Training workers on the correct transfer and handling of fuels and chemicals and the response to spills. Preparation of a spill response plan.
Entire marine cable route in Tanzanian waters Entire marine cable route in Tanzanian waters Entire marine cable route in Tanzanian waters Entire marine cable route in Tanzanian waters Entire marine cable route in Tanzanian waters
Provision of on board portable spill containment and cleanup equipment and training in the deployment of equipment. Provision of suitable personal protection equipment. Maintain consultation with fishermen potentially affected during the cable laying operations and maintain consultation with other potentially affected parties such as tourist traffic and marine transport and shipping (for details see Table: 7-4) Compliance with SUMATRA requirements regarding maritime safety in Tanzanian waters Maintenance of comprehensive insurance cover Scheduling to avoid heavy rainfall periods (to the extent practical)
23
Operation
24
Operation
25
Construction
Marine Cable Repair (if required) Marine Cable Repair (if required) Terrestrial Construction
Accidents involving other seafarers Accidents involving other seafarers Soil erosion and sedimentation due to stormwater runoff
Entire marine cable route in Tanzanian waters Entire marine cable route in Tanzanian waters All terrestrial work areas
Included in Repair Contract Included in Repair Contract Included in Repair Contract Included in Repair Contract Included in SEACOMs environment al and social managemen t program Included in Construction Contract Included in Construction Contract Included in Construction Contract
Repair Contractor EHS Manager Repair Contractor EHS Manager Repair Contractor EHS Manager Repair Contractor EHS Manager SEACOM
Construction Contractor EHS Manager Construction Contractor EHS Manager Construction Contractor
7-10
Item No.
Project Phase
Activity
Applicable Location
Priority (H/M/L)
Cost (TSh)
Responsible Parties
26
Construction
Terrestrial Construction
27
Construction
28
Construction
29
Construction
Soil erosion and sedimentation due to stormwater runoff Soil erosion and sedimentation due to stormwater runoff Soil erosion and sedimentation due to stormwater runoff Soil erosion and sedimentation due to stormwater runoff
Mulching to stabilise exposed areas
All terrestrial work areas
Construction Contractor
Revegetating areas promptly
Reducing or preventing off-site sediment transport through use of settlement ponds, silt fences, etc and modifying or suspending activities during extreme rainfall and high winds to the extent practical. Segregating or diverting clean water runoff to prevent it mixing with water containing a high solids content.
30
Construction
Dust pollution from construction activity
Contractor to employ dust reduction means (watering road) as required
7-11
Item No.
Project Phase
Activity
Applicable Location
Priority (H/M/L)
Cost (TSh)
Responsible Parties
31
Construction
Noise pollution from contractor machinery Blockage of entrances, exits and foot paths Blockage of drainage systems and possible disruption of existing infrastructure
Interrupted access to shops, commuter bus stops and parking space Reduced number of customers and temporary closure of shops
32
Construction
Land works to be limited to daylight hours (this is neither possible nor necessary for the marine vessel); machinery to be in good condition and equipped with noise reduction mufflers where necessary Contractor to adhere to best practice
Included in Construction Contract Included in Construction Contract
33
Construction
Contractor to adhere to best practice standards. Diversion of any infrastructure expected to be impacted, with subsequent restoration.
34
Construction
If necessary, provide alternative temporary bus stops following consultation with TANROADS and or Municipal authorities
35
Construction
Early consultation with the community informing them of the schedule of activity to allow proper planning
7-12
Item No.
Project Phase
Activity
Applicable Location
Priority (H/M/L)
Cost (TSh)
Responsible Parties
36
Construction
37
Construction
Terrestrial Construction Terrestrial Construction
38
Construction
39
Construction
Loss of bay area used for docking and selling fish catch Disturbance of natural drainage Disruption to activities of the local population and other stakeholders Benefits to directly affected local population Disruption to activities of the local population and other stakeholders Various, depending upon extent of decommission activities
Short term impact, but if appropriate an alternative space will be found in advance to accommodate the fishermens market area.
To be avoided by design and careful supervision and adherence to national and international construction standards. Maintain consultation with the local community potentially affected during terrestrial construction and inform and maintain consultation with other potentially affected stakeholders (for details see Table:7-3) SEACOM will work with the local fishers community in the Kunduchi Beach area through the community consultation process to assist with limited and focused community development activities Maintain consultation with the local community potentially affected during terrestrial construction and inform and maintain consultation with other potentially affected stakeholders (for details see Table: 7-4) Prepare and implement a decommissioning plan that will ensure compliance with decommissioning procedures which are recognised international standards for the cable industry at the time of decommissioning
Kunduchi Beach area
Included in Construction Contract Included in SEACOMs environment al and social managemen t program 5,000,000 indicative budget
Construction Contractor SEACOM
SEACOM
40
Operation
Terrestrial Repairs (if required)
41
Decommission
Decommission Cable System
Entire Cable System
Included in SEACOMs environment al and social managemen t program Included in SEACOMs environment al and social managemen t program
SEACOM
SEACOM
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Table 7-2: Marine Survey Procedures
Survey protocols for benthic, planktonic and pelagic life

Parameters to be surveyed Total Suspended Solids Survey method 10 litre sample at 20 m Data assessment method Subsequent centrifugation followed by separation and weighing Locations to be Surveyed 10 points within 500m of reef crossing points + one point every 20km along route within Tanzanian territorial waters As above Frequency of surveying One event before start of construction and one event after completion of construction As above
Turbidity
Secchi Disk
Depth to invisibility
Total biomass
From same sample as above
Identification of 3 commonest phytoplankton
From same sample as above
Identification of 3 commonest zooplankton Identification of macrofauna
From same sample as above Reports from fishermen and verification Diving
Subsequent centrifugation followed by biomass assessment using carbon digestion Initially microscopic examination and assessment of density in field and parataxonomic identification Initially microscopic examination Visual identification
as above
as above
as above
as above
as above
as above
Any points en route where fishing is noted
as above
Reef condition, outer and inner reef
Photograph and written assessment.
Reef fauna and flora outer and inner reef
Diving
Photograph and written assessment.
Selected points within 100m either side of maximum elevation of reef crossing Not more than 3 points along line as above
before work commences, after work is finished
as above
7-14
Survey protocols for benthic, planktonic and pelagic life

Parameters to be surveyed Beach condition, area exposed at maximum low tide Beach fauna and flora, are exposed at maximum low tide Survey method Diving Data assessment method Photograph and written assessment. Photograph and written assessment, sample collection of selected fauna and flora. Locations to be Surveyed as above Frequency of surveying as above
Low tide inspection
as above
as above
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The main risk to pelagic and planktonic life from Project activities would be through pollution resulting from discharges from Project vessels that exceed regulatory and guideline limits. It is not anticipated that any such damage will occur, either by the long-term presence of Project vessels in one area or by accidental discharge of any pollutant such as oil or fuel. The contractor carrying out the construction work is required to comply with international obligations in respect of marine operations (principally those set out in MARPOL 73/78 and the International Finance Corporation Environmental Health and Safety Guidelines for Shipping). These obligations include the establishment and implementation of risk-based management programs for the handling and storage of hazardous materials, the training of workers in the handling of such materials and the response to spills, the preparation of a spill response plan, and the provision of on-board spill containment and clean-up equipment. The procedures outlined in Table 7-1 apply and will be followed. In all areas within Tanzanian jurisdiction fishermen and fishing groups will be given advance notice before construction operations commence. This warning will be renewed 48 hours before starting work in the areas concerned. An explanation of the nature of the work and the avoidance measures to be taken will be distributed to affected parties - who have already been consulted and informed during the preparation of the EIA. The protocol for these measures is to be found at Tables 7-3 and 7-4.
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Table 7-3: Procedure for community contact and participation during Project construction
OUTLINE PROTOCOL FOR COMMUNITY CONTACT AND PARTICIPATION DURING THE PROJECT CONSTRUCTION PERIOD 1 1.1 Groups to be contacted Persons depending on the sea for their livelihood; these comprise fishermen who operate in groups using largely small outrigger canoes and those who user larger vessels with sail or sometimes outboard motors. All these groups are operating within 4 km of the coastline. There are also small numbers of persons collecting mollusks etc from the shallow areas over reefs. Those operating close to the shore are contacted by discussion and informing the local administration chairman or executives; there are associations for fishermen, which includes those habitually operating further from the coast but most of the members will have little contact with the areas concerned. Persons using the marine area for recreation and relaxation. The area of Silver Sands is itself a tourist destination but mainly for either local citizens or overland travelers. Because the land construction operation is limited in physical area the operators of Silver Sands will be invited to a forum and asked to summon their neighbours. The local chairman will be informed of this and fully involved, so that the open meeting will be attended by all concerned. The minutes of these meeting will be posted at Silver Sands and dispatched elsewhere as decided by the attendees and the local chairmen. Groups and businesses transiting through the area, including ferry operators. These groups are best contacted via SUMATRA, the Surface and Marine Transport Agency who will advise as to who should be contacted. The local Yacht club some distance away will also be informed and given contact numbers and possibly a website to improve exchange of ideas. Residents and their representatives in the area of the Cable Station. Local government is extremely effective and all embracing and the local government chairman (village level) will declare who should be specifically be informed and consulted. Government boards and agencies with responsibility for the geographical or operational areas concerned. This should include the Ministry of Livestock responsible for fisheries who will designate their local representative, NEMC who are overseeing the environment in any case, and Sumatra. The national parks board will be informed in respect of the adjacent Marine Reserves. In Zanzibar the concern is both with transit in which case the marine transport agency of Zanzibar will be informed and fisheries in which case the local ministry will designate a liaison officer. Matters of security may require the ministry of the interior to be informed and this will be initiated via SUMATRA. Method of interaction Information and discussion with officials from Kinondoni District, Tegeta Subward will decide which adjacent hamlets or streets are concerned and will authorise and initiate contact which will then be followed up by mutual agreement. In the case of fishermen and similar groups associations or groups with elected officials will be contacted to arrange an open meeting. In the case of residents the chairman and executive officer at sub village ("kitongoji") will arrange for an open meeting. In all cases the ESIA will be presented together with a summary in Kiswahili and discussion invited. This summary will have been prepared by one of the Tanzanian team and will not have been passed through the Institute of Kiswahili Studies at UDSM
1.2
1.3
1.4
1.5
2 2.1
2.2 2.3 2.4
7-17
OUTLINE PROTOCOL FOR COMMUNITY CONTACT AND PARTICIPATION DURING THE PROJECT CONSTRUCTION PERIOD 2.5 SEACOM will offer continued liaison with each community group, to continue discussion and review actions. 2.6 A secretary will be appointed at all meetings and minutes will be compiled and reviewed by SEACOM and the representatives of each community group before being made available to the community group and any other parties deemed by the community representatives, SEACOM and NEMC to be stakeholders 3 Aims of collaboration 3.1 To ensure that opportunities for collaborative synergy are embraced. 3.2 To ensure that no grievances remained unaired. 3.3 To mitigate undesired and unforeseen side effects of the operation on the groups or communities concerned in a collaborative manner, whilst ensuring that these are within the realms of the responsibilities of either party and are in accordance with laws and policies of Tanzania 4 4.1 Geographical area In the case of the marine section of the cable the following groups or persons known to be operating or working within 1km either side of the cable route: x None are known at present, this will vary with time and can only be determined by preliminary survey shortly before operations are envisaged. From the outer reef to the landing point, any groups as defined above in 4.1, plus all residents of the administrative area concerned (see 2.3 above) including the officials and elected officers mentioned therein. When national board or regulator agency is concerned, that agency will designate the local and other officers to be consulted. Timing These procedures will be initiated when approval is given by the National Environment Management Agency and in any case before construction operations commence. The following schedule of meetings will apply: x One meeting before construction operations commence x One meeting immediately after the completion of construction This schedule is based on the short time frame for marine construction operations. However, where construction operations are more extended, for example for the Cable Station, interim meetings will be conducted at the request of either party. Reporting SEACOM will be responsible for the preparation of minutes of each meeting. This will include a list of actions required. These reports will be circulated to meeting attendees prior to broader circulation as required, including submission to NEMC.
4.2
4.3 5 5.1
5.2
6 6.1
6.2
N.B This Procedure for community contact and participation deals with maintaining consultation with fishermen potentially affected during the cable laying operations and procedures for informing and maintaining consultation with other potentially affected parties such as tourist traffic and marine transport and shipping.
7-18
Table 7-4: Procedure for community contact and participation during Project operation (if required)
OUTLINE PROTOCOL FOR COMMUNITY CONTACT AND PARTICIPATION DURING THE PROJECT OPERATIONAL PERIOD (IF REQUIRED) 1 1.1 1.2 1.3 1.4 1.5 2 2.1 2.2 2.3 2.4 2.5 Groups to be contacted (based on groups consulted during construction phase, modified as required) Persons depending on the sea for their livelihood. Persons using the marine area for recreation and relaxation. Groups and businesses transiting through the area. Residents and their representatives in the area of the terminal station. Government boards and agencies with responsibility for the geographical or operational areas concerned e.g. Sumatra. Method of interaction Information and discussion with officials concerned at District, then at village level. In the case of fishermen and similar groups there is an association or group with elected officials who will be contacted to arrange and open meeting. In the case of residents there is a chairman and executive officer at sub village ("kitongoji" who will arrange for an open meeting). SEACOM will offer continued liaison with each community group, to continue discussion and review actions. A secretary will be appointed at all meetings and minutes will be compiled and reviewed by SEACOM and the representatives of each community group before being made available to the community group and any other parties deemed by the community representatives, SEACOM and NEMC to be stakeholders. Aims of collaboration To ensure that opportunities for collaborative synergy are embraced. To ensure that no grievances remained unaired. To mitigate undesired and unforeseen side effects of the operation on the groups or communities concerned in a collaborative manner, whilst ensuring that these are within the realms of the responsibilities of either party and are in accordance with laws and policies of Tanzania. Geographical area In the case of the marine section of the cable any groups or persons operating or working within 1km of the area of repair operations. When national board or regulator agency is concerned, that agency will designate the local and other officers to be consulted.
3 3.1 3.2 3.3
4 4.1 4.3
N.B This Procedure for community contact and participation deals with maintaining consultation with fishermen potentially affected should it be necessary during the cable system operations, and procedures for informing and maintaining consultation with other potentially affected parties such as tourist traffic and marine transport and shipping
Commercial shipping is a 24 hours operation, and tourism and yachting can involve vessels moving at considerable speed and also moving at night. Before construction operations commence a timetable with specific locations will be placed in the hands of the authorities controlling movement of vessels
7-19
(SUMATRA) and in the hands of the Yacht clubs and tourist hotels which operate vessels. The protocol for this work may be found also in Tables 7-3 and 7-4.
7.3.4. Special Considerations for Certain Areas The trenching operations to bring the cable ashore require special management measures for the section of the cable route between the extreme low tide line and the Cable Station. Firstly, the environment in this section of the cable route has already been investigated and it has been concluded that there are no valuable habitats which may be damaged. However, the operation of trenching causes increased turbidity and sediment deposition, the effect of which could extend beyond the immediate vicinity of the cable route, depending on wind and currents. The contractor carrying out these activities will adhere to standard international practices, which are summarised in Table 7-1 and which have proved adequate and effective in other international cable system projects. Construction of the Cable Station is a small scale operation involving less activity that that of building a small house, so no special measures are called for beyond normal regulatory compliance and good practice in construction. There is no special management protocol for this operation, but the procedures outlined in Table 7-1 apply and will be followed. Repair of cable damage is a very serious matter from an operational perspective. Once the cable system is operational any break in service can cause huge economic damage. Locating the fault in an operational cable is done remotely, after which a specialized cable repair vessel would be mobilized to the location. Effecting the repair would involve retrieving the cable from its position on or below the seabed to the surface. After the cable is lifted onto the cable vessel it would be repaired and relaid on or below the seabed, in a procedure very similar to that of the original laying of the cable. The ecological and environmental consequences of cable repair work are practically identical to those considered and managed in the initial laying of the cable during the Project construction phase. The main difference is in the social impact, and the time available to provide prior warning to fishermen and other users of the sea. It will take some time for the repair vessel to reach the location of the fault, and it is therefore likely that there will be sufficient time to adequately inform and forewarn other seafarers in the area. It is therefore the case that the management measures utilised in cable laying operations will also apply in the case of repair work and that no further, special operational procedures need to be defined.
8-1
ENVIRONMENTAL AND SOCIAL MONITORING PLAN
The monitoring framework may be considered as divided into 3 main tiers, which reflect the breadth of the measures to be taken. Together these will be integrated with the social and environmental management system (SEMS) controlling the development of the overall SEACOM Cable System Project. Independent environmental and social auditing will be a function of the SEMS.
8.1 Tier 1 Planning
Tier 1 represents the level at which the monitoring will be integrated into the Kinondoni Municipal and Msasani ward management plans. It is recommended that this integration be an ongoing process that will react to changes in District priorities, proponent requirements and the outputs of the environmental monitoring programme. Key to the success of Tier 1 planning will be communication and commitment. It is therefore recommended that an environmental committee be established whose membership should include a representative of the proponent, the environmental authority (NEMC) and of the district, as permanent or invited members. This committee should meet on a defined basis (every 2 months during construction and once after the first year of operations, thereafter as required by all parties, noting that it is unlikely that any matters will arise during operations except in the event of an emergency repair) to discuss results from the monitoring programme, and make amendments to the mitigations in place and/or the monitoring programme if necessary.
8.2 Tier 2 Planning
Tier 2 of the monitoring framework will focus on ensuring that mitigation measures proposed in the ESIA are efficiently implemented and that the required routine monitoring is carried out during the construction phase and (if required) during the decommissioning phase. Monthly meetings between project representatives, community leaders in the project area and local government should take place to review success and any potential failures in the mitigation and monitoring regime. Minor issues should be dealt with immediately at this level; serious issues should be referred up to regular or extraordinary meetings of the Tier 1 committee.
8.3 Tier 3 Planning
Tier 3 of the monitoring framework relates specifically to the construction phase and most importantly to the mode of work and behaviour of the construction contractor and the necessary mitigation and monitoring required for the Project to
8-2
fulfil its obligations under national guidelines and national and international best practise. In practice the construction-related requirements of the environmental and social monitoring plan will provide the basis for Tier 3 planning and monitoring. The environmental and social monitoring plan is presented in tabular form as Table 8-1.
8-3
Table 8-1: SEACOM Cable System Environmental Monitoring Plan for Tanzania
No.
Project phase
Activity
Monitoring Measure(s)
Monitoring Parameters
Monitoring Frequency
Priority (H/M/L)
Responsible Parties
Construction
Marine Cable Laying
Construction
Marine Cable Laying
Provision of adequate secondary containment for fuel storage tanks and for the temporary storage of other fluids such as lubricating oils and hydraulic fluids. Training workers on the correct transfer and handling of fuels and chemicals and the response to spills.
Construction contractor self-monitoring, and compliance reporting to SEACOM
Construction
Marine Cable Laying
Preparation of a spill response plan.
Construction
Marine Cable Laying
Provision of on board portable spill containment and cleanup equipment and training in the deployment of equipment.
Construction
Marine Cable Laying
Provision of suitable personal protection equipment.
International Finance Corporation Environmental Health and Safety Guidelines for Shipping; MARPOL International Finance Corporation Environmental Health and Safety Guidelines for Shipping; MARPOL International Finance Corporation Environmental Health and Safety Guidelines for Shipping; MARPOL International Finance Corporation Environmental Health and Safety Guidelines for Shipping; MARPOL International Finance Corporation Environmental Health and Safety Guidelines for Shipping; MARPOL
Monthly report to SEACOM
8-4
No.
Project phase
Activity
Priority (H/M/L)
Responsible Parties
Construction
Marine Cable Laying
Maintain consultation with fishermen potentially affected during the cable laying operations and procedures and maintaining consultation with other potentially affected parties such as tourist traffic and marine transport and shipping (for details see Table: 7-3)
Establish baseline conditions prior to start of cable laying and conditions after completion of cable laying Compliance with SUMATRA requirements regarding safety in Tanzanian waters
Retain records of consultation meetings, including lists of attendees, key items discussed and conclusions.
OUTLINE PROTOCOL FOR COMMUNITY CONTACT AND PARTICIPATION DURING THE PROJECT CONSTRUCTION PERIOD
Each consultation meeting
SEACOM
Construction
Marine Cable Laying Marine Cable Laying
Retain records of surveys
Monitoring protocols for benthic, planktonic and pelagic life

SUMATRA requirements regarding safety in Tanzanian waters comprehensive insurance cover
Each survey event
SEACOM
Construction
Construction contractor self-monitoring, and compliance reporting to SEACOM Construction contractor self-monitoring, and compliance reporting to SEACOM
Construction
Marine Cable Laying
Maintenance of comprehensive insurance cover
8-5
No.
Project phase
Activity
Priority (H/M/L)
Responsible Parties
10
Construction
Tier 1: Establishment of an environmental committee whose membership should include a representative of the proponent, the environmental authority (NEMC) and of the district, as permanent or invited members.
11
Construction
Tier 2: meetings between project representatives, community leaders in the project area and local government
12
Construction
Tier 3: relates specifically to the construction phase and most importantly to the mode of work and behaviour of the construction contractor and the necessary mitigation and monitoring required for the Project to fulfill its obligations
Monitoring will be integrated into the Kinondoni Municipal and Msasani ward management plans. It is recommended that this integration be an ongoing process that will react to changes in District priorities, proponent requirements and the outputs of the environmental monitoring programme. Review success and any potential failures in the mitigation and monitoring regime. Minor issues should be dealt with immediately at this level; serious issues should be referred up to regular or extraordinary meetings of the Tier 1 committee SEACOM overview and control of construction contractor on site
Review of monitoring data and reports prepared for SEACOM by the construction contractor
This committee should meet on a defined basis (every 2 months during construction)
SEACOM, NEMC, District representatives
Review of monitoring data and reports prepared for SEACOM by the construction contractor
Monthly during construction
SEACOM, Community, Local Government representatives
national guidelines and national and international best practise
Continuous
SEACOM
Kenya - Environmental Action Plan
Marine Survey Phase Activity Marine Survey Assessment conducted using specialized and custom made ships to navigate the Indian Ocean and identify possible routes for the cable Potential Adverse Impacts Uncontrolled discharges of wastes from work vessels Use of modern survey vessels compliant with international standards for waste management during the survey During the Marine survey SEACOMs Contractors Mitigation Measure(s) Implementation Schedule Responsibility Budget (US$)
Cost factored in the contract for project development
Accidents causing spills from the survey vessels
Use of modern survey vessels compliant with international standards in respect of spill prevention and control management During the Marine survey Employment of a professional and qualified crew with experience in undertaking marine survey works in the deep sea SEACOMs Contractors
Cost factored in the contract for project development
Cable Installation Phase (Construction) Activity Cable laying on the continental shelf will involve excavations to bury the cable Adverse Impacts Sediment disturbance hence increased turbidity and effects on the marine flora and fauna Mitigation Measure(s) Implementation Schedule Responsibility Budget (US$)
Support the excavated material until the cable is positioned in the trench, thereby allowing the seabed material to fall back into the trench.
The cable path has avoided the areas of sensitive ecosystem (refer section 4.5) Use of survey before inshore cable laying to select routes that avoid live reef. Special care has been taken to avoid project exposure of sensitive areas to prolonged high turbidity (Refer to section 4.5) If areas are identified where high wave action induces significant turbidity effects, schedule cablelaying activities to coincide with projected periods of lower wave action.
During the cable laying period
SEACOMs Contractors
Cost factored in the contract of cable laying company
Activity The vessels that lay the cable use fuel oil to operate and could contaminate the water through discharges and accidental spills Onshore activities will involve the construction of a trench and a cable station
Adverse Impacts Discharges and accidental spills from vessels
Mitigation Measure(s)
Implementation Schedule
Responsibility
Budget (US$) Cost factored in the contract of cable laying company
Use of modern cable laying vessels compliant with international standards in respect of spill prevention and control and waste management during the laying phase of the cable
SEACOMs Contractors
Effects of trenching on flora and fauna. The trenches will be backfilled after the ducts are laid, and the surface conditions existing prior to construction will be reinstated over the area impacted by trenching activities.
SEACOMs Contractors
Part of the contract cost
Revegetation and restoration of the rock face at the landing point will be undertaken after onshore cable laying, if necessary. Construction related activities in cable laying; construction of the cable station Noise pollution and disturbances from motorised equipment and machinery
Noise reduction will be undertaken by ensuring that all the equipment in use like generators, fleet vehicles are equipped with noise mufflers to reduce noise disturbances
During the construction and cable laying period
SEACOMs Contractors
Cost factored in the contract of cable laying
Activity
Adverse Impacts
Responsibility
Budget (US$) company
Use of noise suppression shields and mufflers and the location of noise generating sources away from residential and other noise sensitive receptors to meet the ambient noise levels of the IFCs General EHS Guidelines. Air and dust Pollution emitted from and generated by motorised machinery and equipment
Procure equipment and machinery that comply with international air emission standards During the construction and cable laying period
Sprinkle water in the construction site to reduce dust impacts
SEACOMs Contractors
Cost factored in the contract of cable laying company
Ensure all materials stock piles are adequately covered to minimise dust impacts Cable installation Cable installation vessel interference with commercial and recreational vessel navigation The cable route has avoided areas where there are established fishing or water sport activities. Established notification measures will be implemented to minimise any interference of cable laying activities with commercial vessel navigation. (refer to section 7.4.3) Cost factored in the contract of cable laying company
During the construction and cable laying period
SEACOMs Contractors
Activity Occupational Health and Safety(OHS) Impacts
Adverse Impacts Occurrence of accidents and or hazards related to non compliance to OHS requirements
Responsibility
Budget (US$)
All construction contractors will be obliged to comply with the requirements of this EMP and relevant IFC Performance Standards, National and International Laws.
During the Marine survey, construction and cable laying and repair phase
SEACOMs Contractors
None
Operation Phase (Including any Maintenance and Repair Activities) Activity Adverse Impacts Mitigation Measure(s) The cable route has avoided areas where there are established fishing or water sport activities. Established notification measures will be implemented to minimise any interference of cable laying activities with commercial vessel navigation. If any cable repair activities become necessary during project operations impacts due to sediment disturbance will be localised and mitigated by the same actions specified above for cable installation phase activities. If any cable repair activities become necessary during project operations impacts due to air emissions will be localised and mitigated by the same actions specified above for cable installation phase activities. If any cable repair activities become necessary during project operations impacts due to noise emissions will be localised and mitigated by the same actions specified above for cable installation phase activities. Implementation Schedule Responsibility Budget (US$)
Cable Repair or decommissioning works
Cable re-installation or repair vessel interference with commercial and recreational vessel navigation
During the repair or decommissioning period
SEACOMs Contractors
Cost factored in the contract of company that will operate and manage the cable.
Cable repair on the Continental Shelf
Sediment disturbance hence increased turbidity
SEACOMs Contractors
Cost factored in the contract of company that will operate and manage the cable. Cost factored in the contract of company that will operate and manage the cable. Cost factored in the contract of company that will operate and manage the cable.
Air and dust pollution from motorised machinery and equipment on the environment Onshore cable repair Noise pollution and disturbances from motorised equipment and machinery
SEACOMs Contractors
SEACOMs Contractors
Activity
Adverse Impacts
Responsibility SEACOMs Contractors
Budget (US$)
Marine operations
Discharges and accidental spills from Vessels
Use of modern vessels compliant with then current international standards in respect of spill prevention and control and waste management
Cost factored in the contract of company that will operate and manage the cable. Cost factored in the contract of company that will operate and manage the cable.
Occupational Health and Safety(OHS) Impacts
Occurrence of accidents and or hazards related to non compliance to OHS requirements
All construction contractors will be obliged to comply with the requirements of this EMP and relevant (and then current) IFC Performance Standards, National and International Laws.
SEACOMs Contractors
Djibouti - Environmental Action Plan
Table 1: Impacts identified as part of the existing Djibouti Telecom environmental approval
Potential Impact Positive effect of a fisheries exclusion zone along the cable route Destruction of high quality corals identified as national, regionally or internationally important Negative effects on coral species endemic to the Red Sea and Gulf of Aden Direct impacts on Djiboutian Marine Protected Areas Interference with the marine cable Destruction of coral Negative effects on hard corals Negative effects on seagrass zones Negative effects on bird populations of the Haramous Islands Negative effects on dolphins and dugongs Negative effect of a large exclusion zone around cable route Reference EASSy EIA ESMP EASSy EIA ESMP EASSy EIA ESMP EASSy EIA ESMP EASSy EIA ESMP MHUAET approval letter MHUAET approval letter MHUAET approval letter MHUAET approval letter MHUAET approval letter MHUAET approval letter
Management Plan/Action Plan
This Action Plan for the SEACOM Project in Djibouti comprises the following: x x x Provisions of the Djibouti Telecom Environmental and Social Management Plan for the EASSy project (see Appendix 1), as set out in Table 2 below. The requirements of the MHUAET letter of approval to Djibouti Telecom for the EASSy project (see Appendix 2), as set out in Table 3 below. Project-wide provisions from the SEACOM Project Social and Environmental Management System (SEMS) Action Plan, as summarised in Table 4 below.
Table 2: ESMP for the EASSy Project

This project has a minimal impact on the marine environment because it will not generate pollution nor a reduction in biological diversity on the project concerned site. This is why the development of a management plan as such is not necessary. Following attenuation measures if they are respected will make it possible to attenuate the few noted negative impacts. a. the prohibition of trawling activities in Haramous zone
The trawl could be a threat to the cable because it will unearth it if it is used by the trawlers operating often illegally in the zone. A daily monitoring is necessary to implement this measurement because in the past, trawlers from Somalia were caught in the Djiboutian territorial waters. This measurement also has a positive impact to the environment because it will make it possible to protect the marine ecosystems (corals, sea grass...) from any destruction of physical aspect. It is important to recall that trawling is forbidden in the Djiboutian territorial waters according to the environmental legal regulation and the fishing legal code.
17
Moreover, there is a Djiboutian Navy Unit which is based in Loyada that it will be necessary to reinforce its capacity within the framework of this project in average equipments so that the monitoring could be effective in particular at the night where fishermen are active. b. the protection of the coral reef during the cable installation
During the cable installation, a localization process diving tasks of high living percentage corals will precede within the cable landing section to avoid any destruction of the high quality corals identified as national, regional international importance. This task will have to be entrusted to two confirmed divers and having an aptitude to identify the various coral species. They will dive along the landing section within the cable landing corridor to indicate where the cable will land through the corals. It should be specified that the cable will not be buried at this level. The following criteria must be used to locate the best site: - A zone (corridors) which corals are preferably damaged by a former event former to this cable installation. - A zone (corridors) which the alive and hard coral cover is or less than 20%. - It will be necessary to avoid the cable landing within a zone of 30% or more of coral cover; To avoid the cable landing within a zone colonized by endemic coral species to the Red Sea and Gulf of Aden like: Pocillopora damicornis, Acropora hempichii c. the respect of the Djiboutian Marine Protected Areas integrity. The cable will go through the Territorial Waters and it is significant that the limits of the two Marine Protected Areas such as Moucha-Maskali and Sept Frres -Godoria Islands must be respected. The cable must imperatively circumvent them. The known limits of the two MPA must be used. This skirting will make it possible for Djibouti-Telecom to not include in this impact assessment these two MPA because they contain many ecosystems. d. the cable protection zone creation and signalisation A protection zone extending about 400 m of the cable both sides will be created to allow the cable installation and its maintenance. The cable protection creation zone will be done by legal procedure. The compensation reimbursement for the people who has title deed or land property within this zone must be made in a transparent way. The signalisation of this zone will be made by floating buoys which will be placed on both sides of this delimited zone and this is to facilitate it largely its monitoring.
Table 3: SEACOM Management Measures in response to requirements of the existing Djibouti Telecom environmental approval
Potential Impact Positive effect of a fisheries exclusion zone along the cable route Destruction of high quality corals identified as nationally, regionally or internationally important Negative effects on coral species endemic to the Red Sea and Gulf of Aden Existing Avoidance or Mitigation Measure None required
Demonstration through a Project-specific marine survey that high quality corals identified as nationally, regionally or internationally important will not be significantly affected by the Project. Demonstration through a Project-specific marine survey that there will be no significant impacts on coral species endemic to the Red Sea and Gulf of Aden.
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Potential Impact Direct impacts on Djiboutian Marine Protected Areas Interference with the marine cable
Existing Avoidance or Mitigation Measure Demonstration that the Project will have no direct impacts on Djiboutian MPAs. Incorporation of the SEACOM cable into exclusion zones created for existing cables; where necessary, extension of existing exclusion zones to provide adequate protection to the SEACOM cable. Cable route selected to minimise intersections with, and impacts on, live coral. Cable route selected to avoid areas where cover of live, hard coral exceeds 30%. Avoidance of significant areas of sea grass. (Note: Sparse covering of seagrass Halodula ovalis was observed in some places during the marine survey on coarse sands in the shallow intertidal zone. Species such Halodula are relatively tolerant of reduced light penetration and high sedimentation events.) Avoidance of the Haramous Islands, as well as the greater Haramous-Loyada RAMSAR site.
Destruction of coral Negative effects on hard corals Negative effects on seagrass zones
Negative effects on bird populations of the Haramous Islands Negative effects on These species are referenced in Djibouti Telecoms ESIA dolphins and dugongs for the EASSy project. They are present in the territorial waters of Djibouti and may be sometimes be observed at the Ramsar site adjacent to the Project area, but the marine survey conducted for this Supplement found no evidence of their presence in the Project area. Negative effect of a large MHUAET refer to an exclusion zone of 1.5km width either exclusion zone around side of the cable. Where a supplementary exclusion zone is cable route required for the SEACOM cable it will extend 400m either side of the cable.
Table 4: Summary provisions of the SEACOM SEMS Action Plan

In addition to the measures already incorporated into the SEACOM Project a Social and Environmental Management System (SEMS) Action Plan will be implemented to include management measures in respect of: x Soil erosion x Noise and vibration x Air quality x Solid waste x Hazardous materials x Wastewater discharges x Habitat alteration x Occupational health and safety x General site hazards x Disease prevention x Traffic safety x Impacts from vessels (e.g. aqueous discharges, ballast water management, etc.) x Commercial fisheries x Safety at sea
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Egypt - Environmental Action Plan
8.0
ENVIRONMENTAL MANAGEMENT PLAN
This section describes the actions to minimize the adverse effects of main environmental and social impacts during the project lifetime. Adverse environmental impacts occur mainly during the construction phase. Environmental impacts during the
operation phase are benign. 8.1 Onshore Construction
Type of Impact
Impact Localized and short-term altering of the shoreline due to excavation works. Exhaust emissions, suspended dust, particulates and noise caused by construction machinery.
Mitigation Measures Upon completion of inland trenching and cable installation, the excavation will be backfilled to grade to prevent altering of the shoreline, thus minimize scour and sedimentation. Construction area will be minimized whenever possible. Avoiding working during the night and early morning will reduce noise impacts. Dust control measures will be applied when needed (e.g. water spraying)
Environmental
EcoConServ
Final EIA Report_Eng to TE (30jun08)
47
Type of Impact
Impact Disruption of recreational and fishing activities.
Mitigation Measures Awareness activities will be performed by SEACOM/Telecom Egypt prior to commencement of construction, including notification to representatives of the local fishing industry advising them of the timing and type of construction activities, and advising them to seek alternative fishing grounds during the construction phase; and with representatives of local government concerned with the fishing industry. The holiday season (October - May) will be avoided whenever possible. (The current Project schedule envisages construction of the shore crossing between August and October, 2008, with the offshore cable to be laid in November 2008.) Warning signs, lights and fencing will be used.
Socio-Economic
Risk of injury to beach users especially at night due to trenching. Selection of a beach manhole location involving a cable road crossing, resulting in disruption to road traffic
Warning signs and other appropriate traffic control measures will be implemented in conjunction with the local traffic authorities
EcoConServ
48
8.2
Offshore Construction
Type of Impact
Impact Water quality impacts from discharges of oily bilges and ballast water, sewage and solid waste. Damage to live corals. Disturbance of benthic communities and fish.
Mitigation Measures Wastewater discharges to sea during construction will comply with the standards set by Law 4/1994 to minimize impacts to sea water quality. The cable has been routed to avoid major coral areas. Periods of fish spawning (mid-June to end of August) will be avoided whenever possible to minimize adverse impacts to fisheries resources. Breeding areas for sensitive marine mammals (e.g. sea turtles) fall within protected areas and will be avoided. Locations of all oil and gas pipelines in the Gulf of Suez, that intersect the cable rout, have been identified and mapped and negotiations are underway with the relevant oil companies to obtain agreements to cross the pipeline Rights-of-Way. Cable and pipeline crossing will be carefully supervised to minimize risk of line breaks. An emergency response plan will be prepared for pipeline crossings to minimize the potential for oil spills.
Environmental
Disturbance to marine mammals.
Risk of oil spills in case of pipeline damage or rupture during cable installation in the Gulf of Suez.
EcoConServ
49
Type of Impact
Impact Disruption of recreational and fishing activities.
Mitigation Measures Awareness activities will be performed by SEACOM/Telecom Egypt prior to commencement of construction, including notification to representatives of the local fishing industry, advising them of the timing and type of construction activities, and advising them to seek alternative fishing grounds during the construction phase, and with representatives of local government concerned with the fishing industry. The holiday season (October - May) will be avoided whenever possible. (The current Project schedule envisages construction of the shore crossing between August and October, 2008, with the offshore cable to be laid in November 2008.) Imposition of safety zones, as well as the use of navigation lights and radar reflectors will minimize the risk of collision. Project vessels will comply with all regulatory requirements in respect of safety and navigation.
Socio-Economic
Risk of maritime accidents due to high vessel traffic through the Gulf of Suez.
EcoConServ
50

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SEACOM Cable System Project Equator Principles Environmental Impact Assessment

Equator Principles EIA SEACOM Cable System Project

Contract/Proposal No: Issue: Author (signature):

61C12704 06 Chris Halliwell

Project Manager/Director (signature):

VERSION CONTROL RECORD

Equator Principles EIA SEACOM Cable System Project

Equator Principles EIA SEACOM Cable System Project

Equator Principles EIA SEACOM Cable System Project

94 95 95 95 97 98 100 106 109

Equator Principles EIA SEACOM Cable System Project

ROV SAFE SEACOM TB TS UNCLOS

Equator Principles EIA SEACOM Cable System Project

South Africa Mozambique Tanzania Kenya Djibouti India Egypt

Figure 1. Map of the SEACOM Fibre optic cable system

Equator Principles EIA SEACOM Cable System Project

Equator Principles EIA SEACOM Cable System Project

Need for the Project

1.3 Scope of the Equator Principles Environmental Impact Assessment

Equator Principles EIA SEACOM Cable System Project

South Africa Mozambique Tanzania Kenya Egypt

Equator Principles EIA SEACOM Cable System Project

Equator Principles EIA SEACOM Cable System Project

Policy Legal and Administrative Framework

2.1.1 South Africa

Relevant environmental legislation is as follows:

Equator Principles EIA SEACOM Cable System Project

The regulations for both alternative processes stipulate that:

Equator Principles EIA SEACOM Cable System Project

Equator Principles EIA SEACOM Cable System Project

Equator Principles EIA SEACOM Cable System Project

National permitting requirements of significance to the Project are:

Equator Principles EIA SEACOM Cable System Project

The procedure for the Environmental Impact Assessment is as follows:

Equator Principles EIA SEACOM Cable System Project

International Treaties and Conventions

Equator Principles EIA SEACOM Cable System Project

Economic Exclusion Zones (EEZ) High Sea

Equator Principles EIA SEACOM Cable System Project

Equator Principles EIA SEACOM Cable System Project

Equator Principles EIA SEACOM Cable System Project

Equator Principles EIA SEACOM Cable System Project

Equator Principles EIA SEACOM Cable System Project

Equator Principles EIA SEACOM Cable System Project

Categorization of the Project

Equator Principles EIA SEACOM Cable System Project

Equator Principles EIA SEACOM Cable System Project

Egypt Djibouti Kenya Tanzania Mozambique South Africa

Equator Principles EIA SEACOM Cable System Project

Equator Principles EIA SEACOM Cable System Project

Project Consultants and Contractors

Equator Principles EIA SEACOM Cable System Project

The SEACOM Cable System

Equator Principles EIA SEACOM Cable System Project

Figure 3. Typical Installation for an Ocean Ground Bed

Equator Principles EIA SEACOM Cable System Project

3.5.2 Route through international and national waters

3.5.3 Landing locations

3.5.4 Cable route selection

Equator Principles EIA SEACOM Cable System Project

System Manufacture and Installation - General

3.6.1 Marine Cable

Equator Principles EIA SEACOM Cable System Project