Ghana Secondary Education Improvement Project (Gseip)

REPUBLICOFGHANA

GHANA SECONDARY EDUCATION IMPROVEMENT PROJECT (GSEIP)

ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK (ESMF)

March 25, 2014

TABLE OF CONTENTS

1.0INTRODUCTION

2.0PROJECT DESCRIPTION

2.1Component 1: Increase Access with Equity

2.2 Component 2: Quality and Relevance of Secondary School Teaching and Learning

2.3 Component 3: Technical Assistance and Management Support

2.4Description of Civil Works

2.5Implementation Arrangements

3.0RELEVANT LEGAL AND INSTITUTIONAL FRAMEWORK

3.1Ghana’s Environmental Policy

3.2Environmental Protection Agency and Environmental Impact Assessment (EIA)

3.3Public Health Act

3.4National Sanitation Policy

3.5Planning Policies

4.0DESCRIPTION OF THE ENVIRONMENTAL & SOCIAL IMPACTS AND MITIGATION MEASURES

4.1 Introduction

4.2Potential Environmental and Social Impacts

4.3Pre-Constructional Phase

5.0 ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK

5.1 Introduction

5.2 Screening for Site Selection

5.3 Screening for Potential Environmental and Social Impacts

5.4 Mitigation of Impacts

5.5 Guidelines for Community Involvement

5.6 Guidelines for Project Site Selection

5.7 Guidelines for the Timing of Constructional Activities

5.8 Guidelines for Construction Work

6.0ENVIRONMENTAL AND SOCIAL ADMINISTRATIVECONSIDERATIONS

6.1 Institutional Arrangements and Responsibilities

6.2 The Environmental and Social Technical Planning Guidelines

6.3 Internal Compliance Monitoring

6.4 Trainings and Capacity Building

6.5 ESMF Costs

6.6 Actors

6.7 Project Management Structure Guidelines

6.8 Environmental Management Guidelines

6.9 Guidelinesof theRole of theEPAintheProject

6.10 Guidelinesfor EPA’sRegistrationof theProjects

6.11 Guidelinesfor Capacity Building

6.12 GuidelinesforCostEstimatesoftheImplementationoftheMitigation MeasuresandMonitoring

7.0 ENVIRONMENTAL MITIGATION PLAN (EMP)

7.1 Introduction

7.2 The role of stakeholders in ESMF Implementation

8.0CONSULTATIONS

8.1Introduction

8.2 Methodology

8.3 General Concerns

ANNEXES

Annex 1: Methods and Techniques Used in Assessing and Analyzing Impacts

General Approachto theAssignment

Methodsof Data Collection

AssessingandAnalysingof Environmental SocialImpacts

Annex 2. Consultations with key Stakeholders

Annex 3. Socioeconomic and Environmental Characteristics in the Education Sector

Annex 4. School Planning and Construction Checklist

Annex 5. Terms of reference for ICU Environmental Consultant

Annex 6. Example of environmental contract clauses

Annex 7. SEIP Environmental and social screening form

Annex 8. E&S Due Diligence Checklist

ABBREVIATIONSANDACRONYMS

ADEOPAnnualDistrictEducationOperational Plan

AESOPAnnualEducationSectorOperational Plan

APWAnnualProgramsofWork

BECEBasicEducationCertificate Examination

CAGDController andAccountantGeneral Department

CBOCommunityBasedOrganization

CCTConditionalCashTransfer

CREATEConsortiumforResearchonEducationalAccess,Transitions& Equity

CSCircuit Supervisor

CSACivilServiceAgency

DACFDistrictAssemblyCommonFund

DEODistrictEducationOffice

DEOCDistrictEducationOversight Committees

DFIDUKDepartment forInternationalDevelopment

DPDevelopmentPartner

EDIEFADevelopmentIndex

EFAEducationforAll

EFA-FTIEducationforAllFast TrackInitiative

EMISEducationManagement InformationSystem

ERPEconomicReformProgram

ERRCEducationReformReviewCommittee

ESPEducationStrategic Plan

ESPREducationSectorPerformanceReport

FCUBEFree CompulsoryUniversalBasicEducation

FTIFast TrackInitiative

GARGrossAdmissionRate

GDHSGhana DemographicandHealth Survey

GDPGrossDomesticProduct

GERGrossEnrolmentRatio

GESGhana EducationService

GET-FundGhana EducationTrustFund

GLSSGhana LivingStandardsSurvey

GNATGhana National AssociationofTeachers

GNIGrossNational Income

GoGGovernment ofGhana

GPEGlobal Partnership forEducation

GPEFGlobal Partnership forEducationFund

GPIGender Parity Index

GPRSGrowth andPoverty ReductionStrategy

GSFPGhana SchoolFeeding Program

GSSGhana Statistical Service

HDIHumanDevelopmentIndex

HEHigher Education

HEIHigher EducationInstitute

ICTInformationandCommunicationTechnology

IMFInternational MonetaryFund

INSETIn-ServiceEducationandTraining

JHSJunior High School

JICAJapan International CooperationAgency

KVIPKumasiVentilated ImprovedPit

LEAPLivelihoodEmpowermentAgainst Poverty

MDBSMulti-DonorBudget Support

MDGMillenniumDevelopmentGoals

MLGRDMinistry of LocalGovernment andRural Development

MMDAsMetropolitan, MunicipalandDistrictAssemblies

MoEMinistry of Education

MoFEPMinistry of Finance andEconomicPlanning

MoLGMinistry of LocalGovernment

MTEFMediumTermExpenditure Framework

NABNational AccreditationBoard

NARNet AdmissionRate

NCTENational CouncilforTertiary Education

NDCNational DemocraticCongress

NEANational EducationAssessment

NERNet EnrolmentRatio

NERICNational EducationReformImplementationCommittee

NERPNational EducationReformProgram

NESARNational EducationSectorAnnualReport

NGONon-Governmental Organization

NIBNational InspectorateBoard

NVTIsNationalVocation TrainingInstitutes

PBMEPlanning, Budgeting, MonitoringandEvaluationDepartment

PCEPer childrecurrent expenditure

PEPersonnelEmoluments

PERPublic Expenditure Review

PPPPurchasingPowerParity

PRSCsPoverty ReductionStrategy Credits

PRSPPoverty ReductionStrategy Paper

PTAParent TeacherAssociation

PTEPer teacher recurrent expenditure

PTRPupil TeacherRatio

PTTRPupil TrainedTeacherRatio

REORegional EducationOffice

SHSSeniorHigh School

SMCSchoolManagementCommittee

SPAMSchoolPerformanceAssessmentMeeting

SPIPSchoolPerformanceImplementationPlan

SSASub-Saharan Africa

SSSCESeniorSecondarySchoolCertificate Examination

TEDTeacherEducationDepartment

TIMSSTrendsin International MathematicsandScienceStudy

TTIsTechnicalTrainingInstitutes

TVETTechnicalandVocational EducationandTraining

UBCUniversalBasicCompletion

UBEUniversalBasicEducation

UCCUniversity ofCape Coast

UNICEFUnitedNations Children’sFund

UPCUniversalPrimary Completion

USAIDUnitedStates Agency forInternational Development

VATValue AddedTax

WAECWest AfricanExaminationCouncil

WASSCEWest AfricanSeniorSecondaryCertificate Examination

WFPWorldFoodProgram

EXECUTIVE SUMMARY

Introduction

This current Environmental and Social Management Framework (ESMF) has been developed to provide environmental and social management guidance for the Secondary Education Improvement Project (SEIP) being prepared for IDA support of US$155million (one hundred and fifty five million United States dollars). The ESMF will provide guidance to project implementation operatives, districts, institutions, contractors, and other stakeholders including beneficiaries of the senior secondary school rehabilitation and construction under the project. The SEIP will support senior secondary education in Ghana, through a five-year Investment Project Financing (IPF) using a results-based approach. The project development objective is to increase access to upper secondary education in underserved school districts and improve quality in low-performing senior high schools in Ghana.

The project’s two components will: (i) provide support to increase access with equity and quality in senior high schools using results-based financing; and (ii) strengthen capacity of Ministry of Education, Ghana Education Service to monitor, coordinate, evaluate and analyze policies for the first component. A matrix of indicators has been developed to measure performance of component 1 annually and to monitor the results achieved as reflected in the results framework. Component 1 will support and monitor key activities to accomplish these goals through construction of new schools, quality improvement and expansion of existing schools where demand is high and in areas where schools have the potential to absorb and retain students, and through scholarships to girls and low income students.

Component 2 will strengthen the implementation capacity of the Ministry of Education and Ghana Education Service in monitoring and evaluation, coordination, planning, communication, financial management, procurement, and safeguards. It will also support research, social targeting, teacher rationalization, curriculum relevance, strengthen data collection for school mapping, and establish priorities for new construction, renovation and maintenance of schools. The establishment of a web platform for school reporting and real time monitoring of all SHS implementation activities would enhance and strengthen the Education Management Information System (EMIS) in order to help government report on achievement of results.

Activities the Government plans to undertake in the project that trigger the use of the ESMF are: (i) the construction of new senior secondary schools in 14 districts which currently have no senior secondary schools; (ii)new construction in (possibly 10) selected districts based on district criteria for population demand, poverty indicators, etc; and (iii) upgrading, expansion and rehabilitation of existing selected low performing schools. The new construction projects will require the acquisition of parcels of land of approximately 10 acres (4.16 ha) at the respective locations. Schools that run agricultural programs will require additional land for demonstration or practical lessons. Civil works under the project will comprise the construction of a classroom and laboratory complex, a headmaster’s residence, an assistant headmaster’s residence, staff residential quarters, an open sports area, a multi-purpose hall and an administration block. Gender considerations have also been made in the inclusion of gender specific changing rooms and toilets.

This updated ESMF will be used to mainstream environment and social safeguards into the design and planning of the SEIP. The choice of ESMF (instead of EIA) was made for the project because of the following reasons:

• Wide geographical spread – 24 potential districts where new construction will be undertaken and about 100 districts where senior secondary school facilities will be improved. These activities will be in all the ten (10) regions of Ghana;
• Implementation duration – will be over five years from 2014 - 2019;
• Cross sectoral involvement and scope –Ministries, Departments, Agencies and Schools at national, regional and district levels;
• Site specific activities – which may cover a range of different components e.g. classroom block, sanitation, borehole, solar energy, staff residential facilities-the level of site specific project will be determined based on the situation of the location.

It is imperative under these considerations to have an Environmental and Social Management Framework which provides guiding principles and outlines procedures for mitigating identified environmental and social impacts and risks as a result of the project. The current ESMF provides:

• Screening checklist for site selection under the project;
• Legal framework for the implementation of the ESMF,
• The basis for identifying potential environmental and social impacts and risks of project activities and proposes appropriate mitigation measures,
• Institutional structure that assigns responsibility for various activities within the framework.

Legal and Administrative Frameworks

A number of policies as well as legal and administrative frameworks have been considered in the ESMF. Ghana’s National Environmental Policy aims at ensuring a sound management of resources and the environment and to avoid any exploitation of these resources in a manner that might cause irreparable damage to the environment. The policy endorses the preventive approach to environmental management and emphasizes the need to promote socio-economic development within the context of prescribed acceptable environmental standards and safeguards. In effect, it seeks reconciliation between economic planning and environmental resource development with the view to achieving sustainable national development. The Policy Statement seeks among other things:

• to ensure environmentally sound use of both renewable and non- renewable resources in the process of national development,
• to develop procedures for the utilization of land resources in a manner that would ensure the maximum degree of economy in the use of land and avoid or minimize conflicts, and
• to institute and implement the concept of sustainable development by requiring prior environmental impact assessments of new investments and developments that would be deemed to affect the quality of the environment.

The environmental policies and legal framework and procedures considered in preparation of the SEIP ESMF include the following:

• Ghana’s Environmental Policy;
• The Environmental Protection Agency Act of 1994 (Act 490);
• The Environmental Assessment Regulations (LI 1652), and EIA procedures;
• Laws and Regulations pertaining to the protection of the environment and health;
• National Sanitation Policy;
• Town and Country Planning Ordinance 1951 (Cap84);
• The Local Government Act 462 of 1993; and
• The World Bank’s safeguard policies which include guidance on EA requirements - Environmental Assessment (OP4.01), and also the Involuntary Resettlement (OP/BP 4.12), etc.

Likely Environmental and Social Impacts and Mitigation Measures

The SEIP ESMF considers likely potential environmental and social concerns likely to arise from the construction and rehabilitation of buildings, water points and sanitation facilities under the project, and their proposed mitigation measures. Work at the District levels across other World Bank sponsored infrastructure projects shows that issues such as community involvement, community ownership and selection of appropriate sites for schools construction are some of the key concerns, which influence the success, and sustainability of such projects. That the project is a reimbursable process paying against results means that there is no traditional investment procedure (e.g., no objections) nor a PIU and the Bank will have to be provided verification that environmental and social provisions meeting Bank policy standards have been followed. This will require a due diligence checklist demonstrating that all World Bank Environmental and Social policy requirements are met.

Potential environmental and social concerns and impacts at the pre-constructional and constructional stages include under site selection, for example, concerns about the siting of school projects in sacred groves or burial grounds, on disputed land, and in ecologically sensitive areas. Mitigation measures include giving priority to unencumbered land and in cases where people are inevitably affected, according to the World Bank OP 4.12 on Involuntary Resettlement, applying the necessary mitigation measures. Other mitigation measures will include community sensitization and involvement, site preparation and timing which does not leave the land susceptible to erosion, and the destruction of crops, staggering site clearing for school construction and facilities improvement. Construction phase impacts may include air quality impact from dust generation of excavation, noise generation from construction activities, public health and safety from unconsolidated material left at the construction site, and occupational health and safety effects on construction site workers who may be endangered. In all these cases, mitigation measures and procedures including relevant budget have been outlined for easy follow up on mitigation. The responsibilities for screening for potential project impacts as well as the institutional arrangements for environmental and social management frameworks are also outlined.

Institutional Arrangements and Responsibilities

In order to ensure proper management of the environmental and social concerns, responsibilities and roles of focal persons, monitoring mechanisms, training and capacity building are detailed in the ESMF. Oversight of SEIP implementation will be in the Ministry of Education (MOE) with the Ghana Education Service providing their mandated implementation role for service delivery. The institutional arrangements will facilitate environmental and social soundness and sustainability. A Steering Committee and Project Management Team will be established to coordinate and oversee implementation. The Project Management Team will derive from the Project Implementation Committee at the national level and will assume project control and monitor civil works executed in the four (4) zones of the country. The PMT will include 2 environmental and social safeguards consultants; 1 procurement specialist (MOE); 1 technical advisor (MOE); 4 architects (FPMU + 3 others); 4 quantity surveyors (FPMU, GETFund and 2 others); 4 civil engineers (FPMU + 3 others); 1 electrical engineer (on retainer basis) and a Project management consultancy firm (providing other needed capacity). The implementation and monitoring of the ESMF, the identification of affected persons and compensation levels, the payment of compensation and dispute resolution roles include the Project Management Team, the District Education Oversight Committee (DEOC), the Environmental Protection Agency (EPA), and the Project Steering Committee.

The cost of ESMF implementation for duration of three years is estimated at GHC1,657,520 (approx. US$635,000).

1.0INTRODUCTION

The Ghana Secondary School Project will support senior secondary education through a five-year US$155 million Investment Project Financing (IPF) instrument using a results-based-lending approach. This framework builds on existing government systems and also on the key objectives of the Education Strategic Plan 2010-2020, especially in its focus equity and quality of services and on efficiency and accountability of education management.

The Ghana Secondary Education Improvement Project is being developed as part of a larger program of government to support the secondary education sub-sector. The Ghana Secondary Education Improvement Project supports areas that complement the government’s expenditures. The SEIP supports the Government’s long term vision for expansion of Secondary Education. Government strategy aims to rapidly expand both access and quality of secondary education making it gradually universal and also progressively free for students who are unable to afford access to secondary education. Among other plans, the Government is proposing to build about 200 secondary schools above and beyond recent investments into the current infrastructure documented in a recent policy document, the Community Day School Construction Program.

The prioritization and better targeting of resources will help ensure more equitable availability of SHS and redress the growing disparities in access to quality secondary education.

2.0PROJECT DESCRIPTION

The proposed project will support senior secondary education through a five-year US $155 million Investment Project Financing (IPF) instrument using a results-based-lending approach. The project development objective is to increase access to upper secondary education in underserved school districts and improve quality in low-performing senior high schools in Ghana.

2.1Component 1: Program Support to Increase Access with Equity and Quality in SHS

Component 1 uses a results-based financing (RBF) modality. Disbursements up to a capped absolute amountwill be made against specific line items in the Education sector annual budgets, referred to as eligible expenditure programs (EEPs). These disbursements will be conditioned on achievement of specified results, as measured by disbursement-linked indicators (DLIs). A matrix of indicators has been developed to measure performance annually and monitor the results achieved as reflected in the results framework.

Policies and interventions to be supported under the first component of SEIP are grouped into two pillars: (i) increasing access with equity (geographic, gender, poverty, etc.); and (ii) enhancing quality of low performing SHS.

Pillar 1: Increase Access with Equity: The objective of this pillar is to improve access to senior secondary education and improve equity in underserved districts and subsidize students especially girls from low income households. This pillar will support and monitor key activities to accomplish these goals through the construction of new schools and the improvement and expansion of existing schools where demand is high and the schools have inadequate facilities to absorb and retain students.

The SEIP is expected to finance results of the Government’s ambitious program to expand space through the construction of new senior secondary schools in underserved areas, rehabilitation and expansion of existing low performing schools and through support for SHS attainment of disadvantaged students. The Government plans include new construction in the 14 districts where there are no current operating public SHS. In addition, using the agreed selection criteria for eligible student population compared with available school capacity (effective demand) combined with district level poverty indicators, an additional 10 districts have been identified for new construction. The ultimate objective is to create new spaces for those demanding seats in SHS and to fill these spaces with new students coming from previously underserved communities. In addition to new schools, this component would focus on improving existing SHS, particularly those with capacity for expansion, meeting criteria of school age population not attending SHS, and low performance criteria in addition to a needs assessment which will determine level of deficiency (bathrooms, science labs, computer facilities, etc.) and scope for upgrading. This pillar will improve the government’s targeting of resources to support increased access by further supporting scholarship and other demand side investments to encourage girls’ attendance and poorer students.