PRIORITIZED ROAD INVESTMENT AND
MANAGEMENT ENHANCEMENTS (PRIME)AndSTRATEGIC CLIMATE-ORIENTED ROAD
ENHANCEMENTS (SCORE)
PROJECTS
Federated States of Micronesia
ENVIRONMENT AND SOCIAL MANAGEMENTFRAMEWORK (ESMF)
FINAL DRAFT
Prepared by the Department of Finance and Administration Central
Implementation Unit for theWith Funding from

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Environmental and Social Management Framework

CONTENTS
1.

2.

3.

4.

5.

Introduction ...................................................................................................................... 1
1.1

Environmental and Social Assessment Overview ................................................................... 1

1.2

Environmental and Social Management Framework (ESMF)................................................... 1

Project Background and Rationale .................................................................................4
2.1

Overview of the ‘PRIME and SCORE’ Projects ....................................................................... 4

2.2

Climate Adaptation and Resilience Objectives ........................................................................ 4

2.3‘PRIME’ and “SCORE’ Investments and Activities .................................................................. 5

2.4

Project Location ....................................................................................................................11

Legislative & Regulatory Framework ............................................................................ 17
3.1

FSM National Government Legislation, Regulations and Policy Requirements .......................17

3.2

State Government Legislation, Regulation and Policy Requirements .....................................24

3.3

International Standards and OHS Labor Guidelines ...............................................................31

3.4

Comparison of WB ESF and FSM Legislative Requirements..................................................38

Existing Environment..................................................................................................... 44
4.1

Introduction...........................................................................................................................44

4.2

Project Area of Influence .......................................................................................................44

4.3

General Baseline Description ................................................................................................45

4.4

Indigeneity in FSM ................................................................................................................64

Anticipated Environmental & Social Impacts ............................................................... 66
5.1

Introduction...........................................................................................................................66

5.2

Anticipated Impacts of Components 1 and 3 PRIME and SCORE ..........................................66

5.3

Potential Impacts of Components 4 SCORE (CERC) .............................................................67

5.4

Potential Feasibility, Design and Pre-Construction Impacts under Component 2 of PRIME and

SCORE .......................................................................................................................................70

6.

5.5

Potential Construction Impacts under Component 2 of PRIME and SCORE ...........................72

5.6

Potential Operational Impacts under Component 2 of PRIME and SCORE ............................81

5.7

Cumulative Impacts ..............................................................................................................83

5.8

Risk Assessment & Impact Identification Methodology ..........................................................84

5.9

Environmental and Social Sensitivities Maps ....................................................................... 109

Risk Management Procedures for Component 2 Works for PRIME and SCORE Projects...................................................................................................................................... 117
6.1

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Environmental and Social Risk Screening ........................................................................... 117

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6.2

Preparation of ESIA/ESMPs ................................................................................................ 119

6.3

Civil Works Contractor Requirements .................................................................................. 121

6.4

Implementation of ESMP and CESMP ................................................................................. 121

6.5

Risk Management for Technical Advisory Activities ............................................................. 122

7.

Stakeholder Engagement, Consultation and Participation ........................................ 123

8.

Institutional Arrangements, Responsibilities and Implementation ........................... 126
8.1

Institutional Responsibilities and Structures ......................................................................... 126

8.2

Implementation Roles and Responsibilities.......................................................................... 129

8.3

Implementation Process ...................................................................................................... 132

9.

Budget and Financial Arrangements .......................................................................... 134

10.

Monitoring and Reporting ............................................................................................ 136
10.1

11.

Monitoring and Reporting ................................................................................................ 136

References .................................................................................................................... 140

LIST OF TABLES
Table 3-1: WHO ambient air quality guidelines (WHO 2005) ........................................................................33
Table 3-2: WHO noise level guidelines (WHO, 1999). ..................................................................................35
Table 3-3: Gaps between WB ESF and FSM legislative requirements, and gap filling measures ..................39
Table 4-1: Project Area of Influence (AOI) delineations and conditions........................................................45
Table 5-1: Qualitative risk analysis matrix ...................................................................................................84
Table 5-2: Qualitative measures of likelihood ..............................................................................................85
Table 5-3: Qualitative measures of consequence ........................................................................................85
Table 5-4: Outcome of Assessment of PRIME and SCORE Component 1 (Spatial and Sector Planning),
Component 3 (Strengthening the Enabling Environment) and SCORE Component 4 (CERC) Risks. ............87
Table 5-5: Outcome of Assessment of Key Feasibility, Design and Pre-Construction Phase Environmental,
Social, Health and Safety Risks for Component 2 for PRIME and SCORE projects. .....................................90
Table 5-6: Outcome of Assessment of Key Construction Phase Environmental, Social, Health and Safety Risks
for Component 2 Physical Works for PRIME and SCORE projects. ..............................................................96
Table 5-7: Outcome of Assessment of Key Operational Phase Risks Component 2 Physical Works for PRIME
and SCORE projects. ................................................................................................................................ 107
Table 5-8: Key environmental and social attributes enabling assessment of level of sensitivity .................. 111
Table 5-9: ‘High’ sensitivity areas - Kosrae ............................................................................................... 111
Table 5-10: ‘High’ sensitivity areas - Pohnpei ........................................................................................... 111

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Table 5-11: ‘High’ sensitivity areas - Chuuk .............................................................................................. 112
Table 5-12: ‘High’ sensitivity areas - Yap .................................................................................................. 112
Table 9-1: Indicative budget for implementing the ESMF ........................................................................... 134
Table 10-1: Schedule of construction reporting .......................................................................................... 138

LIST OF FIGURES
Figure 2-1: Location of FSM States: Kosrae, Pohnpei, Chuuk and Yap ........................................................12
Figure 2-2: Extent of PRIME (white) and SCORE (red) Roads on Kosrae. ....................................................13
Figure 2-3: Extent of PRIME (yellow) and SCORE (red) Roads on Pohnpei. ................................................14
Figure 2-4: Extent of PRIME (white) and SCORE (red) Roads on Chuuk. .....................................................15
Figure 2-5: Extent of PRIME (white) and SCORE (red) roads on Yap. ..........................................................16
Figure 4-1: Location of key terrestrial habitat classes in Kosrae (from Weeks, 2019) ...................................48
Figure 4-2: Location of key terrestrial habitat classes in Kosrae (from Weeks 2019) ....................................49
Figure 4-3: Existing and proposed protected areas (from TNC, 2019) .........................................................50
Figure 4-4: Areas of Biological Significance in Kosrae (from TNC, 2019).....................................................50
Figure 4-5: Key assets identified during the road corridor inspection – Kosrae ............................................52
Figure 4-6: Images showing examples of PRIME and SCORE key assets located in close proximity to the roadon Kosrae. ..................................................................................................................................................53
Figure 4-7: Key assets identified during a road corridor inspection – Pohnpei .............................................56
Figure 4-8: Images showing examples of PRIME and SCORE assets located in close proximity to the road on
Pohnpei. .....................................................................................................................................................57
Figure 4-9: Key assets identified during a road corridor inspection - Chuuk .................................................59
Figure 4-10: Images of Chuuk showing examples of PRIME and SCORE assets identified during the roadcorridor on Chuuk inspection. ......................................................................................................................60
Figure 4-11: Key assets identified during a road corridor inspection - Yap ...................................................62
Figure 4-12: Images showing examples of PRIME and SCORE key assets located in close proximity to theroad on Yap. ...............................................................................................................................................63
Figure 5-1: Key E&S sensitivities on Primary and Secondary Road network – Kosrae (showing ‘high’ (red box)and ‘medium’ (orange box) sensitivities) .................................................................................................... 113
Figure 5-2: Key E&S sensitivities on Primary and Secondary Road network – Pohnpei (showing ‘high’ (redbox) and ‘medium’ (orange box) sensitivities). ........................................................................................... 114
Figure 5-3: Key E&S sensitivities on Primary and Secondary Road network – Chuuk (showing ‘high’ (red box)and ‘medium’ (orange box) sensitivities). ................................................................................................... 115
Figure 5-4: Key E&S sensitivities on Primary and Secondary Road network – Yap (showing ‘high’ (red box)and ‘medium’ (orange box) sensitivities). ................................................................................................... 116

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Figure 6-1: E&S screening process. .......................................................................................................... 119
Figure 8-1: Implementation arrangements for the PRIME and SCORE Projects. ........................................ 126

APPENDICES
Appendix A

Baseline Resource Report

Appendix B

Data used in E&S Sensitivities Maps

Appendix C

Environmental & Social Screening Forms

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ABBREVIATIONS & ACCRONMYSABS

Areas of Biodiversity Significance

AOI

Area of InterestAP

Affected People

BNPL

Basic Needs Poverty Line

CBD

Convention on Biological Diversity

CBO

Community Based Organization

CESMP

Contractors Environmental and Social Management Plan

CERC

Contingent Emergency Response Component

CFP

Chance Find Procedure

CIU

Central Implementation Unit - DOFA

CoC

Code of Conduct

CoP

Codes of Practice

CRRS

Climate Resilient Road Strategy

DoFA

Department of Finance and Administration

DoTC&I

Department of Transportation, Communications and InfrastructureDP

Displaced Persons

DRC

Development Review Commission – Kosrae StateDRD

Department of Resources and Development – FSM National
Government

EAPEmergency Action Plan

EAS

Environmental Assessment Statement

EEZ

Exclusive Economic Zone

EHS

Environmental, Health & Safety Guidelines

EIA

Environmental Impact Assessment

EIS

Environmental Impact Statement

ENSO

El Nino Southern Oscillation

EPA

Environmental Protection Agency

E&S

Environmental and Social

ESA

Environmental and Social Assessment

ESCP

Environmental and Social Commitment Plan

ESF

Environmental and Social Framework – World Bank

ESMF

Environmental and Social Management Framework

ESMP

Environmental and Social Management Plan

E&S

Environmental and Social

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ESR

Environmental and Social Risks

ESS

Environmental and Social Standards – World BankFA

Finance Agreement

FSM

Federated States of Micronesia

GBV

Gender Based ViolenceGDP

Gross Domestic Product

GGE

Greenhouse Gas Emissions

GIIP

Good International Industry Practice

GIS

Geographic Information Systems

GoFSM

Government of FSM

GMGrievance Mechanism

GPN

Good Practice Notes

ha

Hectares

HS

Health and Safety

HSP

Health and Safety Plan

IOL

Inventory of Loss

IPF

Investment Project Financing

KIRMA

Kosrae Island Resource Management Authority

km

Kilometers

LMP

Labor Management Plan

MOU

Memorandum of UnderstandingNGO

Non-Governmental Organization

NPOES

National Pollutant Discharge Elimination System

OHS

Occupational Health and Safety

PAP

Project Affected Person

PCRTP

Pacific Climate Resilient Transport Project

PEIS

Preliminary Environmental Impact Statement

PIU

Project Implementation Unit

PM

Particulate Matter

PMA

Protected Managed Areas

PMU

DoTC&I Project Management Unit

PPE

Personal Protective Equipment

PRIME

Prioritized Road Investment and Management Enhancements Project

RAMS

Road Asset Management System

RF

Resettlement Framework

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SCORE

Strategic Climate-Oriented Road Enhancements Project

SEA

Sexual Exploitation & Abuse

SEP

Stakeholder Engagement Plan

SH

Sexual Harassment

SIDS

Small Island Developing States

SIP

Social Interaction Plan

SMP

Spill Management Plan

SOGI

Sexual Orientation and Gender Identity

STD

Sexually Transmitted Diseases

TA

Technical Assistance

TAC

Technical Advisory Committee

TOR

Terms of Reference

TRSA

Traffic & Road Safety Assessment

TRSMP

Traffic and Road Safety Management Plan

UNESCO

United Nations Educational, Scientific and Cultural Organisation

UNFCC

United Nations Framework Convention on Climate Change

USA

United States of America

UXO

Unexploded Ordinance

VA

Vulnerability Assessment

VLD

Voluntary Land Donations

VOC

Volatile Organic Compounds

WMMP

Waste Minimization and Management Plan

WWTP

Wastewater Treatment Plant

WB

World BankWHOWorld Health Organization

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GLOSSARY
Cut-off date

The eligibility cut-off date is the date of completion of the Inventory Of
Loss (IOL) for Project works under Component 2 of both projects.
Assets located within the Component 2 works footprint after this date
will not be eligible for entitlements or associated assistance.

Disadvantaged
Vulnerable People

Those who may be more likely to be adversely affected by the projects
impacts and/or more limited than others in their ability to takeadvantage of a project’s benefits. Such an individual/group is also
more likely to be excluded from/unable to participate fully in themainstream consultation process and as such may require specificmeasures and/or assistance to do so. This will take into accountconsiderations relating to age, including the elderly and minors, andincluding circumstances where they may be separated from theirfamily, the community or other individuals on which they depend.
Specifically, vulnerable groups for PRIME and SCORE, disadvantaged
and vulnerable people consist of the following categories of persons:i) those without legal title to the land or other asset/s, ii) households
headed by females (where appropriate1), iii) the elderly or disabled, iv)
vulnerable road users due to road construction (refer definition to
below), and v) other vulnerable groups, such as people living in
extreme poverty or hardship.

Gender Mainstreaming

The process of ensuring that gender concerns and women’s needs andperspectives are explicitly considered in projects and programs, andthat women participate in the decision-making processes associatedwith development-based activities.

Indigenous Persons

WB ESS7: Referring exclusively to a distinct, vulnerable, social andcultural group possessing the following characteristics in varying
degrees: (i) self- identification as members of a distinct indigenous
social and cultural group and recognition of this identity by other; and(ii) collective attachment to geographically distinct habitats, ancestral
territories or areas of seasonal use or occupation, as well as to thenatural resources in these areas; and (iii) customary cultural,
economic, social, or political institutions that are distinct or separate
from those of the mainstream society or culture; and (iv) a distinct
language or dialect, often different from the official language or
languages of the country or region in which they reside.

Meaningful
Consultation

WB ESF / ESS10: a two-way process that (a) begins early in the aproject planning process to gather initial views on the project proposal
an inform project design; (b) encourages stakeholder feedback,particularly as a way of informing project design and engagement by
stakeholders in the identification and mitigation of environmental andsocial risks and impacts; (c) continues on an ongoing basis, as risks
and impacts arise; (d) is based on the prior disclosure anddissemination of relevant, transparent, objective, meaningful andeasily accessible information in a timeframe that enables meaningful

1 Note: On some islands in FSM all houses are headed by a female as they own the land.

In these cases, the female

head of the household would not be considered a vulnerable person.

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consultations with stakeholders, in a culturally appropriate format, in
relevant local language(s) and in understandable to stakeholders; (e)considers and responds to feedback; (f) supports active and inclusive
engagement with project-affected parties; (g) is free of externalmanipulation, interference, coercion, discrimination, and intimidation;and (h) is documented and disclosed by the Borrower.
PRIME Roads

PRIME will only fund identified primary roads and associated roadinfrastructure. Roads that will be assessed as part of Technical
Assistance (TA) aspects of the PRIME Project, including theVulnerability Assessment (VA), Climate Resilient Road Strategy(CRRS) and Environmental and Social Assessment (ESA) studies,
which include the majority of the existing ‘primary roads’ on the mainislands of each Federated States of Micronesia (FSM) State, and some
additional secondary roads that are considered to be of strategic
and/or economic importance by DoTC&I. Only the primary roads
identified will be funded under Component 2 of the PRIME Project.
Any recommended improvements identified by the VA/CRRS on thesecondary roads will not be considered for funding under Component
2 of PRIME, however they are to be included for investment under
SCORE (see below).

SCORE Roads

Roads that will be assessed as part of Technical Assistance (TA)
aspects of the PRIME Project, including the VA, CRRS and ESA
studies, which include the majority of the existing ‘primary roads’ on
the main islands of each FSM State, and some additional secondary
roads that are considered to be of strategic and/or economic
importance by DoTC&I. Only the strategic secondary roads identified
will be funded under Component 2 of the SCORE Project.

Project Affected
Persons

Includes any person, households, entity, organizations, firms or private
institutions who, on account of changes that result from the Projects
will have their (i) standard of living adversely affected, (ii) right, title, orinterest in any house, land (including residential, commercial,
agricultural, forest, plantations, grazing, and/organizing land), water
resources, communal fishing grounds, annual or perennial crops andtrees, or any other moveable or fixed assets acquired, possessed,
restricted, or otherwise adversely affected, in full or in part,
permanently or temporarily; and/or (iii) business, occupation, place ofwork or residence, or habitat adversely affected, permanently or
temporarily, with or without displacement.

Vulnerable Road Users

Road users who are more vulnerable to harm because they are not ina vehicle, including pedestrians, motorcyclists, cyclists, and those on
animals or animal drawn carts.

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1.

Introduction

1.1

Environmental and Social Assessment Overview
The Government of Federated States of Micronesia (GoFSM) has applied for financing
from the World Bank (WB) for the Prioritized Road Investment and Management
Enhancements (PRIME) and Strategic Climate-Oriented Road Enhancements (SCORE)
Projects to improve the climate resilience of FSM’s road network.
Part of the PRIME and SCORE Projects includes the assessment of environmental andsocial risks including:(i)

Environmental and Social Assessment (ESA);(ii) Preparation of environmental and social instruments in accordance with the WB
Environmental and Social Framework (ESF);(iii) Support stakeholder consultation activities; and(iv) Provision of technical environmental and social advice as required to the GoFSM as
part of project preparation.
The GoFSM through the Department of Transportation, Communications and Infrastructure(DoTC&I), with assistance from the FSM Department of Financial Administration (DoFA)
Central Implementation Unit’s (CIU) safeguard team and external consultants haveundertaken the preparation of the instruments required for WB appraisal including
development of an Environmental and Social Management Framework (ESMF)
incorporating both PRIME and SCORE Projects.
The PRIME ESMF project preparation was undertaken in 2020 and appraised by the bankin early 2021, whilst SCORE project preparations were undertaken in late 2021 to besubmitted to the WB for appraisal and subsequent disclosure in early 2022. As bothprojects are associated with primary and secondary strategically important road network in
the FSM which are intrinsically linked, it was jointly agreed by the GoFSM and the WB to
combine the projects safeguard instruments and as such this combined PRIME and
SCORE ESMF has been developed. The rationale supporting this conclusion centeredaround the benefits in time and costs of a single set of instruments for both projects
decreasing the work requirements and related costs for DoTC&I, CIU and stakeholders tomanage the projects respective components separately. This combined PRIME and
SCORE ESMF supersedes the PRIME ESMF instrument previously developed.

1.2

Environmental and Social Management Framework (ESMF)

1.2.1

Purpose and Scope of the ESMF
As outlined in the World Bank Environmental and Social Framework 2017 (ESF), thepurpose of the Environmental and Social Management Framework (ESMF) is to examine
the risks and impacts of a project when the project consists of a program and/or series ofworks, and the risks cannot be determined until the program or works details have been
identified. This is the case for both the PRIME and SCORE Projects as the specific works
that will form the Projects will only be determined after the completion of the Vulnerability
Assessment (VA) and Climate Resilient Road Strategy (CRRS) studies, both funded under
PRIME.

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Once the works are defined for the PRIME and SCORE Projects and the necessary
information becomes available, the framework will be used to develop the projects specific
Environmental and Social Management Plans (ESMP) proportionate to potential risks andimpacts for specific works.
As set out in Environmental and Social Standard (EES) 1: Assessment and Managementof Environmental and Social Risks and Impacts (ESS 1) of the ESF, the ESMF is to set out
the principles, rules, guidelines and procedures to assess the environmental and social
risks and impacts, as well as measures and plans to reduce, mitigate and/or offset adverse
risks and impacts.
1.2.1.1

Covid-19 Pandemic
On March 11, 2020, the World Health Organization (WHO) declared a global pandemic inresponse to the global spread of the severely infectious 2019 Novel Coronavirus (SARSCoV-2, or ‘Covid-19’).
FSM is particularly vulnerable to the risk of Covid-19 due to its economic reliance oninternational travel of residents, tourists, and trade. Although no cases have been reported
in the FSM to date (as at 01 November 2021), both international and domestic (i.e. interState) travel restrictions have been in place in FSM since March 2020, with strict
quarantine requirements for travelers.
As a result the CIU safeguard team and internationally-based ESA consultants were notable to travel to FSM as part of the preparation of both the PRIME and SCORE Project
ESA’s. Instead, locally based sub-consultants in each State were engaged to undertake
baseline data collection, field survey and stakeholder consultation activities under the
direction of the CIU safeguard team and ESA consultants.
In the absence of physically being present on-the-ground in FSM, the project teams
implemented innovative solutions to baseline data collection including the use of ESRI
ArcGIS Collector, a device (e.g. smart phone) based application which was used by the
FSM-based team to capture data for the PRIME project. The data was automaticallyuploaded to a Geographic Information System (GIS) database. This method of datacollection ensured consistent and comprehensive data and information collection andcommunication and allowed the GIS team to review in ‘real-time’ the data and ‘geo-tagged’
photographs captured in the field.
Consultation meetings were facilitated by the State-based ESA consultant team members
under the guidance of the CIU safeguard team and international consultants. While initialefforts were made to allow off island ESA team members access to participate in online
video conferencing, limited and unreliable internet access hindered participation.
The FSM state-based ESA consultant team were provided with training and consultationmaterial (including presentation, project summary, agenda, meeting minutes template andattendee lists) by the CIU safeguard and consultant team prior to consultation meetings.
This was undertaken to ensure consistency in the messages being communicated to
stakeholders across all four FSM States, to ensure valuable feedback was provided andto manage stakeholder expectations. An internal debrief meeting was then held after the
meeting to discuss any issues raised by the stakeholders and learnings from the process
for each project.

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1.2.2

Links with Other Documents
This combined project ESMF is just one of several Environmental and Social (E&S)
instruments developed to support management of the E&S aspects of the PRIME and
SCORE projects. Other key E&S instruments prepared for both projects include:

PRIME and SCORE Resettlement Framework (RF), November, 2021.



PRIME and SCORE Stakeholder Engagement Plan (SEP), November, 2021.



PRIME and SCORE Labor Management Procedures (LMP), November, 2021.

In addition, each project has an individual, Environmental and Social Commitment Plan
(ESCP).


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PRIME ESCP, June 2021.
SCORE ESCP, November 2021.

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2.

Project Background and Rationale

2.1

Overview of the ‘PRIME and SCORE’ Projects
The Prioritized Road Investment and Management Enhancements (PRIME) and Strategic
Climate-Oriented Road Enhancements (SCORE) Projects will provide funds for technicalassistance and institutional strengthening to improve the management of the road networkin relation to potential climate change impacts for the FSM. PRIME will fund the designand construction of road upgrades on the primary road networks whilst SCORE will fundthe design and construction of road upgrades on strategic priority secondary roads in eachstate to improve resilience to climate-related hazards or events.
FSM faces significant challenges related to its small size, remoteness, geographicaldispersion, environmental fragility and sensitivity to external shocks. Climate projections
predict elevations in air temperature, frequency of days of extreme, increased rainfall andrising sea levels. Sea level rise combined with natural year-to-year changes will accentuate
the impact of storm surges and coastal flooding.
FSM’s transport network is of critical importance to the country’s economy and economic
development through supporting trade and promoting commercial activity by facilitating the
movement of goods and services, and providing safe and efficient access to social services
including schools and health facilities. Critical climate resilient road, bridge and/or
drainage improvement works to be implemented urgently to maintain a basic level of landtransport connectivity in each state will be identified as part of the Projects. The potential
geographic extent of these works for both projects are described and shown in Section
2.4.2.
While some initial road works have been identified as requiring urgent works (refer
Component 2 of each project), the design of the required works has not yet been
undertaken and the full extent of impacts are not yet known. The additional works that will
form the PRIME and SCORE Projects will be identified as part of the Vulnerability
Assessment (VA) and Climate Resilient Road Strategy (CRRS) studies funded under the
PRIME project. As part of these studies a multi-criteria assessment will be undertaken toprioritize the urgency of works and works that will be funded by the projects. Preliminary
environmental and social risk screening will be part of the multi-criteria analysis.

2.2

Climate Adaptation and Resilience Objectives
Frequent natural disasters and climate change impacts impose high costs and may eventhreaten the physical viability of some areas of the main islands of FSM and more remoteouter islands. Droughts, typhoons, storm waves, flooding and landslides all affect FSM.
FSM is particularly vulnerable to the impacts of climate change and is likely to suffer
serious adverse environmental, social and economic losses as a result of climate change
induced hazards. Many people live within the coastal zone and are therefore vulnerable
to climate related changes in precipitation, sea level, storms and coastal erosion.
The negative impacts of climate change are already evident in FSM, for instance, saltwater
intrusion from rising sea levels that damage crops and contaminate freshwater supplies
and increasing extreme weather events such as typhoons. In addition, as drought and sea
level rise are amplified by regional El Niño Southern Oscillation (ENSO) processes,
formerly sustainable atoll communities now rely on imported food and water during timesof stress. Exacerbated by sea level rise, extreme spring tides, known in FSM as ‘King

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Tides’, are causing site-specific intense marine inundation that damages taro beds, soil,
agro-forestry resources, and critical infrastructure along the coast, especially on low atoll
islets.
Similar to other Small Island Developing States (SIDS), FSM is vitally dependent on accessto well-functioning and reliable transportation systems. FSM’s road network is of criticalimportance to the country’s economic development. It provides for the day-to-day wellbeing of its people by increasing their access to economic activities and social services. It
is estimated that around 75% of the population lives within 1 km of the coast, and criticalinfrastructure - such as hospitals, schools, government offices, places of employment,
tourist infrastructure, port facilities, airports, and roads are located within the coastal zone.
The country’s road network and users already suffer regular temporary – sometimes only
for hours, but occasionally longer - breaks of serviceability as vulnerable links or locations
can be frequently rendered impassable and journeys disrupted by flooding, debris deposit,
culvert, bridge and/or pavement damage.
Expected climate change effects - the combination of rising sea level and more intense
typhoons – will place these coastal assets and communities at a higher level of risk. The
FSM road network faces a range of vulnerability issues, in particular:(i) Coastal exposure to sea-level rise, storm surge, wave action during spring tides
and typhoons;(ii) Inland flooding and landslips during extreme rainfall events; and(iii) Accelerated pavement deterioration due to extreme weather and rising watertables in some locations.

2.3‘PRIME’ and “SCORE’ Investments and Activities
The PRIME and SCORE Projects are included within the WB’s Pacific Climate Resilient
Transport Program (PCRTP) series of projects and will make significant investments in arange of climate resilient infrastructure.
Physical works will primarily take place within existing primary (PRIME) and secondary(SCORE) road corridors, or immediately adjacent to the road to improve erosion protection,
drainage or safety features. All roads considered for assistance under these projects areto be existing and are strategical and economically important for the individual statetransport networks.
The three and four key components of the PRIME and SCORE Projects respectively, areoutlined below.

2.3.1

PRIME Component 1: Spatial and Sector Planning Tools
This Component involves Technical Assistance (TA) that will improve the way that climatechange is addressed in FSM’s road sector to enable policymakers to make informed
decisions based on the most accurate and up-to-date information available. The following
activities are proposed under Component 1:a) Vulnerability Assessment (VA) and Climate Resilient Road Strategy (CRRS).
Preparation and implementation of a VA and CRRS to assess levels of vulnerability
to climate change and severe weather events (e.g. sea-level rise, extreme rainfall,landslide, storm surge, etc.) across FSM’s existing primary road corridors and
GoFSM selected existing strategic secondary road corridors. The VA and CRRS

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will also identify measures to enhance resilience and prioritize investments tobalance vulnerability reduction against cost implication. Training will be provided
to relevant national and state officials in the use of VA and CRRS tools. Thesestudies are currently underway (November, 2021)b) Climate-informed road asset management systems. Provision of hardware,
software and ancillary tools to establish climate-informed road asset management
systems to be used by DoTC&I and State Road Authorities. Training has been
and will continue to be provided to relevant National and State officials in the useof these systems.

2.3.2

PRIME Component 2: Climate Resilient Infrastructure Solutions
This Component involves feasibility studies, design and construction of identified priority
road assets to improve their resilience to climate-related hazards. The integration ofclimate change considerations into infrastructure activities will help strengthen theresilience of assets and improve functionality of the road network. Component 2 is split
into two parts:a) Urgent Priority Works (including design and supervision). Critical climate resilientroad, bridge, causeway or drainage improvement works that should be
implemented urgently to maintain a basic level of road connectivity in each state.
Project E&S screening is expected in early 2022 and physical works expected toi
start in early 2023. Urgent works proposed for financing under the PRIME Project
include:(i) Improving the narrow, low-level Lelu causeway in Kosrae;(ii) Replacing the 12 m Awak bridge in Pohnpei;(iii) Improving the 2.5 km airport to Pou Bay bridge road in Chuuk; and(iv) Replacing two short-span (6 m long) steel and concrete composite bridges
in Yap.
b) Works informed by the VA and CRRS (including design and supervision). In
addition to the urgent priorities under Sub-component 2a, a selection of near,medium and long-term road works would be financed to enhance the resilience ofthe network in each state to climate change impacts and natural hazards, inaccordance with the recommendations from the VA and CRRS undertaken as partof Component 1. Works will be restricted to road networks within the existing
primary road corridors. It is expected that physical works will commence in year
3 (2023) of the Project.
Interventions are expected to include measures to strengthen network resilience,
including but not necessarily limited to:(i)Pavement and surface strengthening – periodic maintenance, repairs,
rehabilitation or reconstruction of existing road pavement layers and/or
surfacing, including provision of sealed shoulders and raising road levels;(ii) Drainage improvements – provision, reinstatement and/or lining of
longitudinal drainage, replacement and/or increasing capacity of crossdrainage culverts, improving open or covered outfalls, provision of subsoil
drainage and cut-off drains;

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Environmental and Social Management Framework(iii) Spot slope stabilization – widening and/or reducing slope of cuttings andfill embankments to reduce landslip risk, soil bioengineering andbiotechnical stabilization techniques, and anchoring of unstable rockslopes;(iv) Rock wall revetment strengthening – for protection of coastal roadsections;(v) Improvements to causeways and bridges – repairs or reconstruction ofexisting crossings and/or provision of new crossings to provide safe, allweather access for vehicles and pedestrians; and(vi) Road safety improvements – traffic calming measures, provision ofguardrails, line marking and minor realignments to improve sight distance.
Design of civil works will conform to international design codes of practice such as
Austroads2 for road and bridge design. Specifications for all works and materials will also
be in accordance with international standards, making use of innovative materials andapproaches if they will enhance climate resilience.
Once the proposed Component 2 works have been identified as part of the VA/CRSS
prioritization process, early environmental and social risk screening will identify significant
impacts that require avoidance and mitigation and will contribute to project selection for
funding under the PRIME Project prior to commencement of preliminary design for theworks.
Further environmental and social risk screening will be undertaken once concept
preliminary designs have been developed to determine whether:(i) There are high risk (significant) environmental and/or social aspects of these works
that could prevent the works from being included under the PRIME Project;(ii) Works could be designed in a way to minimize environmental and social impacts;or(iii) Specific environmental assessments (such as ESIAs) and ESMPs, and Land
Access Reports/Plans are to be prepared. If works are subsequently redesigned,
further screening may be appropriate.

2.3.3

PRIME Component 3: Strengthening the Enabling Environment
This Component will provide funding to support institutional and regulatory reforms for road
sector asset management and maintenance, including measures to strengthen local
capacity and to increase the sustainability of climate resilient road sector investments. In
addition, this Component will help to strengthen coordination among relevant institutions,will look at ways in which road sector management can be improved, and will address any
emerging priority issues that can help support GoFSM in addressing climate change risks.
Proposed sub-components include:a) Institutional and Governance Review. A review of institutional arrangements,
key policies, regulations, legislation and roles and responsibilities of principle
stakeholders involved in the road sector with recommendations to strengthen sucharrangements. This review is currently underway (November, 2021).

2

https://austroads.com.au/

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Environmental and Social Management Frameworkb) Project Management. Establishment and maintenance of a Project
Implementation Unit (PIU) to support the implementation of the PRIME Project. In
addition, this includes operating costs for PRIME-related travel andcommunications costs. The PIU has been established and is operational(November, 2021). The PRIME PIU will also be responsible for the SCORE project
once approved.
c) Road Safety Program. Provision of technical assistance activities to improve roadsafety.
d) Capacity Building Initiatives. Assess current preventive maintenance techniques
and industry capacity. Provide technical trainings to sector agencies and local
consultants and contractors to better operate and regulate a more climate resilient
road network.
e) Gender-informed Driver Licensing Pilot. A pilot program to study and implement
activities that address gaps in the possession of a driver’s license.
f)

Emerging Priority Issues. Providing technical assistance to strengthen the
Recipient’s capacity to address emerging priority issues that could have an impact
on the Recipient’s ability to manage a climate resilient road network.

Environmental and social instruments outlined in Section 1.2.2 (e.g. RF, ESMF, LMP, SEP
and ESCP), provide the methods to manage the environmental and social risks relating to
the technical advisory services that will be funded under this component. These
instruments are relevant for all activities under each Component. Environmental and social
instruments specifically relevant to Component 3 include the ESMF, ESCP, SEP and LMP.

2.3.4

SCORE Component 1: Spatial and Sector Panning Tools
This Component involves Technical Assistance (TA) to support FSM in the way that climatechange is addressed in the road sector through analytical and sector planning tools thatenable policymakers to make informed decisions based on the most accurate and up-todate sector information available.
The following activities are proposed under Component 1:a) Finance spatial and sector planning tools: To provide specific funds to further
develop the PRIME funded Vulnerability Assessment (VA) and Climate Resilient
Road Strategy (CRRS) to assess levels of vulnerability to climate change and severe
weather events (e.g., sea-level rise, extreme rainfall, landslide, storm surge, etc.)
across FSM’s existing primary road corridors and GoFSM-selected existing strategic
secondary road corridors. The VA and CRRS will also identify measures to enhance
resilience and prioritize investments to balance vulnerability reduction against cost
implication. Training will be provided to relevant national and state officials in the use
of VA and CRRS tools.
b) Establishment of a Crash database: Preparation of a climate-informed Road
Crash Database based on the outcomes of the PRIME Road Safety Diagnostic.
The establishment of a crash database will allow for the recording and analysis of
all road accident data, thereby enabling an evaluation of contributing factors to thecrashes. The free, open-source (Data for Road Incident Visualization, Evaluation,
and Reporting) DRIVER software developed by the World Bank (WB) for thePhilippines, and now rolled out to 10 other countries, is a promising software touse as the crash database. The intention is to link the database to the Road Asset

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Management System (RAMS) that is being set up under PRIME. Staff hired for the
Data Collection Unit (under Component 3) would be trained to manage andeffectively use the road crash database.

2.3.5

SCORE Component 2: Climate Resilient Infrastructure Solutions
This Component involves feasibility studies, design, and construction of identified priority
strategic secondary road assets to improve their resilience to climate-related hazards
and/or events. The integration of climate change considerations into infrastructure
activities will help strengthen the resilience of assets and improve functionality of the road
network. The VA and CRRS under PRIME will guide the investments to be included within
this Component. Interventions are expected to include measures to strengthen network
resilience, including but not necessarily limited to:












2.3.6

Pavement and surface strengthening – periodic maintenance, repairs, rehabilitation
or reconstruction of existing road pavement layers and/or surfacing, including
provision of sealed shoulders and raising road levels;
Drainage improvements – provision, reinstatement and/or lining of longitudinal
drainage, replacement and/or increasing capacity of cross drainage culverts,
improving open or covered outfalls, provision of subsoil drainage and cut-off drains;
Spot slope stabilization – widening and/or reducing slope of cuttings and fillembankments to reduce landslip risk, soil bioengineering and biotechnicalstabilization techniques, and anchoring of unstable rock slopes;
Rock wall revetment strengthening – for protection of coastal road sections;Improvements to causeways and bridges – repairs or reconstruction of existing
crossings and/or provision of new crossings to provide safe, all weather access forvehicles and pedestrians;
Road safety improvements – traffic calming measures, provision of guardrails, line
marking and minor realignments to improve sight distance.
Other improvements to causeways and bridges as required.

SCORE Component 3: Strengthening the Enabling Environment
This Component will help to strengthen coordination among relevant institutions, will lookat ways in which road sector management can be improved, and will address any emerging
priority issues that can help support the Government in addressing climate change risks.
Considering SCORE is an extension (including the strategic secondary roads) of the
PRIME project, the same PIU and CIU staff involved in PRIME will also be involved in the
preparation and implementation of SCORE. This component includes the following
activities:a) Project Management. Provide operating funds for SCORE related travel andcommunications costs. It also includes provision of technical assistance activities toassess environmental and social risks, its impacts and the preparation ofenvironmental and social safeguard instruments that enhance the sustainability of
SCORE’s climate resilient road sector activities in accordance with the WB ESF andlaws of the FSM.
b) Road Safety Program. Provision of technical assistance activities to improve roadsafety more climate resilient road network. This will include baseline and detailed
design stage road safety audits and post-construction road safety audits for all road

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c)

d)

e)

f)

g)

3

works. The road safety audits will also include access audits3 for persons withdisabilities. The purpose of these road safety audits is to identify areas of concern
for the safety of all road users. The audits will systematically analyze the potential
risks making the infrastructure unsafe. The recommendations arising out of theseaudits will inform the detailed design of the works to mitigate the hazards. Follow-up
technical assistance to implement the recommendations of the PRIME Road Safety
Diagnostic may also be financed under this Sub-component.
Material Testing Laboratory. Geotechnical investigations during design of road andbridge improvements require a range of materials tests, and construction works
contracts require extensive testing, by both contractor and employer, of granularmaterials for pavement layers, bituminous and asphaltic materials for flexible
surface layers, and concrete and steel for structures and concrete pavements. The
project will provide technical assistance and equipment for the establishment andinitial operation of a government-owned materials testing laboratory in FSM.
Transport sector data collection unit. This is expected to include the developmentof a transport sector data collection unit housed within DoTC&I. With thestrengthening of sectoral and spatial planning tools and more robust data-driven
analysis the need for a dedicated team with requisite technical skills to gather andmaintain vital data relevant to transport sector management has become apparent.
It is expected that SCORE would initially fund five posts – one junior level officer foreach state and a senior consultant under DoTC&I (the first two years of project
implementation), after which time the individuals will be employed under contract to
GoFSM. The funding source for these positions would then transition to GoFSM
budget.
Gender and gender-based violence (GBV) Initiatives. SCORE will complement
activities under PRIME that enhance women’s representation in technical roles
within the DoTC&I and provide support to DoTC&I Gender Equality Program.
SCORE will also provide support to address potential SEA and SH concerns related
to Project implementation. The following support will be provided to reduce SEA andSH prevalence levels in FSM: (i) provide training to Project workers; (ii) conduct
community awareness raising activities; (iii) support GBV survivors throughstrengthening of services of local service providers; and (iv) establish a referral
pathway for GBV survivors.
Sustainable Motorization Management. technical assistance that would
recommend policy interventions and implementation arrangements to assist GoFSM
to better manage what vehicles are allowed into the country, how these vehicles areoperated and maintained throughout their lifecycle, and what to do with vehicles
when they are considered to have reached end-of-life- status. Better managing the
motorized vehicle fleet is important for both climate change mitigation andadaptation.
Emerging Priority Issues.
Providing technical assistance to the Recipient tostrengthen their capacity to address emerging priority issues that could have an impact
on the Recipient’s ability to manage a climate resilient road network.

The access audits will identify areas of concern and recommend related improvements to selected

infrastructure for persons with disabilities.

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2.3.7

SCORE Component 4: Contingent Emergency Response
This component is designed to provide swift response in an event of an Eligible Crisis or
Emergency4, by enabling GoFSM to request the WB to re-allocate project funds to support
emergency response and reconstruction.

2.4

Project Location

2.4.1

National Context
FSM is located near the equator about 4,000 kilometers (km) southwest of the Hawaiian
Islands in the Western Pacific Ocean and within the Caroline Islands group. The largest
nation in the Micronesian sub-region, FSM is made up of four semi-autonomous states(Kosrae, Pohnpei, Chuuk and Yap) located between Marshall Islands to the east, Palauand the Philippines to the west and Guam north (refer Figure 2-1).
FSM is made up of 607 islands scattered over an area of about 2.6 million km2, including
its Exclusive Economic Zone (EEZ), in the western Pacific Ocean. The total land area of
FSM is 704.6 km2, with 7,192 km2 of lagoon area. The islands vary from small islets, which
are inundated at high tide, to atolls and large volcanic islands with land area of more than
80 km2. Approximately 65 (approx. 10%) of the islands are inhabited.
In general, there is only one primary, circumferential route on each of the four main FSM
Island states with secondary smaller roads providing access to properties in the islandinterior. In addition, most of the population in FSM lives close to the coast, and criticalinfrastructure including roads, schools, places of employment, port facilities, tourist
facilities, power plants and airports, are located primarily in the coastal zone.

4 Defined as “an event that has caused, or is likely to imminently cause, a major adverse economic and/or social

impact associated with natural or man-made crises or disasters”, Paragraph 12, Bank Policy: Investment Project
Financing, Projects in Situations of Urgent Need of Assistance or Capacity Constraints.

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Figure 2-1: Location of FSM States: Kosrae, Pohnpei, Chuuk and Yap

2.4.2

Extent of PRIME and SCORE Roads
The project roads have been defined as the roads that will be assessed as part ofTechnical Assistance aspects of the PRIME Project, including the VA/CRRS and ESA
studies, which include the majority of the existing ‘primary roads’ on the main islands ofeach FSM State, and some additional secondary roads that are considered to be ofstrategic and/or economic importance by DoTC&I and counterpart State government
agencies. The extent of the PRIME and SCORE Roads in each State are shown in thesections below.
Only works that have been prioritized for primary roads identified by the VA/CRRS will be
eligible for funding under Component 2 of the PRIME Project. Only works that have beenprioritized for strategic secondary roads identified by the PRIME funded VA/CRRS will be
eligible for funding under Component 2 of the SCORE project.
The exact location of works, and the proportion of both projects roads that will have climate
resilient road works funded by the projects will vary between States depending on theprioritization process and the nature of the works proposed.

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2.4.2.1

Kosrae State
The primary road network in Kosrae consists of the coastal road which circles two-thirdsof the island, built largely on the coastal strand bordered by mangrove forest and coastal
shoreline, from Utwe in the south through to the Airport at Okat in the northwest. The
PRIME road extent on Kosrae includes much of the primary road network and are provided(white) in Figure 2.2.
The strategic secondary road asset network consists of smaller roads providing access toproperties in the island interior and/or alternative/traditional routes. The secondary road tothe north east of the island (refer Figure 2-2 - red) is considered by DoTC&I to be ofstrategic and economic importance to Kosrae as an alternative higher level access routeand commercial activity on that road.

Figure 2-2: Extent of PRIME (white) and SCORE (red) Roads on Kosrae.

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2.4.2.2

Pohnpei StateThe Primary road network in Pohnpei consists of a paved 77 km coastal circumferential
road, built largely on the coastal strand bordered by mangrove forest and coastal
foreshore. The PRIME road extent on Pohnpei is provided (yellow) in Figure 2.3.
The strategic secondary road asset network consists of smaller roads providing access toproperties in the island interior and/or alternative/traditional routes. The strategic
secondary roads identified by DoTC&I include; i) the road southwest of the island capital,
Kolonia provides an alternative higher level access route to the nation’s capital (Palikir) as
well as servicing the island power plant, wastewater treatment plant and residential houses
and ii) and the road that services Nan Madol, a significant archaeological site (tourism) on
the eastern shore of Pohnpei that has been declared a United Nations Educational,
Scientific and Cultural Organization (UNESCO) World Heritage Site (Figure 2-3).

Nan Madol

Figure 2-3: Extent of PRIME (yellow) and SCORE (red) Roads on Pohnpei.

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2.4.2.3

Chuuk StateThe Chuuk State capital is located on Weno Island and has a circumferential road that is
approximately 18.5 km in length, includes several additional inland roads servicing thetownship (community and commercial center). The Weno primary road network within thetownship is paved and varies in road surface condition, whilst outside of the main capital
the road network is in very poor condition. The PRIME road extent on Weno Island includes
much of the primary road network and are provided (white) in Figure 2.4.
The strategic secondary road asset network identified by DoTC&I consists of smaller roads
providing access to properties in the island interior and/or alternative/traditional routes, forexample: the secondary road to the north east of the island, north and south Pou roads(refer Figure 2-4 red) are considered by DoTC&I to be of strategic and economic
importance to the communities of Weno as an alternative access route connecting thecommunities on the northern and southern side of the island to the islands government
services (e.g. hospital) and commercial activities.

Figure 2-4: Extent of PRIME (white) and SCORE (red) Roads on Chuuk.

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2.4.2.4

Yap State
The primary road network on Yap consists of a coastal and inland roads network andincludes three primary roads: the main trunk road that runs from the southern end of Yap
Island in Magachil to the northern end of Maap Island; the Yap Central Loop; and a roadthat branches off the main trunk road serving the districts of Gagil. The PRIME Road extent
on Yap consists of the primary road network, plus additional branches of the road to Ruu
and Bugol as shown in white in Figure 2-5.
The strategic secondary road asset network consists of smaller roads providing access tothe villages and properties in the island interior and/or alternative/traditional routes. The
secondary road to the north west of the island, (refer Figure 2-5 red) is considered by
DoTC&I to be of strategic and economic importance to the communities of Yap as analternative access route connecting the communities on the east and west sides of theisland to the islands government services (e.g. hospital) and commercial activities.

Figure 2-5: Extent of PRIME (white) and SCORE (red) roads on Yap.

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3.

Legislative & Regulatory Framework

3.1

FSM National Government Legislation, Regulations andPolicy Requirements

3.1.1

Overview
The GoFSM is modeled after the federal system similar to that of the United States ofAmerica (USA) with a national president and four state governors with respective
legislatures and judiciaries. The states of Pohnpei, Chuuk and Yap have four levels ofgovernance – National, State, municipal, and traditional. Kosrae does not have the fourthlevel of government, as it no longer has traditional leadership.
The four States of FSM (Kosrae, Pohnpei, Chuuk and Yap) have considerable degrees ofautonomy. Each State also has its own set of environmental and social laws andregulations geared to protect the States from a wide range of environmental impacts
including, the effects of climate change. Under the Compact II, Article VI and section 161
of Title II, FSM is committed to applying the National Environmental Policy Act 1969 (sincerepealed) and “to develop and implement standards and procedures to protect its
environment”.
The following articles of legislation are relevant to the PRIME and SCORE projects.

3.1.2

FSM Constitution
The Constitution of the FSM (the ‘Constitution’) is the supreme law in FSM, and includes
a bill of rights (Art IV).
The Constitution acknowledges and protects the role and functions of traditional leaders
as recognized by custom and tradition, as well as the traditions of the Micronesian people(Art V).
The Constitution establishes National, State and Municipal levels governance (Art VII).
Each State is required to have its own democratic Constitution. The Constitution refers to
traditional practice and custom as a guiding influence in all aspects of decision-making in
FSM and seeks to preserve the role of tradition and custom in FSM life. To support this, aCouncil of Chiefs consisting of traditional leaders and elected representatives is provided
for in the Constitution.
Article IX of the Constitution establishes FSM’s legislature, which selects the President,
and with members elected for districts in each state according to population. Each State
elects their own legislature and governor. The National legislature has the power to makelegislation on a wide range of topics. For example, they may make laws “to regulate theownership, exploration, and exploitation of natural resources within the marine space of
the Federated States of Micronesia beyond 12 miles from island baselines” [Title 3].
Article X of the Constitution vests FSM’s executive power in an elected President as the
Head of State, who is elected by Congress for a four-year term and limited to no more than
two consecutive terms. The President appoints judges, ambassadors and principal officersof government departments in the National Government.
Article XI of the Constitution establishes the judiciary of FSM as comprised of the Supreme
Court, and subsidiary courts, established by statute. The Judiciary Act of 1979 provides

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to be consistent with Micronesian customs and traditions.
The legislative power of the National Government is vested in Congress. The Congressincludes one member elected from each of the four States, an additional member electedfrom congressional districts in each State apportioned by population. Chuuk, Pohnpei andYap may decide that one of its seats be reserved for a traditional leader in place of one of
the elected representatives.
Regulation development, as prescribed under the FSM Administrative Procedures Act,requires the widespread publication and dissemination of proposed regulations before
adoption, including radio announcements in English and indigenous languages.
Opportunities for public comment and public hearings are incorporated in the Act.
In most instances, national legislation is supplemented, or even duplicated, by Statelegislation.
The Constitution contains several references to the environment, land use and customs,
including the following:

3.1.3

PreambleStates, in part, “[t]o make one nation of many islands, we respect the diversityof our cultures. Our differences enrich us. The seas bring us together, they
do not separate us. Our islands sustain us, our island nation enlarges us andmakes us stronger.”

Article XIII

Contains additional provisions, including some that relate to the environment.

Section 2

Provides that “radioactive, toxic chemical, or other harmful substances may
not be tested, stored, used, or disposed of within the jurisdiction of theFederated States of Micronesia without the express approval of the national
government of the Federated States of Micronesia.”

Section 4

In terms of land use, “[a] noncitizen, or a corporation not wholly owned bycitizens, may not acquire title to land or waters in Micronesia.”

Section 5

Prohibits a lease agreement for the use of land for an indefinite term by a
noncitizen, a corporation not wholly owned by citizens, or any government isprohibited.

Section 113 (General
Provisions)

Empowers the High Commissioner to restrict or forbid non-citizens fromacquiring interests in real property and in business enterprises.

Section 114 (General
Provisions)

Requires due recognition to be given to local customs in the system of law.

Section 202 (General
Provisions)

Provides that customs not in conflict with other laws in Micronesia arepreserved.

FSM Environment Protection Act (2014)
The Environment Protection Act (revised Code 2014) provides for the protection of theenvironment, culture, historic and natural aspects of Micronesian heritage.
The Act is a national government declaration of on-going commitment in cooperation with
State and municipal governments and other concerned public and private organizations.
The Act declares to use all practicable means and measures, including financial andtechnical assistance, in a manner calculated to foster and promote the general welfare tocreate and maintain conditions under which the people of FSM man and nature can exist
in productive harmony and fulfill the social, economic, and other requirements of present
and future generations of FSM.

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The Act declares that it is the continuing responsibility of the FSM to use all practicablemeans, consistent with other essential considerations of national policy, to improve andcoordinate governmental plans, functions, programs, and resources to the end that the
inhabitants of the FSM may:a. Fulfill the responsibilities for each generation as trustee of the environment forsucceeding generations;b. Assure for all Micronesians safe, healthful, productive, and aesthetical and culturally
pleasing surroundings;
c. Attain the widest range of beneficial uses of the environment without degradation,risk to health or safety, or other undesirable or unintended consequences; andd. Preserve important historic, cultural, and natural aspects of our Micronesian
heritage, and maintain, wherever possible, an environment, which supports diversityand variety of individual choice.
The effort to protect and preserve the environment needs to be carried forward in close
cooperation with the States in the formulation of policy, enforcement, and other activities.
The FSM recognizes that each person has a responsibility to contribute to the preservationand enhancement of the environment. Section 302 of the Environmental Impact
Assessment Act states that - 1) any person, prior to taking any action that may significantly
affect the quality of the environment within the EEZ of the FSM, or within the boundariesof the National Capital Complex at Palikir, must submit an environmental impact statement
to the Director, in accordance with regulations established by the Director. (2) The
environmental impact statements required by subsection (1) of this section are public
documents.
Building on the Trust Territory Environmental Quality Protection Act (Title 25 of the FSM
Constitution), the FSM Environmental Protection Act 1984 (FSM EPA), and its subordinate
instruments, seeks to provide the legislative basis for the protection of the environment,
including cultural, historic and natural aspects of Micronesian heritage, throughout FSM.
The Act acknowledges that close co-operation between the National and State
Governments is required to support this objective.
The 1969 Act established the Environmental Protection Board within the Office of the
President. The Board is composed of five members: “one member from each State andone member appointed by the President”. In 1987, an Act to Reorganize the Governmentof the FSM redefined the Board to mean the Secretary for Human Resources.
The Act requires the Secretary to enter into written cooperative arrangements with theStates or State agencies for the purposes of providing funds to the States, collecting dataon local needs and transferring authority to the States to act as agents of the National
Government in implementing environmental programs at the State level. Such delegationof functions may be withdrawn on written advice from the Secretary if the delegation resultsin termination of any financial grant.
The Secretary, as a result, has broad authority to protect health, welfare and safety and to
implement policy and strategies, through the promulgation of regulations, to remedy
pollution and contamination of air, land and water.

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3.1.4

FSM EPA Environmental Impact Assessment Regulations (1989)
The purpose of the Environmental Impacts Assessment (EIA) Regulations is to implement
Section 13 of the FSM Environmental Protection Act by establishing standard proceduresfor preparation of an environmental impact assessment statement prior to taking or funding
any major action that may significantly affect the quality of the human environment.
These Regulations require the National Government and its agencies to submit an
Environmental Impact Statement (EIS) to the Secretary of Human Resources prior to taking
any “major”5 action significantly effecting the quality of the human environment. “Effect” isdefined to include indirect, direct and cumulative effects in areas such as land use,
population density, air, water and natural systems including ecosystems. “Effects” may beecological, aesthetic, cultural, historical, economic, social or health-related. “Significant
Impacts”, determined as a result of a preliminary assessment, require a Comprehensive
EIA. Draft EIA statements are to be made available for public comment and review,
including provision for a public hearing.
Part I (l) defines Project Proponents as the FSM National Government or its agencies or
the recipient of funding from the FSM National Government or its agencies, that propose
to undertake any major action significantly affecting the quality of the human environment.
Part III sets out the EIA process. Part IV elaborates on this process which is a two-step
assessment process with the first step being the submission of an Initial Assessment using
a checklist template. If following evaluation there are potentially severe environmental
impacts, then a Comprehensive EIA is required. The contents of the Comprehensive EIA
are set out in Part V.
The EIA process is intended to help the general public and government officials makedecisions with the understanding of the environmental consequences of their decisions,and take actions consistent with the goal of protecting, restoring, and enhancing theenvironment. These regulations provide the directions to achieve this purpose. In addition,these regulations are designed to:a. Integrate the EIA process into early planning of projects to ensure timely
consideration of environmental factors and to avoid delays; andb. Identify at an early stage the significant environmental issues requiring further
study thereby defining the scope of the EIA.
For the PRIME and SCORE projects, DoTC&I in association with their state counterpart
agencies (state Transport Divisions/Departments) and the CIU Safeguards Team would
identify the range of permits required, prepare the assessments and the permit
applications. As much as possible / relevant the assessments will be prepared for boththe WB and FSM requirements

3.1.5

Labor Law
FSM has national legislation that outlines worker’s rights. The Labor Code (Title 51)
outlines hiring of non-resident workers, labor development, and other requirements. The
Labor Code requires:

5 No definition is provided for a ‘Major’ action in the Regulations. For the purposes of this assessment it isassumed that the urgent works PRIME and SCORE projects constitutes a ‘Major’ action given the potential
nature and scale of associated potential impacts.

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Non-resident workers to obtain health certificates and have a minimum of two yearsof related work experience;b.

Any benefits provided to non-resident construction workers such as housing,transport, etc. will also be provided to any national contractor who is required toleave their principal place of residence for work;c.

Applications for foreign workers are needed, unless the foreign workers will be in the
country less than 90 days; andd.

Minimum employment conditions outlined in the Code apply to all foreign workers.

Legislation related to occupational health and safety is limited. The Public Employment
Code 2014 requires that workers exposed to hazardous working conditions are additionallycompensated.

3.1.6

Other Relevant Legislation
Current environmental regulations relevant to the PRIME and SCORE Projects which draw
heavily on legislation put in place during Trust Territory arrangements include thoseoutlined below.
Legislation related to land tenure and land acquisition in FSM for both projects is outlinedin the combined PRIME and SCORE RF.
While there are laws regulating closed marine areas in FSM, there is no legislation
dedicated solely to protected areas in FSM.
FSM does not have any disaster risk management legislation; however a Nationwide
Climate Change Policy was created in 2009 (FSM, 2009). The focus of this Policy is to
mitigate climate chance especially at the international level and adaptation at the national,
state and community levels to reduce the FSMs vulnerability to climate change adverse
impacts.

3.1.6.1

Marine and Freshwater Quality Standards Regulations (1986)
The Marine and Freshwater Quality Standards Regulations (1986) identify the uses forwhich waters of FSM shall be maintained and protected in order to specify water quality
standards required to maintain the designated use and to prescribe requirements tomaintain specified water quality. Any entity responsible for a point source discharge thatthreatens a breach of these standards, unless it has received a discharge permit under the
National Pollutant Discharge Elimination System (NPDES) from the USEPA, is in breachof these Regulations.
These Regulations provide the basis for the state water quality Regulations, with EPA /Kosrae Island Resource Management Authority (KIRMA) managing these requirements atthe state level. Most of their effort is allocated to drinking water quality rather than river or
marine waters and, as a result, baseline data is sparse. Rivers and streams and coastal
areas potentially impacted by PRIME and SCORE project activities will require baseline
data collection and ongoing monitoring as detailed in this ESMF.

3.1.6.2

Trust Territory Solid Waste Regulations (1979)
The Trust Territory Solid Waste Regulations (1979) establish minimum standards for thedesign, construction, installation, operation and maintenance of solid waste storage,
collection and disposal systems. “Solid Waste” is defined as “garbage, refuse, and otherDecember 2021

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discarded solid waste materials” not including substances in water sources, but including
liquid waste such as waste oil, pesticides, paints, solvents and hazardous waste. A“disposal system” includes the entire process of storage, collection, transportation,
processing and disposal of solid waste by any person or authority.
All waste generated as a result of the PRIME and SCORE projects will be recycled where
possible with residual material being disposed of at a facility permitted by the state
EPA/KIRMA.
Measures related to solid waste management, including minimization, recycling and reuseof material, will be developed in the PRIME Generic ESMP and will be included as requiredin all PRIME and SCORE project site specific ESMP/s. A Waste Minimization andManagement Plan (WMMP) is also to be prepared by the Contractor which sets out
strategies and actions required to reduce potential health and environmental risks
associated with waste generation and disposal, as well as opportunities for constructionwaste reuse.
3.1.6.3

FSM EPA Earthmoving Regulations (1988)
These Regulations provide that “no person shall release funds, equipment or materials orbuilding permit to those engaged in earthmoving activities until a permit is issued by the
Secretary of Human resources”. Earthmoving is defined to include activities of a continuous
nature such as dredging or quarrying which disturb or alter the surface of the land, including
reefs and lagoons. Earthmoving also applies to the subdivision of land, and the moving,depositing or storing of soil, rock, coral or earth.
All aggregate material used for roading (and other works) construction activities will require
to be sourced from a quarry facility that has the appropriate permit. DoTC&I will need toestablish from State agencies whether a permit is required for the “depositing or storing ofsoil, rock, coral or earth” in relation to the PRIME and SCORE Projects. If aggregatematerial is imported then State regulations will also need to be met.
Measures related to earthmoving, as well as use of aggregate material are outlined in the
PRIME Generic ESMP which will be updated to reflect SCORE project, including theprohibition of the use of coral reef/rock for project activities. The disposal, and whereappropriate reuse, of excavated material will be addressed in the Contractor’s WMMP.

3.1.6.4

FSM Constitution, Title 26 Historical Sites, and Antiquities
The FSM Code Title 26 – Historical Sites and Antiquities states that it is FSM policy toprotect and preserve the diverse cultural heritage of the peoples of Micronesia and to
identify and maintain areas, sites and objects of historical significance. “Cultural attribute”
is defined as all aspects of local culture, tradition, arts, crafts, all social institutions, formsof expression and modes of social interaction. “Historical property” is defined as sites,
structures, building, objects, and areas of significance to local history, archaeology andculture. “Historical artefact” means an object 30 years or more in age.
Although the Act allows for the establishment of the Institute of Micronesian Culture andHistory, the Institute was never established and, in 1987, the relevant section of the Act
was repealed. The administrative body charged with the preservation of cultural heritageis the Office of Administration Services, which established the Division of HistoricPreservation in 1988. The Division is currently staffed by one Historic Preservation Officer.
To promote liaison with the States, local staff are employed to assist with the work of theDivision in the States.

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3.1.6.5

Trust Territory Air Pollution Control Standards and Regulations (1980)
This Regulation sets air quality standards by preventing or controlling the emissions of air
contaminants at their source. The Regulations incorporates USEPA National Emission
Standards for Hazardous Air Pollutants. If the PRIME and SCORE projects requires theuse of an Asphalt plant consideration to the standards for this activity will be required6.

3.1.6.6

Toilet Facilities and Sewerage Disposal Regulations (1977)
These Regulations establish minimum standards for toilet facilities and sewerage disposal
to reduce environmental pollution, health hazards, and public nuisance from such facilities.
Standards are established for i) flush toilets connected to a sewerage system available tothe public, ii) flush toilets connected to septic tanks and iii) a pit privy or outside banjo. All
public and private buildings require toilet disposal facilities approved by the Secretary of
Human Resources. The Regulations make it unlawful to dispose of treated or semi-treatedsewerage into any body of water in FSM, unless it can be clearly demonstrated that suchactivity is necessary for the economic and social benefit or research and that the activity
poses no public health hazard.

3.1.6.7

FSM Constitution Title 23 Resource Conservation
Marine species preservation is promoted under the FSMC Title 23 – Resource
Conservation, Chapter 1, Marine Species Preservation, which is based on Trust Territory
Code. Chapter 1 provides for the control of destructive fishing practices and prohibits theuse of explosives, poisons, chemicals or other substances which kills fish or marine life forcatching or killing fish unless authorized by a permit. The Chapter places limitations on
the harvesting of hawksbill turtles and sea turtles, cultivated sponges, black-lip mother-ofpearl oyster shell, trochus and marine mammals.
Title 23 – Resource Conservation (Chapter 2) of the Trust Territory Endangered Species
Act 1975 provides for the protection of endangered fish, shellfish and game. The Act
declares the indigenous plants and animals of the FSM to be of aesthetic, ecological,
historical, recreational, scientific and economic value. The Act further states that the policyof FSM is to foster the well-being of these plants and animals including the prevention of
the extinction of any species.
The Act is administered by the Director of the Department of Resources and Development(DRD) and provides the Director with the authority to set up conservation and research
programs aimed at conserving endangered and threatened species. It also provides
authority to acquire land or aquatic habitats for the conservation resident endangered or
threatened species. It is uncertain if any acquisitions or associated conservation programs
have been established by the Department.
Note that the National Government does not have jurisdiction inside the 12 nautical milesof any land/reef limit, which is the responsibility of the individual States (See Section 3.2
for further detail).

3.1.6.8

FSM Land Use Act
Section 205 of the General Provisions of the Land Use Act for FSM provides that “[t]he law
concerning ownership, use, inheritance, and transfer of land in effect in any part of theTrust Territory on December 1, 1941, shall remain in full force and effect to the extent that
6 See https://www.epa.gov/stationary-sources-air-pollution/risk-and-technology-review-asphalt-processing-and-asphalt-roofing-0
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The Government Property Acquisition [Title 56] deals with eminent domain (Chapter 1),
real property acquisition (Chapter 2), relocation assistance (Chapter 3) and alien property(Chapter 4).
This provisions of this Act are outlined in the RF.

3.2

State Government
Requirements

Legislation, Regulation and Policy

The four States of FSM each have their respective state level regulations and legal
frameworks elaborating on the National Constitution and EIA Regulation and stipulating
their specific requirements. The state level EIA Regulations are briefly discussed below.
Note that it is the State regulations that are the most important for the PRIME and SCORE
projects, as the physical works will be monitored at a State level.
State legislation related to land tenure and land acquisition is outlined in the RF.

3.2.1

Kosrae3.2.1.1

The Legal Framework
The following laws and policies that exist in Kosrae for managing and conserving theenvironment that may apply to the PRIME and SCORE projects:
Constitution of the State of Kosrae 1984 (Primary rule of law in the State of
Kosrae).



Kosrae State Code, Title 17, Chapter 4 (Establishes the Kosrae EPA).



Kosrae State Code Title 9 (Establishes the Kosrae Protected Areas System).

Kosrae Island Resource Management Act.



Kosrae State Development Regulation 2014.



Kosrae State Code, Section 11.103 (State Acquisition of Land).



Kosrae Code, Section 11.1401 and 11.1402 (Protection of antiquities andtraditional culture).

Kosrae Code, Section 11.1601 (Endangered species).

Kosrae Code Section 11.201 (Land use and subsidiary regulations).

Kosrae Code, Section 13.1201 (Toilets and the disposal of domestic (human)
waste).



Kosrae Code, Section 13.506 (Littering).



Kosrae Code, Section 13.514 (Water quality).



Kosrae Code, Section 13.524 (Endangering a species).

The Development Review Commission (DRC) is a five-member body that reviews
development proposals and is mandated to “protect the environment … balancing
development with those of environmental quality … ensuring that economic and social
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development is environmentally sustainable”. The DRC has the authority to enter, enforce,and issue injunctions, mandamus, or other remedies requiring compliance through thestate’s Attorney General. Further, the DRC has the authority to protect the environment
and antiquities.
The State can acquire an interest in private land for public purpose. The Constitution and
Article XI, Land and Environment, provide for fair compensation should there be a need forland acquisition for the purpose of resettlement. The process must be done in good faithwith reasonable effort to avoid substantial hardship to the interested parties.
3.2.1.2

Kosrae Constitution (1984)
Article XI of the Kosrae Constitution addresses land and environment matters. It grants
the people the right to “a healthful, clean and stable environment”. The State governmentis required to “by law protect the State’s environment, ecology, and natural resources from
impairment in the public interest.” The Constitution prohibits nuclear, chemical, gas or
biological weapons and hazardous radioactive material being in the State. The
Constitution provides “[t]he waters, land, and other natural resources within the marine
space of the State are public property, the use of which the State Government shallregulate by law in the public interest…” Rivers and streams may be designated by law as
public property for use in the public interest. The State Government may acquire land for
public purposes without the interested parties’ consent, subject to the payment of faircompensation and good faith attempt at negotiation. Title to State land may only be
acquired by Micronesian citizens who are Kosraean by descent.
Kosrae Article VIII of the Kosrae Constitution provides that the two levels of governmentfor Kosrae are State and municipal. Municipalities are granted powers and functions inrelation to local affairs, property and government so far as they are not limited by law. The
Kosrae Constitution requires the State Government to “protect the State’s traditions as
may be required by the public interest” (Art II).

3.2.1.3

Kosrae State Development Regulation 2014
The purpose of the Kosrae State Development Regulation 2014 is to implement Title 7,
Chapter 4 of the Kosrae Code by establishing the EIA process which is intended to help
the general public and government officials make decisions “with the understanding of theenvironmental consequences of their decisions, and take actions consistent with the goalof protecting, restoring, and enhancing the environment. In addition, the regulations areintended to:Integrate the EIA process into the early planning of projects to ensure timely
consideration of environmental factors in order to avoid delays; and

Identify at an early stage the significant environmental issues requiring further
study and de-emphasize insignificant issues, thereby defining the scope of theEnvironmental Impact Statement ("EIS").”The Regulation defines a "development project" to mean the construction, alteration,
movement, fill, removal, disposal or any other modification to the land or coastal areas. A
development project can include, but is not limited to the installation, placing, or buildingof surface structures, land reclamation, navigation channels, harbors, utility lines, piers,
shopping centers, clearing land, causeways, golf courses, apartment complexes, hotels,
schools, roads, parking areas, or any other similar activity. It also defines "Earthmoving"
to mean any construction or other activity which disturbs or alters the surface of the land,
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Federated States of Micronesia PRIME & SCORE Projects
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mineral extraction, ocean disposal, and the moving, depositing or storing of soil, rock, coralor earth.
Part III sets out the Development Review Permit process which among other things,
requires the developer to conduct initial consultation with the Kosrae Island Resource
Management Authority (KIRMA) to explain the planned development and to determine if a
Development Review Permit application is necessary. KIRMA operates as a semiautonomous agency within the Kosrae State Government and consists of five units(historic, marine, terrestrial, education, and permitting) which monitors, promulgates safety
and security, and informs policy in the protection of the island’s resources.
If necessary, the proponent then submits an application for a Development Review Permit
including an EIA Checklist. The review of the application will involve a determination if an
EIS is necessary, depending on the Technical Advisory Committee’s assessment of thenature and severity of the potential impacts. A Development Review Permit will be
reviewed and granted by KIRMA.
The DRC also determines if (under Section 3.7) the proposal requires a public information
meeting “whenever it is reasonably foreseeable that a project will result in a significant
impact to the environment, DRC will ensure that all affected persons will have theopportunity to provide input, written or oral, for the project.”
The Development Review Permit process will be required for physical works funded by the
PRIME and SCORE projects with the decision being made on whether an EIA is required
following a review by the Technical Advisory Committee (TAC).

3.2.2

Pohnpei

3.2.2.1

The Legal Framework
The following laws and policies that exist in Pohnpei for managing and conserving theenvironment that may apply to the PRIME and SCORE projects:

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Constitution of the State of Pohnpei 1984 (Primary rule of law in the State ofPohnpei).

Public Trust Lands Distribution Act 1980.



Public Lands Act 1987.



Deed of Trust Act 1987.

Trust Territory Environmental Protection Act, preserved from the Trust Territory
environmental law (The Act) and subordinate regulations relate to:o

Air pollution;oPesticides;oPublic water supply systems;oMarine and freshwater quality;oSolid waste;oToilet facilities and sewerage disposal; andFinal Draft

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Earthmoving.

Transportation Zone Act 1987.



Conservation and Resource Enforcement Act 1982.



Forest Management Act 1979.

Pohnpei Watershed Forest Reserve and Mangrove Protection Act 1987.

Designation of State Bird Act.

Marine Resources Conservation Act 1981.

Pohnpei Environmental Protection Act 1992.

Pohnpei Cultural Preservation Act.

Trust Territory Environmental Quality Protection Act.

Pohnpei Constitution (1984)
Under the Pohnpei Constitution, the State Governor must establish and administer“comprehensive plans for the conservation of natural resources and the protection of theenvironment”. Article 12 states that only Ponapean citizens, who are also pwilidak ofPohnpei, may acquire a permanent interest in real property. The Constitution also prohibits
leases of more than 25 years and indefinite land-use agreements. The Government ofPohnpei may acquire land for public purposes following consultation with local government,
owners and an offer for payment of a purchase price or compensation. Article 13 of the
Pohnpei Constitution prohibits the introduction, storage, use, test and disposal of nuclear,chemical, gas and biological weapons, nuclear power plants and related waste materials
from Pohnpei.
Article 5 of the Pohnpei Constitution states “[t]his Constitution upholds, respects, andprotects the customs and traditions of the traditional kingdoms of Pohnpei” and that the
Pohnpei Government shall respect and protect customs and traditions.

3.2.2.3

Pohnpei Environmental Protection Act (1992)
Pohnpei’s Environmental Protection Act (1992) S.L. No. 3L-26-92 establishes a procedure
for preparation of an Environmental Assessment Statement (EAS) prior to any action that
may significantly affect the quality of the human environment. The degree of environmental
assessment detail for a project depends upon the significance of its potential environmental
impacts.
Significance of the action is determined by the EPA on consideration of an Initial
Assessment (with a prescribed checklist) submitted by a proponent.
The EPA receives the environmental assessment document and reviews it for compliancewith the Act and the regulations in terms of format, adequacy of information and objectivity.
The EPA authorizes commencement of a project, through a permitting process, only if it
determines that the assessment is sufficient. Once the completed assessment is presented
to the EPA Board of Directors and upon the final deliberations of the EPA Board, a permit
will be given to the project proponent with conditions for compliance of the project
proponent as required by EPA regulations.
There is a range of potentially required permits and licenses for a major development in
Pohnpei. These comprise:

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EPA Earthmoving Permit;b.

Land Ownership Documentation;c.

Forestry Clearance;d.

Marine Resources Assessment Report;e.

Municipal Government Clearance (planning approval);f.

Department of Lands Approval; andg.

Historic Preservation Clearance.

The Act requires the active assistance of all government authorities to achieve its goals.
The result, in practice, is that only the EPA Earthmoving Permit is required. This applies toprojects with significant amounts of earthworks. Its focus is the management of soil andwater conservation.
The Pohnpei EPA will require an initial assessment document which will determine whether
an EAS is required depending on the nature and scale of impacts. The EAS would be
reviewed by the EPA Board of Directors and a permit provided with conditions forcompliance with EPA regulations.

3.2.3

Chuuk

3.2.3.1

The Legal Framework
The following laws and policies that exist in Chuuk for managing and conserving theenvironment that may apply to the PRIME Project:

3.2.3.2

Constitution of the State of Chuuk 1989 (Primary rule of law in the State of Chuuk).

Memorandum of Understanding (MoU) – Solid Waste Management (MoU between
the State and National Governments delegating State power to administer, at Statelevel, the Solid Waste Management Permit Program and the Solid Waste
Management Permit Variance Program).



MoU – Earthmoving (MoU between the State and National Governments
delegating State power to administer, at State level, the National Earthmoving
Regulations).



Chuuk State Historic Preservations Act 1991 (Relating to wrecks in Chuuk lagoon).



Chuuk State Environmental Protection Act 1994.

Chuuk Constitution (1989)
Article XI of the Chuuk Constitution requires the legislature to “provide by law for thedevelopment and enforcement of standards of environmental quality, and for theestablishment of an independent state agency vested with responsibility for environmental
matters.” Article XI of the Chuuk Constitution also gives the State Government the power
to take an interest in land for public interest purposes subject to negotiations and thepayment of compensation.
Article IV of the Chuuk Constitution recognizes and protects customary law and the role oftradition leaders in Chuuk.

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3.2.3.3

Chuuk State Environmental Protection Act (1994)
The Chuuk State Environmental Protection Act (1994) creates and empowers the Chuuk
State EPA. Section 1005 defines the functions and powers of the Chuuk EPA, one of which(para f) is: “Establish and provide for the continuing administration of a permit system
whereby a permit shall be required before the discharge by any person of any pollutant in
the air, lands and water or for the conduct by any person of any activity, including but notlimited to, the operation, construction, expansion, alteration of any facilities.”
Section 1006 of the Act states that “A person shall submit an environmental impact
statement to the Agency, in accordance with regulations established by the Agency, prior
to taking any major action which may substantially affect the quality of the environment.”
In addition, further functions of the Chuuk EPA relevant to the PRIME and SCORE projects
include:

Establishment of criteria for the classification of air, land and water; andCollection of information, record keeping, monitoring, and reporting.

There are penalties for any persons who violate the Act or any permits or orders issued
under it. The Act is not clear regarding the process of applying for a permit, and theenvironmental assessment requirements to support such an application.
Notwithstanding this, given the nature and scale of the works proposed under the PRIME
and SCORE projects it is likely that an EIS would be required.

3.2.4

Yap

3.2.4.1

The Legal Framework
The following laws and policies that exist in Chuuk for managing and conserving theenvironment that may apply to the PRIME Project:

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Constitution of the State of Yap 1982 (Primary rule of law in the State of Yap).



Environmental Quality Protection Act 1987.



Draft Water Supply Systems Regulations (Based on the U.S. Trust Territory Public
Water Supply Systems Regulations).



Trust Territory Solid Waste Regulations 1979.



Draft Toilet Facilities and Sewerage Disposal Regulations.



Draft Earthmoving and Sedimentation Regulations.



Yap State Code, Chapter 10, Section 1008 (Wildlife conservation).



Yap State Code, Title 11, Section 805 (Oil spills).



Yap State Code, Title 11, Section 815 (Reef and environmental damage).



Yap State Code, Title 18, Chapter 4, Section 401 (Disposal of petroleum products).

Yap State Code, Title 18, Sections 404, 402 and 403 (Relating to oil spills).



Yap State Code, Title 18, Chapter 10, Section 1011 (Temporary protection ofmarine life).

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3.2.4.2

Yap State Code, Title 20, Chapter 3 (Building permits).

Yap Constitution (1982)
The Yap Constitution states that the “state Government may provide for the protection,conservation and sustainable development of agricultural, marine, mineral, forest, water,
land and other natural resources.” It also prohibits testing, storing, using or disposing ofradioactive and nuclear substances within the State. Land ownership and uses are
restricted under the Yap Constitution. The State recognizes traditional rights andownership of natural resources and areas within the marine space of the State up to 12
miles from island baselines.
The Yap Constitution grants due recognition to the Dalip pi Nguchol and their traditionaland customary roles, and to traditions and customs in providing a system of law (Art III).
In Yap, Traditional leaders who serve in the Council of Pilung and the Council of Tamolcarry out traditional and customary functions. Land in Yap may only be acquired in amanner consistent with traditions and customs (Art XIII).

3.2.4.3

Yap – Regulations for Environmental Impact Assessment, Title II, Chapter I. (1995)
Administered by the Yap State Environmental Protection Agency (EPA), the Regulation forEnvironmental Impact Assessment 1995 implements the Yap State Environmental Quality
Protection Act by establishing standard procedures for the preparation of an EIS to beprepared prior to any action proposed to be undertaken that may significantly affect thequality of the human or natural environment.
In addition, these regulations are designed to:a. Integrate the EIA process into early planning of projects to ensure timely
consideration of environmental factors and to avoid delays; andb. Identify at an early stage the significant environmental issues that may require
further study thereby the, scope of the EIA.
The Regulation requires that all projects require a Preliminary Environmental Impact
Statement (PEIS) (Part II; 2.1, 2.2) prior to and preferably early in the planning stages ofthe development proposal.
There are exemptions from the preparation of a PEIS for activities that “will probably haveminimal or no significant effects on the environment.” Among those exempted activities are“(1) Operations, repairs, or maintenance of existing structures, facilities, equipment, or
topographical features, involving negligible or no expansion or change of use beyond that
previously existing; (2) Interior alterations involving things such as partitions, plumbing,and electrical conveyances.”
Where the environmental impacts in the PEIS is assessed by the EPA Board to be havesevere potential impacts, the proponent is required to prepare a more detailed
environmental assessment report (Draft EIS) which will be reviewed and commented onby the EPA Board and others including the public, and these comments are send to the
Proponent for review and incorporation into the Final EIS.
A process of public consultation and review of the Draft EIS is also provided in theRegulation (Section 3.4) with all written comments to be received by EPA after a specified
period. The EPA Board makes a determination whether or not to approve the proposal,
with or without conditions, or to decline, within 30 days of submission of the finalized EIS.

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The Yap State EPA will require a PEIS which will determine whether an EAS is required
depending on the nature and scale of impacts. It is possible that the PRIME and SCORE
projects would be exempt from the requirement to prepare a PEIS if it was determined thatthe proposed activities consist of operations, repairs, or maintenance of existing structures,
facilities, equipment, or topographical features, involving negligible or no expansion orchange of use beyond that previously existing. This would need to be discussed with the
Yap State EPA. A more detailed environmental assessment report would be required if it
was determined that the Project has severe potential impacts.

3.3

International Standards and OHS Labor Guidelines

3.3.1

International Environmental Agreements
FSM is a signatory to a number of international conventions and treaties. Those potentiallyrelevant to the Project are listed below:

3.3.2



International Plant Protection Convention 1951.



World Heritage Convention 1972.



United Nations Convention on the Law of the Sea 1982.

Agreement relating to the Conduct of a Joint Program of Marine Geoscientific
Research and Mineral Resource Studies of the South Pacific Region, with
Annexes, 1982; with Related Agreement, 1984.



Vienna Convention for the Protection of the Ozone Layer 1985.

Convention for the Protection of the Natural Resources of the South Pacific Region
1986; and companion protocols 1986.

Convention on Biological Diversity (CBD) 1993.



United Nations Framework Convention on Climate Change (UNFCC) Paris
Agreement 2016.

World Bank Environmental and Social Framework
As a condition of WB financing the PRIME and SCORE Projects, DoTC&I has committed
to implementing the Project in a manner consistent with the WB Environmental and Social
Framework 2017 (ESF).
Matters to be addressed include environmental, Occupational Health and Safety (OHS),
gender, labor, social, land and cultural heritage laws and policies as a minimum. The WB
Environmental and Social Standards (ESS), as set out in the ESF, are considered to
relevant for the PRIME and SCORE projects requiring the GoFSM to prepare
environmental and social risk management instruments:

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

ESS1 – Assessment and Management of Environmental and Social Risks andImpacts.



ESS2 – Labor and Working Conditions.



ESS3 – Resource Efficiency and Pollution Prevention and Management



ESS4 – Community Health and Safety.



ESS5 – Land Acquisition, Restrictions on Land Use and Involuntary Resettlement
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

ESS6 – Biodiversity Conservation and Sustainable Management of Living Natural
Resources.



ESS7 – Indigenous Peoples/Sub-Saharan African Historically Underserved
Traditional Local Communities.



ESS8 – Cultural Heritage.



ESS10 – Stakeholder Engagement.

The project was screened as ‘Substantial’ risk at concept stage. Most Project risks arelikely to be identifiable, localized, short term or small scale, not irreversible orunprecedented, and can be addressed through conventional mitigation and management
measures. However, because project investments are expected to be in fragmented
locations being spread across four separate states and some of the roads are in close
proximity to cultural heritage sites and sensitive coastal ecosystems there is the potential
for longer term or broader scale impacts. Social risks relating to road construction andmaintenance activities include involuntary resettlement impacts, the health and safety risks
for workers and the community (noise, dust, traffic) as well as the management of imported
workforce with the associated potential increased risk of Gender-Based Violence (GBV),
Sexual Exploitation and Abuse (SEA) and Sexual Harassment (SH). Many of these may
give rise to social conflict or risks to human harm at a local scale.

3.3.3

World Bank General Environmental, Health & Safety Guidelines
The World Bank Group’s General Environmental, Health, and Safety Guidelines 2007
(EHS Guidelines) represent good international practice for managing environmental
impacts and community and Occupational Health and Safety (OHS) risks. The EHS
Guidelines contain the performance levels and measures that are generally considered tobe achievable in new facilities by existing technology at reasonable costs.

3.3.3.1

Environmental - Air Emissions and Ambient Air Quality
This guideline applies to projects that generate emissions to air and provides an approachto the management of significant sources of emissions including specific guidance forassessment and monitoring of impacts. The key potential source of air emissions
associated with the PRIME and SCORE projects are in relation to potential cement orasphalt plant or dust pollutants emissions generated from construction activities and/or
machinery usage.
Projects with significant sources of air emissions and potential for significant impacts toambient air quality should prevent or minimize impacts by ensuring that:

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Emissions do not result in pollutant concentrations that exceed relevant ambientquality guidelines and standards by applying national legislated standards, or in
their absence, the current World Health Organisation (WHO) Air Quality Guidelines(see Table 3-1); andEmissions do not contribute a significant portion to the attainment of relevant
ambient air quality guidelines or standards. As a general rule, this Guideline
suggests 25 percent of the applicable air quality standards to allow additional,
future sustainable development in the same airshed.

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Table 3-1: WHO ambient air quality guidelines (WHO 2005)

Parameter

Averaging Period

Guideline Period in µg/m324-hour

10 minute

125 (Interim target-1)
50 (Interim target-2)
20 (guideline)
500 (guideline)

Nitrogen dioxide (NO2)

1-year
1 hour40 (guideline)
200 (guideline)

Particular Matter
PM10

1-year70 (Interim target-1)
50 (Interim target-2)
30 (Interim target-3)
20 (guideline)

24-hour

150 (Interim target-1)
100 (Interim target-2)
75 (Interim target-3)
50 (guideline)

1-year35 (Interim target-1)
25 (Interim target-2)
15 (Interim target-3)
10 (guideline)

24-hour

75 (Interim target-1)
50 (Interim target-2)37.5 (Interim target-3)
25 (guideline)

8-hour daily maximum

160 (Interim target-1)
100 (guideline)

Sulfur dioxide (SO2)

Particular Matter
PM2.5

Ozone

Notes: PM 24-hour value is the 99th percentile. Interim targets are provided in recognition of the need for astaged approach to achieving the recommended guidelines.
Point sources are characterized by the release of air pollutants typically associated withthe combustion of fossil fuels such as nitrogen oxides (NOX), sulfur dioxide (SO2), carbon
monoxide (CO), and Particulate Matter (PM) as well as other air pollutants including certain
Volatile Organic Compounds (VOCs). Emissions from point sources should be avoided
and controlled according to Good International Industry Practice (GIIP) through the
combined application of process modifications and emissions controls, such as regularengine maintenance and repair, use of modern vehicle fleet with emissions control devices
such as catalytic converters and driver education programs.
Fugitive source air emissions refer to emissions that are distributed spatially over a wide
area and not confined to a specific discharge point. The most common pollutant involvedin fugitive emissions is dust or PM. This is released during certain operations such astransport and open storage of solid materials and from exposed soil surfaces including
unpaved roads. Recommended prevention and control of these emissions sources
include:

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Use of dust control methods such as covers, water suppression, or increased
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Federated States of Micronesia PRIME & SCORE Projects
Environmental and Social Management FrameworkUse of water suppression for control of loose materials on paved or unpaved roadsurfaces.

Consideration to both point source (from an asphalt or cement plants) and fugitive (e.g.
dust from stockpiles, exposed soils) will need to be given for the PRIME and SCORE
projects.
3.3.3.2

Environmental - Hazardous Materials Management
This guideline applies to projects that use, store, or handle any quantity of hazardous
materials defined as materials that represent a risk to human health, property or theenvironment due to their physical or chemical characteristics.
The guideline provides guidance in relation to both General Hazardous Materials
Management: (where hazardous materials are handled or stored) and Management ofMajor Hazards (storage or handling hazardous materials at, or above, threshold quantities
thus requiring special treatment to prevent accidents such as fire, explosions, leaks or
spills and to prepare and respond to emergencies).
The overall objective of hazardous materials management is to avoid or, when avoidanceis not feasible, minimize uncontrolled releases of hazardous materials or accidents during
handling, storage and use. This objective can be achieved by:Establishing hazardous materials management priorities based on hazard analysis
of risky operations identified through ESA;

Where practicable, avoiding or minimizing the use of hazardous materials;

Preventing uncontrolled releases of hazardous materials to the environment or
uncontrolled reactions that might result in fire or explosion;

Using engineering controls (containment, automatic alarms and shut-off systems)commensurate with the nature of hazard; andImplementing management controls (procedures, inspections, communications,training, and drills) to address residual risks that have not been prevented orcontrolled through engineering measures.

A Waste Minimization and Management Plan (WMMP) and Spill Management Plan (SMP)
are to be prepared by the Contractor which sets out strategies and actions required toreduce potential health and environmental risks associated with waste generation anddisposal, including hazardous materials (discussed further in Section 6.2.3), management
to avoid spills and other environmental releases, and identify opportunities for constructionwaste reuse.
3.3.3.3

Environmental - Waste Management
These guidelines apply to projects that generate, store, or handle any quantity of waste.
Solid (non-hazardous) wastes generally include any garbage, refuse. Hazardous waste
shares the properties of a hazardous material (e.g. ignitability, corrosivity, reactivity, or
toxicity), or other physical, chemical, or biological characteristics that may pose a potential
risk to human health or the environment if improperly managed.
Waste management should be addressed through a Waste management system that
addresses issues linked to waste minimization, generation, transport, disposal, andmonitoring.

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The PRIME and SCORE projects will generate a range of solid waste types including nonhazardous and potentially hazardous wastes including waste material generated fromremoval of existing road surfaces, bridges, causeways etc. Consideration to the
management of hazardous materials will be required for the PRIME and SCORE projects.
A WMMP is to be prepared by the Contractor which sets out strategies and actions required
to reduce potential health and environmental risks associated with waste generation anddisposal, as well as identify opportunities for material recycling or reuse (discussed further
in Section 6.2.3).
3.3.3.4

Environmental - Noise
Noise prevention and mitigation measures should be applied where there is the potential
for noise levels to exceed applicable guidelines at sensitive receptors.
The preferred method for controlling noise from stationary sources is to implement noise
control measures at source. Methods for prevention and control of sources of noise
emissions depend on the source and proximity of receptors. Noise reduction options thatshould be considered include: Selecting equipment with lower sound power levels;
mandatory mufflers on engine exhausts and compressor components; limiting hours ofoperation for specific pieces of equipment or operations, especially mobile sources
operating through community areas; Re-locating noise sources to less sensitive areas totake advantage of distance and shielding; Taking advantage of the natural topography asa noise buffer during facility design; and developing a mechanism to record and respondto complaints through the Grievance Mechanism (GM) established for the PRIME and
SCORE projects (in the projects combined SEP).
Noise impacts should not exceed the levels presented in Table 3-2, or result in a maximum
increase in background levels of 3 dB at the nearest receptor location off-site.
Table 3-2: WHO noise level guidelines (WHO, 1999).

Receptor

3.3.3.5

One Hour LAeq (dBA)
Daytime (07:00 – 22:00)

Daytime (22:00 – 07:00)

Residential; industrial; educational

55

45

Industrial; commercial

70

70Worker Health and Safety
The fundamental premise for Occupational Health and Safety (OHS) under theEnvironmental Health and Safety (EHS) Guidelines is that “Employers and supervisors are
obliged to implement all reasonable precautions to protect the health and safety of workers”
and that “Companies should hire contractors that have the technical capability to manage
the occupational health and safety issues of their employees…”.
The OHS philosophy in the EHS Guidelines is that preventive and protective measures
should be introduced according to the following order of priority:
a. Eliminating the hazard by removing the activity from the work process.
b. Controlling the hazard at its source through use of engineering controls.
c.

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Minimizing the hazard through design of safe work systems and administrative or
institutional control measures.

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Environmental and Social Management Frameworkd. Providing appropriate Personal Protective Equipment (PPE) in conjunction withtraining, use, and maintenance of the PPE.
All workers engaged in the PRIME and SCORE projects will need to be covered under theterms of the EHS Guidelines. The Contractor will be required to provide a Worker Healthand Safety (H&S) Plan that addresses key project requirements in relation to worker healthand safety. All other Project workers will work under the OH&S controls outlined in the
combined PRIME/SCORE Labor Management Procedure (LMP).
3.3.3.6

Community Health and Safety
This guidance specifically addresses some aspects of project activities taking place outsideof the traditional project boundaries but nonetheless related to the project operations.
These issues may arise at any stage of a project life cycle and can have an impact beyond
the life of the project and includes issues such as:Water Quality - Groundwater and surface water represent essential sources ofdrinking water which may be impacted by project activities involving discharges.

Traffic Safety - Prevention and control of traffic related injuries and fatalities
should include the adoption of safety measures that protect project workers androad users. Road safety initiatives proportional to the scope and nature of project
activities should include measures such as:oAdoption of best transport safety practices (e.g. emphasizing safety
aspects among drivers, improving driving skills);o

Use of speed control devices (governors) on trucks;oRegular maintenance of vehicles;o

Employing safe traffic control measures, including road signs and flag
persons to warn of dangerous conditions; andoPlanning and timing of road use for Project activities (such as delivery ofequipment or material).

Disease prevention - Health hazards typically include those relating to poor
sanitation and living conditions, sexual transmission and vector-borne infections
associated with imported labor. Communicable diseases of most concern are
Sexually-Transmitted Diseases (STDs) such as HIV/AIDS. Recommended
interventions include: Providing surveillance and active screening and treatment ofworkers; and undertaking health awareness and education initiatives.

Consideration to community health and safety will be required for the PRIME and SCORE
projects in relation to water quality, traffic safety, Sexual Exploitation and Abuse/Sexual
Harassment (SEA/SH) and disease prevention, will also be required, particularly if
imported labor is used. The PRIME Generic ESMP and works project based specific ESMP
will include controls to protect the community from road works incidents and nuisances,vehicle incidents and nuisances and harm from workers. A community Health and Safety
Plan (HSP) is to be prepared by the Contractor which sets out strategies and actions
required to prevent and/or minimize any negative health or safety impacts on thecommunity arising from the physical works (discussed further in Section 6.2.3).

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3.3.3.7

Toll Roads
The guidance document for toll roads includes information relevant to construction,
operation and maintenance of large, sealed road projects including bridges andoverpasses. Elements of this guideline document also apply to smaller scale and/or
unsealed road projects.
Issues specific to construction and operation of roads, as set out in the Toll Roads guidance
document, include the following:

3.3.3.8

Environmental issues – including habitat alteration and fragmentation,
stormwater, waste, noise, air emissions and wastewater.

Community Health and Safety issues - including pedestrian safety, traffic safety
and emergency preparedness.

Construction Materials Extraction
The construction materials extraction guidance document includes information relevant toconstruction materials extraction activities such as aggregates, sand, gravel, etc. It
addresses stand-alone projects and extraction activities supporting construction, civil
works, and cement projects.
Potential issues during the operational, construction, and decommissioning phases of
construction materials extraction primarily include the following:

3.3.4



Environmental issues – including air emissions, noise and vibrations, water,
waste and land conversion.



Occupational health and safety hazards – including respiratory hazards, noiseand physical hazards.

Community health and safety issues – including land instability, water,
explosives safety and decommissioning.

World Bank Good Practice Notes
A number of World Bank Good Practice Notes are relevant for the PRIME and SCORE
projects including:Addressing SEA/SH in Investment Project Financing involving Major Civil Works,
February 2020.



Non-Discrimination and Disability, June 2018.



ESS6: Biodiversity and Sustainable Management of Living Natural Resources,
June 2018.



Gender, October 2019.



Road Safety, October 2019.



Non-Discrimination: Sexual Orientation and Gender Identity (SOGI), October 2019.

These Good Practice Notes (GPN) have been considered in preparation of the PRIME and
SCORE instruments and will be incorporated into design, technical advisory, site specificenvironmental and social assessments, the PRIME Generic ESMP, works specific ESMPs
and Contractor Environmental and Social Management Plans (CESMP).

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3.4

Comparison of WB ESF and FSM Legislative Requirements
Table 3-3 provides an analysis of gaps between WB safeguard requirements as set out inthe ESMF and FSM Legislative requirements.

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Table 3-3: Gaps between WB ESF and FSM legislative requirements, and gap filling measures

WB Environmental and Social Standards

FSM Legislative Requirements

Equivalence and Gap
Filling

The EIA Regulations at national and state levels require an
EIA to be prepared prior to taking any “major” action
significantly effecting the quality of the human environment.
The EIA process is intended to assist understanding ofenvironmental consequences and actions required toprotect, restore, and enhance the environment.
The regulations Identify at an early stage significant
environmental issues thereby defining EIA scope.

Partial equivalence.
ESS1 and FSM nationaland state requirements
would need to be followed
for ESA and preparation of
instruments.
Where
possible,
instruments
willbeprepared to satisfy both
WB
and
FSM
requirements. In someinstances,
separate
instruments
willbeprepared (for example
where the timing or scale oftheassessment
issignificantly different).

FSM national legislation outlines worker’s rights, and theLabor Code outlines the requirements regarding hiring of
non-resident workers, labor development and otherrequirements.

Partial equivalence.
ESS2 requirements will befollowed where there aregaps in local legislation,
including preparation of the
PRIME and SCORE
Project LMP.

ESS1 – Assessment and Management of Environmental and Social Risks and Impacts
To identify, evaluate and manage the environment and social risks and impacts of the project in a mannerconsistent with the ESSs.
To adopt a mitigation hierarchy approach to:(a) Anticipate and avoid risks and impacts;(b) Where avoidance is not possible, minimize or reduce risks and impacts to acceptable levels;(c) Once risks and impacts have been minimized or reduced, mitigate; and(d) Where significant residual impacts remain, compensate for or offset them, where technically andfinancially feasible.
To adopt differentiated measures so that adverse impacts do not fall disproportionately on the disadvantaged
or vulnerable, and they are not disadvantaged in sharing development benefits and opportunities resulting
from the project.
To utilize national environmental and social institutions, systems, laws, regulations and procedures in theassessment, development and implementation of projects, whenever appropriate.
To promote improved environmental and social performance, in ways which recognize and enhance Borrower
capacity.
ESS2 – Labor and Working Conditions
To promote safety and health at work.
To promote the fair treatment, non-discrimination and equal opportunity of project workers.
To protect project workers, including vulnerable workers such as women, persons with disabilities, children(of working age, in accordance with this ESS) and migrant workers, contracted workers, community workers
and primary supply workers, as appropriate.
To prevent the use of all forms of forced labor and child labor.
To support the principles of freedom of association and collective bargaining of project workers in a mannerconsistent with national law.
To provide project workers with accessible means to raise workplace concerns.

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WB Environmental and Social Standards

FSM Legislative Requirements

Equivalence and Gap
Filling

The EIA Regulations at national and state levels require an
EIA and permitting process to assist with understanding ofenvironmental consequences and actions required toprotect, restore, and enhance the environment, as well assourcing raw aggregate material required, and disposal ofwaste.

Partial equivalence.
ESS3 requirements will befollowed where there aregaps in local legislation.

No specific health and safety regulations or policies relating
to community well-being.

ESS4 requirements will befollowed where there aregaps in local legislation.

FSM’s legislation:

Partial equivalence.
ESS5 requirements will befollowed where there aregaps in local legislation,
including preparation of the
PRIME and SCORE
Projects RF.

ESS3 – Resource Efficiency and Pollution Prevention and Management
To promote the sustainable use of resources, including energy, water and raw materials.
To avoid or minimize adverse impacts on human health and the environment by avoiding or minimizing
pollution from project activities.
To avoid or minimize project-related emissions of short and long-lived climate pollutants.
To avoid or minimize generation of hazardous and non-hazardous waste.
To minimize and manage the risks and impacts associated with pesticide use.
ESS4 – Community Health and Safety
To anticipate and avoid adverse impacts on the health and safety of project-affected communities during the
project life cycle from both routine and nonroutine circumstances.
To promote quality and safety, and considerations relating to climate change, in the design and constructionof infrastructure, including dams.
To avoid or minimize community exposure to project related traffic and road safety risks, diseases andhazardous materials.
To have in place effective measures to address emergency events.
To ensure that the safeguarding of personnel and property is carried out in a manner that avoids or minimizes
risks to the project affected communities.
ESS5 – Land Acquisition, Restrictions on Land Use and Involuntary Resettlement
Involuntary resettlement should be avoided where feasible, or minimized, exploring all viable
alternative designs.
Where it is not feasible to avoid resettlement, resettlement activities should be conceived andexecuted as sustainable development programs, providing sufficient investment resources toenable the persons displaced by the end of the project to share in the project benefits.
Displaced persons should be meaningfully consulted and should have opportunities to participate
in planning and implementing resettlement programs.

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

Encourages the avoidance of adverse
environmental and social impacts and their effective
mitigation where avoidance is not possible.



Requires negotiations with affected land owners, onvalues of land, and resettlement assistance.

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WB Environmental and Social Standards

FSM Legislative Requirements


Avoiding hardship on displaced land owners is
explicitly provided for but more for legal landowners,
and legal occupiers, not for illegal occupiers andtheir assets / livelihoods.



Requires that Displaced Persons are compensated for all losses, including non-land assets, at full
replacement cost.

Requires negotiations with affected land owners, onvalues of land, and resettlement assistance.

Bank expects the borrower to take into account the views, roles, and rights of groups including NonGovernment Organizations (NGO’s), Community Based Organizations (CBO’s) and local
communities affected by the Bank financed project in the planning, designing, implementing,monitoring and evaluating of such projects.

Limits compensation imposed on how muchcompensation is paid for lost income from businessor farm operation.

Provides for public consultation as part of theenvironmental assessment process and full
disclosure of EIA reports to the public.

Bank requires that Displaced People (DP) should be meaningfully consulted and should haveopportunities to participate in planning and implementing resettlement programs. Bank also requiresthat displaced persons should be assisted in their efforts to improve their livelihoods and standardsof living or at least to restore them, in real terms, to pre-displacement levels or to levels prevailing
prior to the beginning of project implementation, whichever is higher.

Is explicit on dealing with displaced people.



Recognizes the heritage, traditional boundaries andcultural ties to the islands.

To address the impacts resulting from Bank-assisted investment projects, the borrower prepares a
resettlement plan or resettlement policy framework.
It is necessary to improve or at least restore livelihoods of Displaced Persons (DP) by a range ofstrategies targeted at Affected People (AP). Nobody is to be made worse off as a result of thedevelopment project.

Equivalence and Gap
Filling

Bank requires: i) Screening to identify whether Indigenous Peoples are present, ii) Social
assessment to assess potential adverse impacts, iii) Consultation and participation, iv) preparationof an Indigenous Peoples Plan (if required), and v) Public Disclosure.

ESS6 – Biodiversity Conservation and Sustainable Management of Living Natural Resources
To protect and conserve biodiversity and habitats.
To apply the mitigation hierarchy and the pre-cautionary approach in the design and implementation ofprojects that could have an impact on biodiversity.
To promote the sustainable management of living natural resources.

The Environment Protection Act provides for the protectionof the environment, culture, historic and natural aspects ofMicronesian heritage.
The EIA Regulations at national and state level requires
actions that protect, restore, and enhance the environment.

Partial equivalence.
ESS6 requirements will befollowed where there aregaps in local legislation.

To support livelihoods of local communities including Indigenous Peoples, and inclusive economic
development, through the adoption of practices that integrate conservation needs and development priorities.
ESS7 – Indigenous Peoples

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WB Environmental and Social Standards

FSM Legislative Requirements

Equivalence and Gap
Filling

To ensure that the development process fosters full respect for the human rights, dignity, aspirations, identity,
culture, and natural resource-based livelihoods of Indigenous Peoples/Sub-Saharan African Historically
Underserved Traditional Local Communities.

The Environment Protection Act provides for the protectionof the environment, culture, historic and natural aspects ofMicronesian heritage.
FSM law recognizes the heritage, traditional boundaries
and cultural ties to the islands.

Partial equivalence.
ESS7 requirements will befollowed where there aregaps in local legislation.
Provisions have been
included in the PRIME and
SCORE Projects SEP tocomply with ESS7.

FSM National and State law including the Environment
Protection Act recognizes the heritage, traditionalboundaries and cultural ties to the islands.

Partial equivalence.
ESS8 requirements will befollowed where there aregaps in local legislation.
Provisions have been
included in this ESMF toaddress potential risks andimpacts and comply withESS8.

The EIA Regulations at national and state level involves aprocess which is intended to help the general public andPartial equivalence.

To avoid adverse impacts of projects on Indigenous Peoples/ Historically Underserved Traditional Local
Communities, or when avoidance is not possible, to minimize, mitigate and/or compensate for such impacts.
To promote sustainable development benefits and opportunities for Indigenous Peoples/Historically
Underserved Traditional Local Communities in a manner that is accessible, culturally appropriate andinclusive.
To improve project design and promote local support by establishing and maintaining an ongoing relationshipbased on meaningful consultation with the Indigenous Peoples/ Historically Underserved Traditional Local
Communities affected by a project throughout the project’s life cycle.
To obtain the Free, Prior, and Informed Con-sent (FPIC)3 of affected Indigenous Peoples/ Historically
Underserved Traditional Local Communities in the three circumstances described in this ESS.
To recognize, respect and preserve the culture, knowledge, and practices of Indigenous Peoples/Historically
Under-served Traditional Local Communities, and to provide them with an opportunity to adapt to changing
conditions in a manner and in a time-frame acceptable to them.
ESS8 – Cultural Heritage
To protect cultural heritage from the adverse impacts of project activities and support its preservation.
To address cultural heritage as an integral aspect of sustainable development.
To promote meaningful consultation with stake-holders regarding cultural heritage.
To promote the equitable sharing of benefits from the use of cultural heritage.

ESS10 – Stakeholder Engagement and Information Disclosure.
To establish a systematic approach to stake-holder engagement that will help Borrowers identify stakeholders
and build and maintain a constructive relationship with them, in particular project-affected parties.

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WB Environmental and Social Standards

FSM Legislative Requirements

Equivalence and Gap
Filling

To assess the level of stakeholder interest and support for the project and to enable stake-holders’ views to
be taken into account in project design and environmental and social performance.

government officials make decisions with theunderstanding of the environmental consequences of
their decisions.

ESS10 requirements will
be followed where there
are gaps in local
legislation.
Provisions have been
included in the PRIME and
SCORE Projects SEP tocomply with ESS10, andnational legislation on
public consultation, project
information disclosure andgrievance mechanisms.

To promote and provide means for effective and inclusive engagement with project-affected parties
throughout the project life cycle on issues that could potentially affect them.
To ensure that appropriate project information on environmental and social risks and impacts is disclosed to
stakeholders in a timely, understandable, accessible and appropriate manner and format.
To provide project-affected parties with accessible and inclusive means to raise issues and grievances, andallow Borrowers to respond to and manage such grievances.

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4.

Existing Environment

4.1

Introduction
This section provides a summary of the information provided in the Baseline Resource
Report (Appendix A) on the physical, biological and socio-economic elements of theenvironment.

4.2

Project Area of Influence
The initial description of the Project’s Area of Influence (AOI) is based on the definition
provided in the Guidance Note to ESS1, to which the Project is to comply. Specifically, this
Guidance note states that:“….Where the project involves specifically identified physical elements, aspects, andfacilities that are likely to generate impacts, the collection and analysis of environmental
and social baseline information and data, at an appropriate level of detail for the project,
are essential to define the project’s area of influence and describe relevant physical,
biological, ecological, socioeconomic, health, and labor conditions, including any changes
anticipated to occur in the foreseeable future (including projected variability in climatic andenvironmental conditions due to potentially significant climate change or that would require
adaptation measures that could occur over the life of the project), along with current andproposed development activities within the general project area but not directly connectedto the project to be financed…..”
The area considered for assessment of baseline conditions (the Project “Area of Influence”
or “AOI”) consists of the:Road corridor adjacent to the ‘PRIME and SCORE Roads’ (and works where it is abridge, causeway, etc.) and immediate adjacent environment either side of the roadalignment (see Figure 2-2 to Figure 2-5);

Road users as well as communities, sensitive receptors and sites of cultural/heritage
significance connected to and adjacent to the PRIME and SCORE roads;

Any temporary structures (such as bridges, causeway replacement structure, etc);

Receiving environment downstream (and upstream when considering fish passage)
if the works are a bridge (or causeway) or works are related to drainage, culverts
etc.;



Contractors yards, lay down or stockpile areas and any other works related facilities;and

Quarry locations and immediate surrounds.

Table 4-1 outlines the guidelines that have been followed to determine the AOI for the
PRIME and SCORE Projects which is based on a precautionary approach. All PRIME and
SCORE project data was obtained by desktop study and field survey conducted between
July and October 2020 and October 2021, respectively.

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Table 4-1: Project Area of Influence (AOI) delineations and conditions

Environment

Project AOILocal villages / communities
businesses.
Sites of cultural/heritage
significance

Adjacent to PRIME and SCORE Road alignments and works locations.
Connected to and adjacent to the PRIME and SCORE Road network.

Road users (motorists, cyclists,
pedestrians and other modes oftransport).

Users of the road that may have access or transportation restrictions fromthe works if they are not adequately managed.
Users that will benefit from improved infrastructure.

Important species and ecologicalhabitat.

Sensitive ecological areas in close proximity to the PRIME and SCORE
Road alignments and works locations potentially receiving runoff during
construction / operation.

Streams & inshore waters(adjacent to coastline).

Assuming a precautionary approach, an area directly adjacent to the
PRIME and SCORE Road alignments and works locations potentially
receiving stormwater runoff during construction / operation.

The AOI extent considered in the ESMF is broader than the area in which possible physicalworks/interventions will occur as Component 2 works for both PRIME and SCORE projects
will only be undertaken along small discrete sections of the ‘primary and secondary roads’
identified a part of the ‘PRIME and SCORE Roads’. However, all road users that rely on
the road networks for work, education, markets, community and social connectivity will
potentially be affected by, and benefit from both Projects.
The broader AOI has been applied for the E&S baseline, impact and risk assessment for
the ESMF in order to ensure the process captures anticipated impacts.
Any site-specific environmental and social assessment to be prepared, if required, are todefine the AOI specifically for those works, based on the works footprint including all
ancillary components and potential impacts on environmental, economic and social
receptors.

4.3

General Baseline Description
This Section of the report summaries the key physical, environmental, and socio-economic
resources present nationally and at a state level potentially within the AOI from primary(i.e., field assessment) and secondary (e.g., reference material, GIS data, site
investigations) sources. The E&S Baseline Resources Report which provides moredetailed on the secondary source information is provided in Appendix A. This information
has been used to screen the environmental and social risks associated with the PRIME
and SCORE Projects (see Section 5.87).

4.3.1

National

4.3.1.1

Biological Resources
FSM consists of two ecoregions (Wortel et. al. 2003). The Yap tropical dry forest ecoregionis characterized by a monsoon-like climate with rainy seasons followed by periods ofdrought. The dominant vegetation types are mixed broadleaf forest, swamp, mangrove,savanna, and agroforests (Falanruw et. Al., 1987). The other States share the Caroline’s
tropical moist forest ecoregion characterized by heavy rainfall. Mixed broadleaf forests
comprise the dominant vegetation type on the high volcanic islands. FSM is characterized

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by 12 terrestrial biomes and 6 marine biomes. Biodiversity is characterized by a high rateof endemism and large numbers of species.
FSM coastline is about 3,300 nautical miles (6,100 km) with an estimated 14,517 km2 ofreefs and wide range of different habitat types. Areas of mangrove and seagrass beds,
consisting of a number of species and considered important sensitive habitat, are foundthroughout FSM.
The EEZ has resident and transient or migratory populations of cetaceans (whales anddolphins) with a total of nine species have been recorded. Of these species, blue whale(Balaenoptera musculus) is considered ‘Endangered’ and sperm whale (Physeter
macrocephalus) is considered ‘Vulnerable’. The green turtle (Chelonia mydas) is‘Endangered’) and hawksbill turtle Eretmochelys imbricata is ‘Critically Endangered’ andare the most commonly observed (IUCN 2020).
In terms of Conservation areas, 130 Areas of Biodiversity Significance (ABS) have been
identified in FSM (TNC 2003). The combined sites encompass 291,753 hectares (ha) or
19% of the FSM's entire terrestrial and inshore area (including reefs and lagoon areas). In
addition, each state has a number of protected managed areas.
4.3.1.2

Governance, Economy, Poverty and Gender
All States have an effective traditional system of governance which complements thenewer systems of government supported by non-government agencies (Raynor & Kostka
2003). Customary marine tenure gives resource owners jurisdiction and responsibility formarine resource use. Management of land, waters and all natural resources is through thetraditional leadership system.
Ownership of land and aquatic areas varies between States. In Kosrae and Pohnpei, landis both privately and State owned, while aquatic areas are managed by the State as publictrusts. In Chuuk, most land and aquatic areas are privately owned and acquired throughinheritance, gift or, recently, by purchase. In Yap, almost all land and aquatic areas(shoreline to the outer reefs) are owned or managed by individual estates and usage issubject to traditional control (FSM, 2010).
FSM cash economy primarily depends on the flow of funds from the United States ofAmerica (OEC, 2017).
FSM receives Compact of Free Association funds andsupplementary grants from the United States which provides for US economic assistance,
defense of the FSM and other benefits in exchange for US defense and certain otheroperating rights in the FSM. Economic activities consist primarily of subsistence farming
and fishing. The economy has languished over the last decade and real Gross Domestic
Product (GDP) growth has averaged -0.4% resulting in declining living standards andcontributed to net outward migration (FSM DoTC&I, 2015). The economy is firmly tied tooverseas aid which is significant relative to domestic revenue at the State level and isdominated by funding from the Compact agreement.
FSM is at an early stage of the process of urbanization with about 22% of its population
living in the urban areas (2010 FSM Census). Agricultural and livestock raising activities
and fishing activities are almost universal among FSM households.
Heads of households are primarily male with 53% of heads aged 40 to 59 years old (FSM,2014). The annual average income in FSM was estimated to be USD 16,950. However,
20% of the households earned less than US$ 2,600 and approximately 37% of household
heads earned less than USD 5,000 with the majority of household heads earning between

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USD 5,000–29,000. The most common source of income for households is home
production (mainly agriculture items) with 76% of the households involved in some form ofsubsistence activity.
A labor force comprised of 37,919 people represents a national labor force participation
rate of 57.3% (2010 FSM census). Of this group, 31,789 people are employed while 6,130
are unemployed equating to an unemployment rate of 16.2%. For those that are employedover half are involved in education (24.6%), public administration and defense (18.6%),
wholesale/retail trade and motor vehicle repair (9.7%) and health and social work (9.1%).
Approximately 22.4% of households or 29.9% of the population (SPC, 2005) are living
below the minimum cost of living or the Basic Needs Poverty Line (BNPL). Chuuk, Pohnpei
and Yap have experienced an increase in the poverty incidence while Kosrae had adecline. Poverty also has a gender bias; while female-headed households constituted 20%of the household population in FSM, they constituted 39% of the total number ofhouseholds in the lower three expenditure deciles (ADB, 2004).

4.3.2

Kosrae4.3.2.1

Physical Environment
Kosrae has a total area of approximately 112 km2. The steep mountainous interior iscovered with tropical rainforest. Around much of the island there are continuous mangroveswamp forests and seaward coastal strands. The island is surrounded by a broad shallow
carbonate platform much of which is covered by freshwater swamps, mangrove forestsand low coral land and beach strand (US Army Engineers, 1989). In the nearshore coastal
environment, seagrass beds sensitive to development are present in some locations andfurther offshore, coral reef habitat.
Soils are typically brownish red in color, mostly fine granular clay depending on the bedrockand can be deep in places (Takesy, 2014). The most erodible soils are typically confinedto the interior where steeper slopes predominate. The island has several significant rivers
and other smaller perennial and intermittent streams and springs. Groundwater is notconsidered to be an important water source.
A number of areas (including Lelu, Malem, Utwe and Tafunsak) have been identified where
coastal change-related impacts are likely to be most significant either due to ongoing
movement of the shoreline and/or the proximity of key infrastructure to the shoreline suchas roads (Ramsay & Douglas 2000).

4.3.2.2

Ecological Environment
Terrestrial Ecology
There are over 322 plant species in Kosrae of which 250 species are native, many of which
are endemic to one or more islands in the FSM (Falanruw, 2002). Key vegetation types
are shown in Figure 4-1.

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Figure 4-1: Location of key terrestrial habitat classes in Kosrae (from Weeks, 2019)

Those located in close proximity to the coastal road include:Freshwater marsh and riverine systems with grasses, sedges and herbs growing instanding water most of the year and generally located in areas slightly above sea
level and are often just inland of mangroves.



Swamp forests occur where soils are inundated with fresh or slightly saline water.
They are most commonly found just inland of mangroves, above tidal influence but
lower in elevation than the surrounding terrain.

Mangrove forests.



Agroforest including palm trees, a component of forests, which occur in dense stands
especially in areas where the primary forest has been disturbed.

Three species are identified as IUCN listed threatened (one ‘Endangered’ and two‘Vulnerable’) and one ‘near threatened’ (NT) flora species. Kosrae has six endemic bird
species two of which are now extinct. Two restricted-range bird species including the‘Critically Endangered’ migratory species Beck's petrel Pseudobulweria becki and theMicronesian Imperial-pigeon Ducula oceanica, which is considered ‘Near Threatened’ arealso present. Other rare, regionally significant or protected fauna species include twoendemic species of bats, three threatened reptiles and two ‘Endangered’ freshwater fish
species.
Coastal Marine Ecology
Kosrae is surrounded by a broad shallow carbonate platform much of which is covered by
freshwater swamps, mangrove forest and low coral land and beach strand. The carbonate
platform is of recent reef origin and extends between 1 – 5 km out from the islands volcanic

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shoreline boundary. Three lagoons or embayment’s bisect the reef platform, the largest ofwhich is Lelu Harbor off the east coast.
Coastal marine habitat sensitive to development activities is present around Kosrae.
Figure 4-2 presents a map showing the distribution of key coastal habitat classes in Kosrae(from Weeks, 2019).
Mangrove and lowland swamp forest occupy relatively large areas between the basaltic
uplands and seaward beach strand areas - 1,562 ha of mangrove forest represents 14%of the total land area (Cole et al 1999). Mangrove forest is most extensive along the south
and north-west coasts (and in Tofol Harbor) while lowland swamp forest occurs in several
discrete locations.
Sea grass beds are present on fringing reef flats primarily along the north and west coasts
and consist primarily of four species (Cymodea rotundata, Enhalus acoroides, Thalassia
hamprichii and Holdule uninervis).
Outer reef slopes and terraces beyond the spur and groove formations are characterizedby coral reef habitat with high diversity and species abundance. Several species of giant
clam that once proliferated across these reefs are now under threat due to the high levelsof exploitation.
Kosrae has 8 Protected Managed Areas (PMA) and 12 Areas of Biological Significance(Figure 4-4) including two terrestrial, one marine, five coastal marine and two coastal
freshwater ecosystems totaling 8,261 ha.
The primary and secondary roads considered under the Projects do not pass through anyof the ‘existing’ protected areas, although four ‘proposed’ protected areas do intersectthese roads Figure 4-3).

Figure 4-2: Location of key terrestrial habitat classes in Kosrae (from Weeks 2019)

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Figure 4-3: Existing and proposed protected areas (from TNC, 2019)

Figure 4-4: Areas of Biological Significance in Kosrae (from TNC, 2019)

4.3.2.3

Social-Economic Environment
Kosrae’s economy depends significantly on financial support from the United States,
provided by the Compact Agreement with FSM. Consequentially, public sector dominates
the economy; the primary employer is the State through its ten departments.
Kosrae’s GDP was estimated at USD$14.6m in 2015 (FSM DoTC&I 2015). Major
economic sectors in the State of Kosrae are marine resources, tourism, agriculture andsmall scale businesses. The private sector provides employment through retail outlets,
restaurants, resorts, farming and some service businesses. Employee earnings in 2015
was US$1.822m (private sector) and US$17.051m (State Government). The subsistence
economy is based on small-scale horticulture and fishing.

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Kosrae has a total population of 6,616 (FSM 2010 census) with an average annual growthrate of -0.40%, the greatest rate of change of all FSM States, reflecting a declining
economy and an interstate (to Pohnpei) or international population movement.
In terms of public infrastructure, piped water systems from rivers for potable water serve 7
areas in Kosrae (SPREP, 2019). The Lelu sewerage system provides small bore sewers
which receive effluent from household septic tanks. The Tofol sewerage system collects
sewage from Government buildings and provides oxidation ponds treatment.
The solid waste facilities in Kosrae consist of five dumpsites and an aluminum cancompaction and storage facility. Kosrae has 20 permitted privately-owned quarry sites.
Only the Quarry at Tenwak (locally-known as Puk Quarry) has a rock crushing machineand sorter. No data is available on the quality or quantity of material potentially available
for roading projects.
Figure 4-5 shows the location of key sensitive social receptors (such as key villages,
churches, schools, hospitals) along the PRIME road extent on Kosrae, as well as assets
identified during a road corridor survey (including private dwellings, commercial buildings,
grave sites). Examples of these assets are shown in Figure 4-6.

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Figure 4-5: Key assets identified during the road corridor inspection – Kosrae

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Figure 4-6: Images showing examples of PRIME and SCORE key assets located in close proximity
to the road on Kosrae.

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4.3.3

Pohnpei

4.3.3.1

Physical Environment
Pohnpei is a high volcanic island with a mountainous interior, is about 21 km in diameterand 112 km in circumference. Including lagoon islands, the total land area of Pohnpei isapproximately 340 km2.
In terms of Flooding and Erosion hazard areas the majority of the low-lying coastal margin
is considered at risk of flooding and the majority of ‘very high’ to ‘high’ potential erosion
hazard areas are located in the stepper areas poorer quality soils of the interior occasional
extending towards the coastal margin.

4.3.3.2

Ecological Environment
Key terrestrial habitat sensitive to development disturbance as a proportion of total area
ranges includes Mangrove forest (15.6%), Swamp forest (0.6%), Upland forest (35.4%)
and Marsh (0.4%). A total of 729 species plants have been described with approximately
438 species being native. A total of 291 introduced plant species are present. A range of
avian, mammalian, reptilian species are present including 73 bird species. A number ofmammals (including bats), reptiles (skinks, geckos, snakes), amphibians and freshwater
fish are also likely to be present.
The key reef type in close proximity to the coast is described as “reticulated fringing reef
defined as a network of linear or polygonal reef framework with intervening depressions”.
Approximately 4,403.6 ha of predominately intertidal and shallow (<3 m) subtidal seagrassmeadow are present the waters around Pohnpei Island of varying levels of coverage(continuous, aggregated, and isolated).
A total of existing (12 areas) and proposed (12 areas) protected areas in Pohnpei and 35
Areas of Biodiversity Significance (ABS) have been identified for Pohnpei including
terrestrial (9), marine (5), coastal marine (18) and coastal freshwater sites (3).

4.3.3.3

Social-Economic Environment
Economic activity consists largely of subsistence farming and fishing and government
activity which employs two-thirds of the adult working population and receives fundinglargely - 58% in 2013 – from US Compact of Free Association assistance. Pohnpei had
been the fastest growing with GDP growth averaging 2% per annum in the FY1987-FY2003
period (FSM Strategic Development Plan, 2003). In the early period FY1987-FY1995 of
the Compact, a strong rate of growth 5.4% was experienced. Private and public sector
expanded attaining 9.0% and 2.3% growth respectively.
The mainstay of the economy is subsistence farming and fishing. There is limited tourism
due to a lack of access and facilities although it has increased in recent years with small
hotels opening.
Land is both privately and State owned while aquatic areas are managed by the State as
public trusts. The Constitution requires the Government of Pohnpei to protect customs
and traditions and allows statutes to be enacted to uphold custom.
A total of 29 bridges and causeways have been identified around Pohnpei associated withthe primary road network. Piped water systems from Nanpil River and wells serve a total
population of 2,500 in Kolonia and Palikir. The Kolonia Central Sewerage System, which
consists of about 12 miles of sewers has about 1,200 connections.

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Pohnpei has 45 coral sand dredge sites (33 inactive and 12 active) and two rock quarries.
They all have permits from EPA and are mainly for road maintenance and construction.
One of the hard rock quarries is located at Ipwal Sokes and is owned and operated by acompany called APSCO.
Figure 4-7 shows the location of key sensitive social receptors (such as key villages,
churches, schools, hospitals) along the PRIME road extent on Pohnpei, as well as assets
identified during a road corridor survey (including private dwellings, commercial buildings,
a seawall and a pipeline). Examples of these assets are shown in Figure 4-8.
Nan Madol, a significant archaeological site on the southeastern shoreline of Pohnpei thathas been declared a United Nations Educational, Scientific and Cultural Organization(UNESCO) World Heritage Site. It is the ruin of a megalithic civilization composed of 92
small to large artificial islets built on a coastal inshore reef flat. The islets are scatteredover an area larger than 105 ha and are separated by narrow channels and enclosed byan outer seawall. Archaeological studies have suggested construction of the islets beganaround 500 AD and the Saudeeur Dynasty of Chiefs expanded on its initial construction
until about 1200 AD.
Nan Madol cultural heritage sites is located on a separate island to the mainland, isaccessed by a low causeway across an intertidal reef flat that is directly connected to a
strategic secondary road that exists the primary road network of Pohnpei and passes
through a rural residential area that includes a former secondary school (Pohnpei
Agricultural and Trade School -PATS.

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Figure 4-7: Key assets identified during a road corridor inspection – Pohnpei

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Figure 4-8: Images showing examples of PRIME and SCORE assets located in close proximity to theroad on Pohnpei.

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4.3.4

Chuuk

4.3.4.1

Physical Environment
Weno Island is of volcanic origin consisting of olivine-basalt with minor andesite, with steep
rugged uplands surrounded by coastal lowlands. Weno is drained by a number of streams
most of them short with small catchment areas. The compacted volcanic material results
in a shallow (unconfined) groundwater lens. Key areas considered to be of high coastal
instability are primarily located along the northern (including Pou Bay) and south-eastern
coastlines.

4.3.4.2

Ecological Environment
Key terrestrial habitat sensitive to development disturbance as a proportion of total area
includes mangrove (7%), upland forest (16.2%) and marsh (5.6%). A total of 470 species
have been described of which approximately 298 species are native. A total of 172 speciesof plants have been introduced. A range of avian, mammalian, reptilian species arepresent including 73 species of bird and number of mammals (including bats), reptiles(skinks, geckos, snakes), amphibians and freshwater fish are likely present.
Weno Island has several designated protected / managed areas. In addition, 50 Areas of
Biodiversity Significance (ABS) have been identified including terrestrial (9), marine (10),coastal marine (20) and coastal freshwater sites (11) throughout Chuuk. The key ABS
sites on Weno in close proximity to the primary and secondary road network are Pou Bay
and the North Weno Marine ABS (refer E&S Baseline Resources Report, Appendix A).

4.3.4.3

Social-Economic Environment
In 2010, Chuuk experienced 3% GDP growth with an increase in spending from both public
and private sectors (Arnold, 2016). Chuuk’s economy grew at 1% experiencing public
sector expansion of 4.4% and the numbers of hours worked by civil servants increased. In
subsequent years, Chuuk has experienced very little growth. Analysts have forecast thedecrease in compact funding ($1.7 million) will hinder government spending with little
private sector growth. In 2011, the unemployment rate in Chuuk was 28%
The Chuuk Public Utility Corporation (CPUC) operates the public water supply serving 378
residential customers (around 19% of total households) and 101 commercial andgovernment customers. The Weno sewerage network, the only centralized sewer system,
is located on the north and north-western side of Weno Island. The sewerage network has
384 residential households and 106 commercial and government customers. Sewage istreated at the Weno Wastewater Treatment Plant which is located next to the Weno airport.
Solid waste facilities on Weno consist of the Fanipat dumpsite and the Weno Recycling
Facility (Johnston, 2011). There are three basalt quarries located on Weno two of whichhave not been in operation since the 1990s. One of the sites has equipment and is still in
operation but output is extremely limited (see Figure 4-9). There is also a basalt Quarry on
the neighboring lagoon island of Tonoas.
Figure 4-9 shows the location of key sensitive social receptors (such as key villages,
churches, schools, hospitals) along the PRIME road extent on Chuuk, as well as assets
identified during a road corridor survey (including private dwellings, commercial buildings,
and fruit trees). Examples of these assets are shown in Figure 4-10.

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Figure 4-9: Key assets identified during a road corridor inspection - Chuuk

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Figure 4-10: Images of Chuuk showing examples of PRIME and SCORE assets identified during theroad corridor on Chuuk inspection.

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4.3.5

Yap

4.3.5.1

Physical Environment
Yap Islands comprise an island arc system composed of continental crust and consist of
two distinct sequences: ancient weathered volcanic rock and weathered metamorphic
schists, accompanied by coral sand and mangrove mud. The islands are surrounded by abroad fringing barrier reef and has a low undulating topography. There are four main soil
types on the Yap Islands have been derived from the basement rocks.
The primary freshwater source on Yap proper is surface water. There are no perennial
streams on Yap where most streams will be dry during part of the dry season. A proportionof the surface water percolates into the soils recharging groundwater, which eventuallyescapes as small springs or seeps directly into the ocean. However, given the bedrock on
Yap is metamorphic and volcanic, it yields little groundwater for use.

4.3.5.2

Ecological Environment
The major land class/habitat types are: non-forest (28%), agroforest (26%) and secondary
vegetation (6%). The vegetation of Yap has been greatly modified; other than mangroves,little native forest remains. There are four threated (one ‘Endangered’ and three‘Vulnerable’) and one “Near Threatened’ (NT) floral species in Yap. All of the threatened
species are trees. Yap contains four endemic bird species: the Yap cicadabird (Edolisoma
nesiotis) is considered to be ‘Endangered’ and the other three are ‘Near Threatened’.
There are 8 protected marine areas and currently no legally protected terrestrial areas. A
total of 32 Areas of Biodiversity Significance (ABS) are located in Yap State including fiveterrestrial, six marine and 21 coastal marine ecosystems, at least seven of which are inclose proximity to the primary road network (refer E&S Baseline Resources Report,
Appendix A).

4.3.5.3

Social-Economic Environment
The Yap State economy is firmly dependent on funding from the USA, which provides about
75% of revenue. The Yap state economy achieved the highest rate of economic growth of
the FSM states during the original Compact period. Growth of the private sector was themost impressive achieving an annual average of 5.8% across 17 years. Economic
performance during the last 4 years of the Compact were disappointing reflecting theinability of the private sector to sustain growth, prudential fiscal policies and poor resultsof the state owned commercial purse seine fishing company (FSM, 2003).
Almost all land and aquatic areas are owned or managed by individual estates and usage
is subject to traditional control (FSM, 2010). The distribution of Yap’s population varies
considerably between rural (10,537 people) and urban (840) areas, with the population in
Piped water systems from Gitam Reservoir and wells serve the population of 3,150 inColonia. The sewerage system has about 700 connections. A disused quarry site is
located on the northern side of the western end of the existing Airport runway in Kanif. The
only solid waste management facility is the Fitkabeetinaem landfill.
Figure 4-11 shows the location of key sensitive social receptors (such as key villages,
churches, schools, hospitals) along the PRIME road extent on Yap, as well as assets
identified during a road corridor survey (including private dwellings, commercial buildings,
and fruit trees). Examples of these assets are shown in

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Figure 4-12).

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Figure 4-11: Key assets identified during a road corridor inspection - Yap

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Figure 4-12: Images showing examples of PRIME and SCORE key assets located in close proximity
to the road on Yap.

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4.4

Indigeneity in FSM
Micronesians represent the overwhelming majority in FSM, with recent estimates putting themat 91% of the population. With the vast geographical expanse of the country, there is huge
cultural and linguistic diversity amongst the islands comprising the four states. While English
is the official language of FSM, there are eight major indigenous languages of the MalayoPolynesian linguistic family spoken in the FSM: Yapese, Ulithian, Woleaians, Chuukese,
Pohnpeians, Kosraeans, Nukuoro, Kapingamarangi. Each State includes the indigenous
languages as official languages. English has become the common language of thegovernment, and for secondary and tertiary education. Outside of the main capital towns of
the four FSM states, the local languages are primarily spoken.
There are distinct cultural identities between the four states with unique culturalcharacteristics. However, cultural similarities are indicated by the importance of traditional
extended family and clan systems found on each island as well as a common national identity.
Traditional leadership continues to play an important role in Micronesian society on mostislands (with the exception of Kosrae). Over the recent two decades, Pohnpei has rapidly
developed as the most westernized state in the nation. This results due to the location of thenational government. Yap continues as the most traditional society in the FSM with a strong
caste system.
The individual States have separate and distinct land tenure arrangements, with some broadcommonalities that persist throughout State land tenure systems. The FSM Constitution
forbids land ownership to foreigners as well as to domestic corporations that have non-FSM
citizens among their shareholders. Group and communal ownership of land is prevalentthroughout the FSM. There are differences, however, concerning rights of land transfer within
the FSM. In Chuuk, Kosrae and Yap, land can be transferred by law to all FSM citizens. In
Pohnpei, however, it can only be transferred to persons from that island.
Traditional and cultural institutions have a strong presence in Micronesian life. The keystoneof Micronesian society is the extended family, which is collectively responsible for maintaining
the welfare of the family including in relation to customary family land.
The system of land tenure is a complex mix of the old and the new. Older customary land
tenure conditions are strong or weak depending on the people involved, the location andhistory of the land, the historical title and rank of the land, and the cash opportunity associatedwith ownership, lease or use rights. Traditionally, land ownership in FSM was limited toinheritance within a family or clan. As a result, many land parcels in FSM are subject to thecommunal use and alienation rights of extended families, clans and communities. Private
landholders influenced to varying degrees by customary land tenure systems neverthelessoccupy most lands.
Patterns of public and private ownership over land and aquatic areas vary among thestates. In Pohnpei and Kosrae, land is both privately and state owned, while aquatic areas
are managed by the state as public trusts. In Chuuk, most land and aquatic areas are privately
owned and acquired through inheritance, gift or by purchase. In Yap, almost all land andaquatic areas are owned or managed by individual estates and usage is subject to traditional
control.
Land tenure patterns generally involve communal ownership of a single plot, single ownershipof several and separate plots or usage right to land owned by traditional leaders. In the
traditional economy, land is not a commodity to be sold or traded. However, the attitude insome areas towards land is changing with sales and trades taking place as well as leases

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especially near centers of development. Cadastral and registration programs have been
undertaken in each of the states with varying effects. In the main island of Yap, less than
10% of land has been registered and titled since a cadastral program commenced some 30
years ago. Chuuk and Kosrae have made more progress in the initial determination of landparcels although there is a substantial backlog in the land parcels to be surveyed and mappedand numerous outstanding disputes. Pohnpei appears to have made the greatest progress inthe cadastral survey of private lands.

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Anticipated Environmental & Social Impacts

5.1

Introduction
The PRIME and SCORE projects have the potential to create a range of impacts as a resultof Project feasibility, design and construction of physical works on primary and secondary
road assets. The impacts of these Projects on the physical, ecological and social
environment have been assessed using the methodology described below.
Specific environmental and social sensitivities identified through the impact and risk
assessment are outlined in Section 5.9.
Detailed assessment and measures to be adopted to mitigate any potential impacts havebeen provided in the PRIME Generic ESMP and/or works and site specific ESIA/ESMP as
required for both projects.

5.2

Anticipated Impacts of Components 1 and 3 PRIME and
SCORE
While the majority of potential impacts are expected under Component 2 physical works
for both projects, a number of risks are anticipated for Components 1 PRIME (Technical
Assistance related to the VA/CRRS, and road asset management systems) and SCORE(Technical Assistance related to the delivery of the VA/CRRS and road safety diagnostic
output recommendations), and Component 3 PRIME (institutional and regulatory reforms
and capacity buildings) and SCORE (institutional and regulatory reform and capacity
budling including a material testing laboratory).
The risks to be considered under Components 1 and 3 for both PRIME and SCORE
projects include the following:

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

Lack of or insufficient stakeholder engagement – where key stakeholders andcommunity have not been meaningfully engaged during the Technical Assistancestage, impacting outcomes of the technical assistance projects (e.g. VA/CRRS)
and resulting in distrust/discontent from stakeholders.



Poor quality environmental and social data – existing data and information
inadequate to inform the assessment, with high level of inaccuracy or gap filing
required, leading to either additional investigative studies required or inaccurate
conclusions/recommendations from the technical studies of both projects (e.g.
VA/CRRS).



Avoiding sensitive receptors (cultural heritage, natural or critical habitats) –sensitive receptors not being adequately screened during Component 1, leading tothese sensitivities not being fully understood or identified.

Inadequate training of national and state officials – training and capacity
building undertaken during Component 1 and 3 is not adequate to provide nationaland state officials to either support the Projects, meaningful input in the decisionmaking process, or carry the Projects forward through operation, after the external
consultants are no longer involved.

Institutional and regulatory reforms not sufficient – inadequate strengtheningof institutional structures and regulation leading to lack of communication between

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institutions and States and an inability to effectively regulate climate change risks
on the road network.
In addition, under SCORE component 3, general construction environmental impacts are
anticipated for the construction and operation (e.g. waste material) development of thematerial testing laboratory and as such section 5.4 below identifies anticipated impacts.
These impacts will be further detailed once the location and design of this facility has been
finalized.

5.3

Potential Impacts of Components 4 SCORE (CERC)
A Contingent Emergency Response Component (CERC) is included within the project toenable SCORE funds to quickly be reallocated to respond to emergency events.
Component 4 is designed to provide swift response in the event of an Eligible Crisis or
Emergency by allowing a portion of undisbursed project funds to be reallocated to respondto natural disasters and/or other crises and emergencies.
Due to the vulnerable nature of the FSM to climate change and severe weather events,
even with successful implementation of the other PRIME and SCORE components,
supporting post-disaster recovery remains an important feature of SCORE. Therefore thiscomponent is designed to provide swift response in an event of an Eligible Crisis or
Emergency, by enabling GoFSM to request the World Bank to re-allocate project funds tosupport emergency response and reconstruction.
Activities under Component 4 SCORE will be governed by the World Bank Directive
Contingent Emergency Response Components (CERC) (October, 2017). Disbursement ofemergency financing under the CERC will be contingent upon: a) the recipient establishinga nexus between the disaster event and the need to access funds to support recovery andreconstruction activities (an “eligible event”); and b) submission to and no objection grantedby the World Bank of an Emergency Action Plan (EAP). The EAP will include a list ofactivities, procurement methodology and safeguards procedures.
The EAP will require consideration of safeguard implications for any proposed emergency
supplies procurement or reconstruction activities. The WB, through the no objection
process, will closely examine the nature of the proposed activities, particularly those
involving civil works, to ensure (i) that they are not prohibited under the negative list and(ii) that the recipient is aware of the required safeguard compliance documentation before
initiating the process by which the proposed works will be prepared and implemented.
An eligible crisis or emergency considered for financing under Component 4 is defined by
the World Bank as: “an event that has caused, or is likely to imminently cause, a major
adverse economic and/or social impact to the Recipient, associated with a natural or manmade crisis or disaster”. This may include, but not be limited to, for example: cyclone;earthquake; storm surge and strong waves; tornado; tsunami; volcanic eruption; flood orinundation; drought; severe weather and extreme temperature; high winds; any othernatural disaster; and health related emergencies.
Preparation of the EAP will have regard to this ESMF and safeguard instruments will
require WB approval prior to commencement of activities. Importantly, the EAP will needto include procedures for:December 2021

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In order to ensure that CERC subproject activities comply with the requirements of theBank’s Safeguard Policies, a positive and negative list has been developed to provide
guidance on critical imports and/or for emergency works, goods or services which may be
eligible for financing. The negative list and screening process will be retained, but will needto allow for a degree of flexibility and efficiency in processing potential sub-projects. Further
guidance will be detailed in the Finance Agreement (FA) and CERC Operations Manual.
All CERC Activities will need to be screened for risk. Any new activity or sub-project andassociated elements developed during the implementation of the CERC will be evaluatedaccording to the screening process described below to determine the potential risk of
associated environmental and social impacts, and associated mitigation options.
The screening process consists of the following steps:
Step 1: at the time of identifying a new activity such as identifying new goods to procure,preparing Terms of Reference (TOR) for an activity or associated element (such astechnical advisory or services delivery, the activity shall be screened and categorized by
the CIU safeguards team. Annex C Form 5 provides the general CERC Safeguards
Screening Form.
If Step 1 reveals that there is no requirement for new mitigation measures or safeguards
instruments, then the screening form is completed and the activities proceed under the
existing PRIME-SCORE ESMF. Go on to screening Step 5 below.
If Step 1 reveals there are new risks or issues not already identified under the existing
PRIME-SCORE ESMF, then screening Step 2 below applies.
Step 2: Preparation of required safeguards instruments or update the PRIME-SCORE
ESMF mitigation measures including stakeholder consultations as necessary (CIU
safeguards team);
Step 3: Review of prepared safeguards instruments or updated mitigation measures as
per FSM and State laws and World Bank safeguards policies; additional stakeholder
consultations as deemed necessary (e.g. DTC&I, DoFA and WB);
Step 4: Submit prepared safeguards instruments or updated mitigation measures to WB
for no objection. Disclosure of approved instruments locally and on WB’s website (DTC&I,
CIU); andStep 5: Implementation, monitoring, reporting and remedial measures as per the PRIMESCORE ESMF or the approved instruments (DTC&I, DoFA CIU). Ongoing consultations
where necessary (DCT&I, DoFA CIU).
CERC Positive List:
The purpose of the positive list is to indicate the types of critical imports and emergency
works following a loss and needs assessment that would be acceptable to the Bank to befinanced under SCORE Component 4 (CERC). Project funds allocated to the CERC
Disbursement Category may be used to finance any expenditure of the GOFSM that is
consistent with the financial agreement provisions.
The following subproject or activities will be deemed eligible under the CERC:

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Federated States of Micronesia PRIME & SCORE Projects
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required by the public/private sectors (imported or locally manufactured) under the
CERC include:oHealth emergencies and the purchases of health-related goods and services;oConstruction materials, equipment and industrial machinery:oWater, air, land transport equipment, including spare parts:oPurchase of petroleum and other fuel products;o

Any other item agreed to between the WB and the Recipient (as documented inan Aide-Memoire or other appropriate Project document).

Emergency Sub-projects: Eligible expenditures for emergency sub-projects
initiated following the Declaration of a National Emergency/Disaster in response tosupporting post-disaster recovery (e.g., damage, losses and needs caused by anevent). The CERC subprojects will focus on emergency repairs to infrastructure
which may include; roads, wharves, jetties, runways, bridges, causeways, seawalls
and associated drainage systems,

CERC Negative List:
Sub-projects with the following potential impacts will not be eligible for financing under the
CERC component or the parent project:Involve the significant conversion, clearance or degradation of critical natural
habitats, forests, environmentally sensitive areas, significant biodiversity and/or
protected conservation zones, or will negatively affect rare or endangered species;Will cause, or have the potential to result in, permanent and/or significantly damage
to nonreplicable cultural property, irreplaceable cultural relics, historical buildings
and/or archaeological sites;; will result in involuntary land acquisition or physical displacement of affected
communities,

Will involve or relocation of Indigenous Peoples that would restrict or cease theiraccess to traditional lands or resources; andDo not meet minimum design standards with poor design or construction quality,
particularly if located in vulnerable areas.

The subprojects will also not require or involve:

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

Purchase, application or storage of pesticides or hazardous materials (e.g.
asbestos) (except fuel as mentioned above); Building structures that will
significantly alter coastal processes or disrupt breeding sites;

Sand/aggregate mining or land reclamation, particularly with material from themarine environment;Land that has disputed ownership, tenure or user rights;

Land that is considered dangerous due to presence of UXO;Political campaign materials or donations in any form;

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5.4



Weapons;

Any activity that supports drug crop production, processing or distribution; andA higher proportion of funding than is available.

Potential Feasibility, Design and Pre-Construction Impacts
under Component 2 of PRIME and SCORE
Without knowing the exact Component 2 physical works to be implemented under the
PRIME and SCORE Projects, the impact assessment process for this ESMF involved
identification of the Project’s ‘likely’ activities and potential environmental and social
impacts resulting from each activity during Project phases. A works activity could include
design/technical assistance, site preparation, construction, reinstatement, operation andmaintenance.
Potential impacts have been screened and evaluated as to whether they are adverse,
positive, or have a negligible or neutral impact. These issues are discussed in the following
sections in relation to the ‘likely’ Component 2 works activities under the PRIME and
SCORE Projects.
The feasibility, prioritization, design and procurement of works can play a major role to
avoid or reduce significant impacts to people and the environment. Project design shouldreflect current international standards for design and construction of roads, bridges
causeways and drainage, which may include site preparation, slope stability, drainage,
access road geometry, pavement, footpaths, bridges, causeway and other roadinfrastructure assets.
The following key impacts need consideration at the design / pre-construction / technicalassistance phases of both projects:Climate Change Impacts – roads and bridges typically have design lives of 20 to
40 year timeframes over which climate change could have direct and indirect
impacts. Direct impacts are due to effects of the environment namely increased
frequency and intensity of rainfall and sea level rise. The indirect impacts of climatechange on roads are due to the potential relocation of population and human activity
altering the demand for roads. An understanding of the likely impacts of futureclimate change by road planners, designers and asset managers can result in
considerable cost savings in the long term.

Easement Agreements – there may be issues defining or securing the roadeasement documents for some works areas, potentially more complex for secondary
roads under the SCORE project. This could include:(i) Formal easement documents do not exist;(ii) Documents are believed to exist, but cannot be sourced/found;(iii) Easement documents exist and can be sourced but are not well defined (i.e.,either no map accompanying the easement agreement or the map is notdetailed enough to define the exact extent of the easement); or(iv) There are existing (i.e. historic) disputes over the area of land or easement.
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lead to Project risks such as land owner disputes and grievances, which if
unmitigated or unresolved could hinder the implementation of works under the
PRIME and SCORE projects program of works. Previous experience in FSM has
shown that if land users with affected assets within road corridors are not consulted
in advance of works on design, anticipated impacts and mitigation measures, that
there is potential for opposition to road improvements. However, the generalexperience in FSM is that with proper consultations road improvements aresupported by the landowners and general public once project information has been
discussed. Each state road agency has policies and protocols in place to discussand reach agreements.


Asset Damage – through stormwater runoff eroding road or damaging adjacentassets through poorly designed and installed side-drains and culverts.



Direct Land and/or Asset Loss – as a result of the need to relocate structures
such as houses, commercial properties, etc. and the resultant impact on livelihoodsto accommodate the PRIME and SCORE Projects.



Disruption to Access – such as during road works activities or the replacementof bridge or causeway which could pose significant inconvenience to road users.



Restricted Coastal Margin Access – where works restrict local communities
access to the coastal margin either temporarily or permanently.



Safety in Design / Road Safety Assessments – design not robust enough for
local conditions or not international best practice, does not take into account locallyavailable material, or not appropriate for local safety issues (i.e. types of pedestrianor vehicular road use).



Avoiding and/or managing sensitive receptors (cultural heritage, natural or
critical habitats) – Due to the nations cultural richness and general practice ofburying loved one on private land may lead to contact with both known andunknown physical and cultural resources and as such chance finds are possible.
As such sensitive receptors not being adequately screened, leading to thesesensitivities not been fully understood or identified during design phase, resulting
in inappropriate design, or unnecessary impacts. UNESCO and other locally, nationallyor internationally significant cultural heritage sites may be impacted from construction andpost-construction use of roads that are improved under SCORE and PRIME. Damage canbe direct (such as within the footprint of works) or indirect (such as limiting or changing
access arrangements, desecrating spiritual or cultural significance or reducing visualamenity).

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

Identifying opportunities for environmental improvements – opportunities
exist for environmental and cultural heritage improvements and social benefits
through sound and thoughtful design, particularly as part of the ‘participatory
design approach’.



Lack or insufficient public consultation and project information disclosure –leading to community not aware of nature, scope, impacts or timing of works, andnot being able to adequately engage in the ‘participatory design approach’ process.

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5.5

Potential Construction Impacts under Component 2 of
PRIME and SCORE
Potential impacts arising from road works activities will depend on a number of factors
including the existing site conditions, the location of nearby assets and sensitiveenvironmental and social receptors and the scale and nature of the works proposed. On
this basis potential impacts are summarized in Sections below. In many instances potential
impacts can be mitigated through the implementation of Good International Industry
Practice (GIIP) measures outlined in the PRIME generic ESMP or works specific
ESIA/ESMP.

5.5.1

Physical and Ecological Environment

5.5.1.1

Water Quality and Sediment
There is potential for the discharge of sediment and contaminants as a result of both
Projects construction activities. An increase in suspended sediments in receiving water
bodies (streams, rivers and estuarine/coastal marine areas) can be caused by earthworks
and vegetation clearance activities as well as uncontrolled discharges of fine material fromexposed soil and stockpiles through stormwater runoff and overland flow. This can lead tochanges in the water quality of adjacent watercourses and coastal environments. Thereis also the potential for hydrocarbons from machinery operations and refueling activities
impacting water quality.
In the case of the PRIME and SCORE projects potential water quality impacts could arise
due to the generation of fine material in stormwater runoff and the vicinity of ecologicallysensitive terrestrial ecosystem and water bodies (freshwater and/or marine). Impacts are
fully manageable through the use of practical standard road environmental mitigation
practices, such as stormwater control, sediment traps, stockpile management, controlling
hazardous substances, suitable slope stabilization and minimizing instream works.

5.5.1.2

Terrestrial Biodiversity and Habitat
The potential impacts of construction activity relate primarily to the direct loss of habitat inroad, bridge or causeway footprints (such as riparian margins) as a result of earthworks
associated with construction activity. Noise and vibration are likely to be the main impacts
on terrestrial faunal species (e.g. birds, lizards, bats, etc.) during construction (refer section
5.4.1.5).
The environmental screening process (refer Section 6) includes a biodiversity and natural
habitat screening and assessment process for works, and specific mitigation measures areto be developed in a site-specific ESMP, if necessary.

5.5.1.3

Freshwater and Coastal Marine Biodiversity and Habitat
The potential impacts of construction activity relate primarily to:

The direct loss of freshwater, estuarine and coastal marine habitat in road / bridge /causeway footprint;Water quality impacts associated with uncontrolled runoff of sediments from exposed
earth or stockpiles in stormwater from construction areas, or from spills or leaks fromhazardous substances; andImpacts on freshwater and marine fauna and flora as a result of changes in water
quality.

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The environmental screening process (refer Section 6) includes a biodiversity and natural
habitat screening and assessment process for works, and specific mitigation measures (inaddition to those related to water quality management) have been developed in the PRIME
Generic ESMP, or site-specific ESMP for both projects if necessary, such as maintaining
fish migration and suitable crossing design.
5.5.1.4

Air Quality
Fugitive emissions of particulate material can occur from earthworks, concrete construction
activities and from disturbance of unsealed roads. Mobile source emissions occur frommachinery used for excavation, construction and transport operations.
Emissions during construction are likely to consist of the following:Exhaust emissions from machinery (e.g. excavators, trucks, generators etc) which
will depend on age and condition of machinery;

Dust associated with the earthworks, road use, material storage/ stockpile, concrete
batching or asphalt plant operation, quarrying or crushing materials; andEmissions of smoke from bitumen production.

Adverse effects of these emissions depend primarily upon the sensitivity of the local
environment and proximity to local populations. Those located closer to the construction
activities are most likely to be most affected, whilst those located further away are likely
be least affected. These effects can be classified generally as nuisance effects as a resultof deposition of particulates onto places where people live or frequent, or onto crops.
Impacts of particulate matter depend on the size of the particles generated. Human healtheffects of airborne Particulate Matter (PM) are mainly associated with fine particles thatare less than 10 microns in size (PM10) and which are small enough to enter the upper
respiratory tract. Coarser particulate matter, greater than about 10 to 20 microns, generally
cause nuisance effects due to soiling of surfaces, visibility or irritation to eyes and nose.
The large fraction (greater than 20 m) is usually referred to as deposited particulatematter.
Proposed construction activities are expected to result in minor impacts relating to dust
generation from earthworks activities, formation of soil and gravel stockpiles and from the
movement of heavy construction vehicles. These impacts can be managed but can causea nuisance for neighboring property owners and can create a hazard to road users.
Monitoring and implementation of measures to manage dust generation (such as the useof dust carts, etc.) has been developed for the PRIME generic ESMP or site-specific ESMP
for both projects if necessary. All machinery and vehicles used in both Projects will be
expected to meet FSM State EPA emissions standards and EHS Guidelines.
5.5.1.5

Noise and Vibration
Construction activities can result in increases in ambient and peak noise levels. Increases
in noise associated with construction are typically short term and are not considered to besignificant given the adoption standard mitigation measures (i.e., mufflers on vehicles,
specific work times etc.).
Intense vibration can damage buildings, retaining walls and other structures as well as
cause nuisance and potential health effects on people.

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The main potential sources of noise and vibration for this Project are likely to be:Removal of any road surface / soil / overburden / vegetation by bulldozer;



Delivery and placement of fill material in reclamation areas;Equipment and material deliveries to site by heavy vehicles;

Aggregate crushing, concrete batching or asphalt plant operation;

Removal of existing structures (such as bridges and causeways); and

Installation works for new bridges and causeways (e.g. pile driving).

Any residential dwellings or commercial buildings in close proximity to works will be
particularly sensitive to elevated noise and vibration.
Construction related traffic or activities could affect noise levels and potentially result innoise effects on nearby sensitive receptors such as local residents, schools, hospitals etc.
Managing the timing of works and site activities is the most appropriate management option
for all the noise-producing activities.
No blasting is expected to be required for both projects reducing the potential impacts fromvibration. However, drilling may be required for installation of new bridge piles which could
have low to moderate vibration effects. Monitoring and compliance with accepted EHS
Guidelines will be required.
Overall, given the short-term nature of construction activity and adherence to GIIP andEHS Guidelines, including monitoring, the potential noise and vibration impacts during
construction are not expected to be significant.
5.5.1.6

Hazardous Substances
The use and storage of hazardous substances (such as hydrocarbons, bitumen, cement,etc) can impact soil and water resources, if they accidentally spill or leak into theenvironment or if they are not properly disposed of, or in the event of a fire in the case of
flammable substances. Storage of hazardous substances will need to be managed (i.e.,
EHS Guidelines and adopted for fuel stored in bunded fenced areas, refueling activities
remote from watercourses on hard stand areas, fire-related precautions adopted, fenced
and secured etc.).
With GIIP mitigation measures in place, such as suitable storage, inspection, handling andcontingency practices and trained staff the risk of hazardous substances being discharged
to the environment is considered to be low.

5.5.1.7

Waste Management
Solid waste will be generated as a result of the construction process particularly as a resultof removing existing structures such as bridges and causeways or the existing roadsurface. While existing road material should be reused on site some may require removal
and disposal.
Any solid waste generated will be managed according to the following hierarchy oftreatment:(i)

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Remaining waste taken off-site and disposed at a facility licensed (permitted) by
State EPA/KIRMA.

Any hazardous waste generated as a result of the PRIME and SCORE projects will be
managed based on World Bank EHS Guidelines in conjunction with FSM national and Statelaws and regulations.
Construction workers will also require access to sanitation facilities. Liquid wastes will
require treatment to a standard that is consistent with treatment of similar waste withineach State.
The Contractor will be required to prepare a Waste Minimization and Management Plan
(WMMP) and Spill Management Plan (SMP) which sets out strategies and actions required
to reduce potential health and environmental risks associated with project waste
generation and disposal, including hazardous materials, management to avoid spills andother environmental releases, and identify opportunities for material recycling or reuse.
5.5.1.8

Invasive Pest Species
Roads and vehicles associated with construction activities can be vectors for weeds andanimal pests. There is the potential to introduce terrestrial invasive species throughvehicles and transport of soil, aggregate and construction materials particularly if thismaterial is imported from overseas or inter-State. Implementation of GIIP mitigation
measures (vehicle washing, sourcing weed free aggregates, fumigating aggregates etc)
will ensure all GoFSM biosecurity measures are implemented minimizing the risk ofinvasive pest introductions.

5.5.1.9

Aggregate and Asphalt Suppliers
Construction works will require aggregate to be used and a supply of asphalt or cement.
Asphalt and concrete batching plants have the potential to be a source of pollution to soils,
ground and surface waters.
Suppliers of road construction material for the Projects will be required to hold a quarry
license from the EPA/KIRMA and meet ESS, as well as be in general accordance with EHS
Guidelines. No coastal or marine reef derived coral rock or sand will be permitted to be
used on the PRIME and SCORE projects due to risks to climate resilience and ecologicalimpacts.
Each of the FSM States have existing and disused quarry sites, which have beenpreviously used for road maintenance and construction activities. These sites (describedin the Baseline Resource Assessment, Appendix A) will require further investigation todetermine whether they can supply suitable material (both quality and quantity) to meetthe needs of both Projects works (once known). The investigation of the quarry sites will
be completed following mobilization of the design and supervision consultant.
If these quarry sites are not able to meet the Projects requirements, aggregate material
will need to be sourced from offshore (inter-state or international). All domestic movementof aggregate between states will be subjected to E&S protocols, which is a standardpractice within the FSM. The FSM has a number of infrastructure projects that have in thepast included additional aggregate from other states of the FSM and or other nations.
Aggregate material imported from offshore will need to meet any State and ESS
requirements, which includes impacts managed through the implementation of Codes ofPractice (CoP) for quarry and dredging operations and ensuring materials such as

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aggregate and equipment meet strict biosecurity precautions and clearance for imported
materials, as well as adherence to the World Bank Group EHS Guidelines for construction
material extraction.
With GIIP mitigation measures in place, any potential impacts of locally or internationalsourced material can be managed to mitigate potential impacts.
5.5.1.10 Greenhouse Gas Emissions
Greenhouse Gas Emissions (GGE) during construction will be generated by construction
machinery. This impact will be temporary and is not expected to be a significant contributor
to overall emissions, so long as vehicles are adequately maintained. Vessels bringing
equipment and resources from overseas will generate emissions but are considered to beminor in terms of overall contribution to GGE.
Since any change or increase in GGE are likely to be minimal, no assessment has been
completed and no mitigation is proposed.

5.5.2

Social-Economic and Cultural

5.5.2.1

Resettlement, Land and Asset Loss
Direct temporary or permanent land and/or asset loss as a result of the need to remove
productive trees and crops as well as relocate structures (such as house fences, boundary
walls, access driveways) and the resultant impact on livelihoods could arise as a result of
the PRIME and SCORE projects. No physical displacement of people is expected to occur
for either projects.
The project will involve communities and affected land users in a process of participatory
design for planned road improvement works. Land acquisition is to be minimized.
However, for land that is required for project needs, this will be achieved through either
voluntary land donation (VLD) or land acquisition. The RF sets out requirements for landacquisition and other losses. A VLD protocol is included in the RF. The Project VLD
Protocol also applies for the donation of community, customary or collective land. As
stated in the protocol, VLD cannot be applied when (i) customary rights holders do notsupport, or will not directly benefit from, the Project, and (ii) conflicts over land exist whereconflicts over land exist, including customary collective ownership.
Measures outlined in the PRIME and SCORE Resettlement Framework (RF) will mitigate
this potential impact. The E&S Instruments are to be publicly disclosed on the WB website(www.worldbank.org)
as
well
as
relevant
FSM
government
websites(http://www.dofa.gov.fm/world-bank-projects/).

5.5.2.2

Pedestrian and Vehicular Traffic
During construction it is likely that there will be an increase in the number of vehicle (e.g.,trucks) movements to and from the work sites bringing in fill, construction material andearthworks equipment. This increased traffic could result in increased traffic congestion
and an increased risk of traffic incidents and general road safety issues (such as roadcrossing by pedestrians).
However, it is considered that any increased construction traffic experienced will result in
only minor impact on road users and minor and short term increases in congestion, andnoise and air quality effects on nearby sensitive receptors such as local resident’s following
implementation of GIIP mitigation measures.

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Traffic related impacts on air quality, noise and vibration are discussed in Section 5.4.1.4
and Section 5.4.1.5 above.
Disruption of a key transportation networks (i.e. replacement of bridge or causeway) could
pose significant delays in journey times and overall inconvenience to road users.
Alternative routes and/or temporary crossings (in the case of bridges works) are to beconsidered as part of the design, and a ‘participatory design approach’ will be used todetermine the best approach to maintaining access for all road users during construction
for applicable works. Mitigation must include safety measures such as signage, barrier
fencing, speed restrictions, etc.
In addition, roads will be required to remain passable during construction activities tominimize potential impacts on all road users including pedestrians and cyclists.
A Traffic and Road Safety Assessment (TRSA) will be undertaken under PRIME
Component 1 for identified roads and mitigation and will be developed to be included in
the PRIME generic ESMP and project site specific ESMP as required. In addition, allProject contractors will be required to prepare detailed methodologies in the CESMP tocomply with the TRSMP for the works, which is to be cleared before work commences.
Overall, the impacts from increased construction traffic to and from works sites, andconstruction related traffic impacts are considered to be minor for most works due to thefinite duration of works with any impacts mitigated through implementation of GIIP
mitigation measures.
In some instances however, there is a risk of more substantial pedestrian and vehiculartraffic related impacts from proposed works (such as proposed improvements to causeway
and bridge replacements). However these potential impacts can be managed through theimplementation of effective mitigation measures (i.e. installation of temporary parallel
crossing structure).
Given the significant benefit that the community will gain from the works being completed
these impacts are considered minor provided mitigation measures outlined in the PRIME
Generic ESMP and/or work specific ESMP are implemented.
5.5.2.3

Disruption to Existing Essential Services
It is possible that disturbance or relocation of existing utility services (such as power, water,
telecommunications etc) may be required for some works as it is common for thisinfrastructure to be located within or adjacent to the road corridor in all States.
Once the Component 2 works have been determined for both projects, utility infrastructure
within the proposed works footprint is to be surveyed as part of the Inventory of Loss (IOL).
Consultations with the relevant State owners of the utility infrastructure identified within thefootprint will be necessary to negotiate the most practical solution for avoidance orrelocation of that infrastructure to ensure that works construction activities do not impact
provision of this service to the community.

5.5.2.4

Construction Yard, Site Offices, Laydown Areas, Stockpiles etc.
Construction yards, laydown areas and associated works facilities can cause an adverse
impact through the increased disturbance, vegetation clearance, noise and waste
generated by yards and work sites especially if the sites are located within or close tocommunities. In addition, use of construction camps to accommodate imported workers
can create a range of issues such as: unsolicited interaction with local communities; drug

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Environmental and Social Management Framework/ alcohol use; and increases in communicable diseases such are sexually-transmitted
diseases (STDs), HIV/AIDS. etc.
Given the works are likely to be in close proximity to towns, villages and communities andin many cases State capitals, it is anticipated that the Projects will not require
accommodation camps. Workers would likely be housed in existing facilities such as guest
houses or rental properties. However, should construction camps be required the potential
impacts can be mitigated by the implementation of GIIP such as providing suitable
sanitation, water, catering, recreation and controlling/managing worker behavior.
Imported labor may be required for the Projects, if adequate resources and skills are notavailable locally. Importing labor can result in a range of impacts including environmental(e.g. increased pressure on existing natural resources), local economy and livelihoods (e.g.
inflation pressures, exacerbate vulnerability of marginal groups), increased pressure on
local infrastructure and health services (e.g. potential increases in violence, alcohol / drug
consumption, diseases, etc), social and community wellbeing.
Contractors shall also adhere to the PRIME and SCORE Project Labor Management Plan
(LMP), as well as be required to prepare a Social Interaction Plan (SIP) that will need tobe consistent with the requirements of the Stakeholder Engagement Plan (SEP), as partof the Construction Environmental and Social Management Plan (CESMP), which is toinclude a Code of Conduct (CoC) for site workers induction, rules regarding alcohol use,interaction with the local community, establish requirement for stakeholder
committee/community liaison officer, etc.
A construction yard, site office, laydown areas and/or stockpile area/s may be required
during construction depending on the location and scope of the works of both projects.
Should this infrastructure be required, this will be negotiated between the Contractor andlandowners (as outline in Section 5.4.2.1). Mitigation measures have been included in the
PRIME Generic ESMP and any projects works specific ESMP’s to ensure no residual
impacts are anticipated.
5.5.2.5

Archaeology and Cultural Heritage Resources
Ground disturbance activities such as those likely for bridge and road works are to beundertaken, which can potentially physically damage or indirectly impact cultural or historicsites, particularly where earthworks are required.
The likelihood of any physical cultural resources being present within works for both
Projects are considered low given the works are predominantly located within the roadcorridors within the existing road network with no new alignments proposed. The exception
may include graves, in close proximity to PRIME and SCORE project works and incudes
both tangible and intangible outcomes.
Sites of archaeological or cultural significance (such as grave sites, heritage ruins on
Pohnpei - Nan Madol) that may be adversely affected in any way by the works will havebeen identified in the design phase of each project as part of the environmental and social
assessment (ESS) or through the Inventory of Losses (IOL) survey, and throughconsultation with the land owners and community (and any other relevant stakeholders).
Contractors will implement the agreed mitigation measures throughout the construction
phase.
As part of the SCORE project on the island of Pohnpei the historic and cultural heritage
listed Nan Madol ruins are accessed by land via a secondary road. Although the road

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terminates at the foreshore and outside of the UNESCO listed historic/heritage site, socialand environmental due diligence assessments will need to be undertaken before thedesign phase to ensure potential impacts are managed in accordance with WB ESF andFSM national and state laws and regulations.
To avoid any potential impacts to unknown sites of archaeological or cultural significance,a chance find protocol has been developed in the PRIME Generic ESMP, which identifies
actions to be undertaken in the event of uncovering cultural heritage artefact during theconstruction phase. The chance find procedure is to be used for both projects.
5.5.2.6

Worker Health and Safety
Bridge, causeway and road construction activities can present significant health and safety
risks to workers. These include potential risk to workers from vehicles (working on an
active road network), heavy machinery, working near water, exposure to heat/sun,trenching, unstable slopes, overhead hazards (such as cranes), etc.
To avoid these impacts Contractors will be required to work in accordance with relevant
the WBG EHS Guidelines, adhere to National and State Health and Safety legislation, andbe addressed by way of a project specific Occupational Health and Safety Plan (OHSP) tobe prepared by the Contractor/s for both projects that outlines labor and working condition
requirements.
Contractor/s shall also adhere to the PRIME and SCORE projects LMP and the
National/State Labor Laws to prevent the exploitation of workers. In addition to workplace
occupational safety regulations, this includes requirements to not use child labor; notdiscriminate workers in respect of gender, race, employment and occupation; to not use
forced labor; and to allow freedom of association.
Unexploded Ordinance (UXO) are known to exist in FSM as a result of military actions
throughout the Pacific during World War II from 1942-1945. While many of the UXO’s havebeen cleared there is a chance some may still remain undiscovered.
Given the works to be implemented under the PRIME and SCORE projects are largely
within existing road corridors that had been altered, built on and maintained since that time
(typically 1970s onwards), the chance of workers encountering UXO’s as part of these
Projects are low.
However, mechanisms for identifying and reporting UXO’s should be included as part of
the Contractors Health and Safety Plan (CH&SP) and included in a screening and Chance
Find Procedure (CFP) that has been included in the PRIME Generic ESMP. In the eventthat a temporary road, bridge or causeway alignment is required, an assessment for UXO
risk should be undertaken, and a UXO clearance team may be required.

5.5.2.7

Community Health and Safety
Community health and safety can be impacted directly and indirectly during works
construction activities through accidents, injury and spread of communicable disease.
Public access must be restricted (managed) from entry to the work sites to ensure safety.
Safe, well sign-posted, alternative routes for pedestrians and vehicles must be provided at
all times. Conversely, the Contractor must not restrict the rights of local communities toaccess their properties. Restricting the movements to traffic and temporarily changing
road layouts can increase the potential for accidents.

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Construction traffic will utilize existing roads as haulage routes. The increase in vehicle
movements has the potential to place people using the area at risk particularly children.
This risk can be minimized by restricting construction vehicle speeds and timing the works
to avoid the periods when pedestrians and vehicles are most frequently using the road.
Other protective measures include signage and barriers, speed restrictions and publicproject awareness.
There is also the risk of spread of communicable diseases from workers to the local
community particularly if workers are working or residing in an area for extended periods.
Any associated risks will be managed through the Projects works specific ESMPs.
Gender-based violence (GBV) rates are high in FSM and women are vulnerable totrafficking, illegal sex work, unwanted pregnancies, harassment and violence. Sexual
Exploitation and Abuse (SEA) and Sexual Harassment (SH) is prevalent withapproximately one in three women (32.8%) having experienced physical and/or sexual
violence by an intimate partner in their lifetime within the FSM.
Imported and transient workforces such as those that are required for the constructionindustry are known to contribute to these issues. For women in FSM there are multiple
barriers to having equal opportunities as well as a life free from violence and coercion.
Priority areas of the GoFSM national gender planning include addressing female
unemployment and a gender-stratified labor market, teenage pregnancy, violence against
women and girls and limited access to justice and protection for women.
The PRIME and SCORE projects aim at achieving gender mainstreaming in its design,
management and implementation, to ensure barriers to participation of women are taken
into account. The Contractor/s shall also prepare a GBV Action Plan, a part of the CESMP,
to address GBV risk. Additionally, the PRIME and SCORE projects will be managed by
the projects specific Grievance Mechanism (GM) which includes a GBV/SEA/SH reporting
and referral pathway as well as standard project grievance pathway.
5.5.2.8

Vulnerable Groups
ESS1 also states that “special consideration should be given to stakeholders that may bedisadvantaged or vulnerable”.
While some vulnerable groups may live near or use sections of the PRIME and SCORE
roads that will be potentially impacted by works construction activities, they are notspecifically targeted or likely to be impacted over and above other landowners or groups
and will not be excluded from any socio-economic benefit from the Projects.
Particular attention will be paid to the needs of vulnerable Project Affected Person (PAPs)
including socially and economically vulnerable groups during any stakeholder consultation
activities and socio-economic surveys to be undertaken for works (if required). These may
include those without legal title to the land or other assets, households headed by females(where appropriate7) the elderly or disabled and other vulnerable groups such as people
living in extreme poverty or hardship8. The PRIME and SCORE project Stakeholder
Engagement Plan (SEP) provides further detail on engagement with PAPs.

7 Note: On some islands in FSM all houses are headed by a female as they own the land.

In these cases the female

head of the household would not be considered a vulnerable group.
8 As determined and identified by the relevant community leader.

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Pedestrians and cyclists are also considered to be vulnerable to road works. Children are
particularly vulnerable in this regard. Relevant aspects of the WBG EHS Guidelines andthe WB Road Safety Guidance Note are to be adhered to in regard to traffic safety.
5.5.2.9

Visual Amenity
Key potential impacts on visual amenity from the works could include minor vegetation
clearance, increased heavy vehicle traffic, land disturbance, lighting, the presence of works
infrastructure and increase workers.
Visual impacts are most significant when they affect the view of sensitive receptors suchas residential areas, urban areas, major and secondary roads, recreational and tourist
areas, heritage sites and other landmarks. The development of works could disrupt the
local landscape and scenic views through:

Clearing of existing vegetation;

Stripping, excavation and earthworks on the site;

Soil, waste and aggregate stockpiling; andTransportation of equipment to and from the site.

If these activities are appropriately managed (through measures such as visual screening
from replanting vegetation), the visual amenity impacts of construction activities for theworks are expected to be minor, and mostly temporary.
5.5.2.10 Stakeholder Engagement and Consultation Risks
Lack of meaningful, or insufficient consultation and project information disclosure canresult in distrust or discontent from Project stakeholders.
It is important for the stakeholder engagement process to be inclusive, participatory andtransparent to ensure multiple opportunities for learning about the Projects for all affected
or interested stakeholder groups. Ensuring informed participation and consultations
creating an atmosphere for open dialogue, ensuring the vulnerable are empowered andfacilitated to participate and transparency are the principles in the approach to stakeholder
engagement.
Key stakeholder considerations, principles and engagement approaches for the PRIME
and SCORE Projects are outlined in the Project’s combined SEP.

5.6

Potential Operational Impacts under Component 2 of PRIME
and SCORE
The potential operational phase impacts, including both positive and negative, aresummarized below.

5.6.1

Potential Benefits
Once operational, roads, culverts and causeway upgraded or repaired under the PRIME
and SCORE projects will likely result in the following benefits:

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Road and assets that are more resilient to climatic events by providing a more robustroad surface, effective drainage, protection from coastal and river/streambank
erosion, realignment away from erosion risk areas, access to properties, villages etc.

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Environmental benefits resulting from improved water flow / aquatic habitat frombridge, culvert and causeway improvements.

Improved connectivity and more reliable access resulting in socio-economic
improvements through the ongoing transportation and movement of people andgoods.



Reduction in lost time due to road damage from inclement weather events that affectbridges and culverts through flooding or washout.

Enhance the safety of road users including pedestrians and cyclists.

Improve the travel times and comfort of road users.



Reduced vehicle wear and tear requiring less frequent maintenance.

The Projects will therefore benefit both communities and vulnerable groups by way ofproviding a safer environment for all road users and allow improved and safer access toemployment opportunities, markets, and social services. This includes men and women,
the young and the old, indigenous and non-indigenous persons within FSM.
Other potential positive impacts following completion of the Projects could include
improved road side drainage system (e.g., channels and catch pits) conveying stormwater
to the adjacent receiving environment and assist with more efficient capture of potential
contaminants (such as sediment, litter etc.).

5.6.2

Environmental Impacts
Potential environment impacts include:

Water Quality – There is the potential for the discharge of sediment andcontaminants (such as heavy metals, oils and hydrocarbon) from vehicle movementson the completed works infrastructure (e.g. road, bridge, causeway etc). These
uncontrolled discharges have the potential to enter surface water drainage channels
from runoff over newly created impervious surfaces and migrate towards theadjacent receiving environment. This potential impact can be mitigated in design
and is considered minor and to be similar to that which occurs currently.



Aquatic Biodiversity and Habitat – The potential impact of the PRIME and SCORE
projects on aquatic biodiversity once completed primarily include the discharge ofcontaminants in stormwater runoff from the road surface. This potential impact canbe mitigated in design and is considered minor and to be similar to that which occurs
currently.



Terrestrial Biodiversity and Habitat – Minor clearance of overhanging andencroaching vegetation may be required for maintenance purposes for some works
and a possibility of domestic animal roadkill cannot be discounted. However impacts
on the integrity of natural habitats are considered very minor and consistent with thecurrent way the existing road network is maintained throughout FSM.

Air Quality – Air quality source emissions during operation will occur from vehicular
movements along the road network and are likely to consist of exhaust emissions
and dust associated with the road use, etc. The likelihood of nuisance effects are
no different to that which occur currently because the works are not anticipated toincrease the volume of traffic or the duration of journey time. Dust may be reduced
in areas where the road surface is improved.

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

5.6.3

Noise and Vibration – Vehicle movements across the operational bridges,
causeways and roads are likely to result in very little or no increase in noise andvibration from current conditions for adjacent residential properties as no increases
in traffic movements are anticipated.
Speeds may increase due to safer
infrastructure and heavier truck weights may be possible due to the upgradedinfrastructure resulting in an associated increase in engine noise. However, thesmoother running surface is likely to reduce tire noise. While FSM has no noise
standards, any change from current conditions is expected to be minor.

Social Impacts
Potential social impacts include:

Pedestrian and Vehicular Traffic – traffic flow and road safety is expected to be
improved during operation. It is expected that similar volumes of traffic will continue
to use the road network (i.e. there is expected to be no appreciable change in traffic
volume). Traffic speed limits are planned to generally be maintained at 40km/hour.

Community Health and Safety – Community safety can be impacted directly andindirectly once the works have been completed, through vehicular and pedestrian
accidents resulting in injury (which can be potentially serious).

The potential increase in speed and wider road corridor has the potential to place people,
particularly children, using the area at risk. This risk can be minimized through the design
and implementation of traffic management systems (speed bumps, pedestrian crossings,
signage, central pedestrian islands, etc.) which will assist with restricting speeds restricting
vehicle speeds particularly near residential properties and public awareness/enforcementof state speed laws. As no increase in vehicle movements are anticipated, the increased
potential to place people using the area at risk is no more than minor.

5.7

Cumulative Impacts
Neither construction nor operation of the works are likely to be implemented under the
PRIME and SCORE projects will result in trans-boundary or global scale impacts.
The FSM with assistance from the broader international development community, including
the WB, are developing a number of significant road infrastructure projects throughout thenation over the next decade. The combined cumulative environmental impacts from all
Projects, including PRIME and SCORE will potentially be created by minor vegetation
clearance, contaminants discharges (such as sediment), waste material management andminor habitat alteration and social impacts such as increased labor (local and foreign),
temporary disruptions to traffic and pedestrian flow, changes to ambient air quality and theexisting noise environment primarily throughout the construction period.
The PRIME and SCORE Projects will not significantly change environmental conditions
and result in an overall positive social outcome for local communities provided GoodInternational Industry Practice (GIIP) mitigation measures are implemented.

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5.8

Risk Assessment & Impact Identification Methodology
In assessing the environmental and social risk of road works activities, impacts are rated
to determine the appropriate response or management actions that should be implemented
to minimize potential impacts. The risk assessment methodology for the PRIME roadworks activities is described below.
The commonly adopted Australasian Standard for Risk Management9 has been used todetermine the level of risk posed by activities associated with road works based on thelikelihood or probability of an event, and the consequences of the impacts of that event
occurring (see Table 5-1). Note this is risk rating at the activity level to inform the specificmitigation measures to be applied and is different to the World Bank Environmental andSocial Framework risk ratings (low, moderate, substantial, high) that are applied at the
project level based on accumulated risk assessment of all activities related to the subproject (refer to the ESMF screening process).
Table 5-1: Qualitative risk analysis matrix
Consequence
1

2

3

4

5

Risk Map Color CodeLikelihood

SevereMajor

Moderate

Minor

Negligible

E = Extreme

A - Almost
Certain

E

E

H

M

M

H = High

B – Likely

E

H

H

M

L

M = Moderate

C- Possible

H

H

M

M

L

L = Low

D – Unlikely

H

M

M

L

L

E - Rare

M

M

L

L

L

This conventional risk management framework is considered applicable in the context of
this assessment which has a focus on high level identification of biodiversity andecosystem services, social and socio-economic risks.
There are four main levels of risk after combining the ‘likelihood’ and ‘consequences’factors (see Table 5-2 and Table 5-3). Each level has a response or management control
action.
The four ‘Risk Levels’ are:

Extreme (E) Risk - those impacts that require significant mitigation to avoid serious
harm because of the high probability of severe or major harm (significant, long term
irreversible damage).

High (H) Risk - those impacts that are likely and predictable but of moderateconsequence; requiring specific and detailed mitigation, possible bespoke orcomplex if harm to sensitive environments and communities.

Moderate (M) Risk - those that are likely to unlikely and predictable require industry
standard mitigation measures in place to address impacts and monitoring programs.

9 AS/NZS ISO 31000:2009.

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Environmental and Social Management FrameworkLow (L) Risk - those impacts that do not require any specific management actions
but may be part of routine management and monitoring plans.

In cases of “E”, “H” and “M” Risks, mitigation measures are identified to reduce the levelof residual Project risk.
Table 5-2: Qualitative measures of likelihood

Level

Descriptor

ExampleA

Almost certain

Is expected to occur in most circumstances

B

LikelyWill probably occur in most circumstancesC

Possible

Could occur

D

Unlikely

Could occur but not expected

E

Rare

Occurs in only exceptional circumstances

Source: Modified from Standards Australia/New Zealand 2006

Table 5-3: Qualitative measures of consequence

LevelDescriptor

Environmental / Social Impacts

Public/Media
Attention

Financial(USD)

1

Catastrophic

Irreversible changes to habitat/s species.
Significant extensive detrimental long term
impacts on the environment, community or
public health. Catastrophic and/or
extensive chronic discharge or persistenthazardous pollutant. Damage to an
extensive portion of aquatic ecosystem.
Long term impact on water resource.
Human life at risk or life has been lost.
Large scale involuntary resettlement.
Indigenous people disconnected from land
and resources. GBV harm.

Probable public ormedia outcry withnational/international
coverage. Significant
green NGO
campaign>$700,000

2

Major

Degradation or damage to habitat that will
have long term consequences. Off-site
release contained with outside assistance.
Short to medium term detrimental
environmental and social impact off-site orlong term environmental damage on-site.
Indigenous Peoples at risk from harm.
Moderate scale of involuntary resettlement
or economic displacement. GBV harm.

May attract attentionof local and state
media and local
community groups$350,000 –$700,000

3

Moderate

Onsite release contained with outside
assistance. Significant discharge ofpollutant possible source of community
annoyance. Non-persistent but possible
widespread damage to land. Damage tohabitat or land use that can be remediatedwithout long term loss or very localized
persistent damage. Voluntary resettlement
required. Small scale involuntary
resettlement. Community unrest potential.
Impacts on wellbeing and livelihood
through noise/traffic/access.

May attract attentionof local media
heightened by local
community$35,000 –$350,000

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Leve
l
4

Descriptor
Minor

Environmental / Social Impacts
On site release immediately contained
without outside assistance. Smallemissions odor, dust or noise/vibration
without sensitive receptors. Voluntary
resettlement

Public/Media
Attention
Local community
attention or repeatedcomplaints

Financial(USD)$3,500 –$35,000

Notes: Financial consequence value converted from AUD to USD (1:1.4)

5.8.1

Outcome of Risk Assessment & Impact Identification
Table 5-4 to Table 5-7 present the results of the assessment of risks associated with theproposed PRIME and SCORE Projects. A summary of key measures to mitigate risk are
identified.

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Table 5-4: Outcome of Assessment of PRIME and SCORE Component 1 (Spatial and Sector Planning), Component 3 (Strengthening the Enabling Environment) and SCORE
Component 4 (CERC) Risks.

Activity

Source of Risk

Description of Potential Impact

Assessment of
Risk
C

L

RatingMitigation Summary

PostMitigation
Residual
ImpactComponent 1:
Preparation of VA / CRRS
Lack of or insufficient
stakeholder engagement

Local community.

Lack of or insufficient stakeholder engagement
where key stakeholders and community havenot been meaningfully engaged during theTechnical Assistance stage, impacting
outcomes of VA / CRRS and resulting in
distrust / discontent from stakeholders.

2

A

E

Ensure Stakeholder Engagement Plan (SEP) is
implemented to ensure appropriate engagement and input
and buy-in from stakeholders.

M

Poor quality environmental
and social data

Local community /environment

Poor quality environmental and social data
inadequate to inform the assessment, with highlevel of inaccuracy or gap filling required,leading to either additional investigative studies
requiredorinaccurate
conclusions/recommendations
fromthe
VA/CRRS.

2

A

E

Environmental and social objectives to be included inTerms of References (ToRs).

M

Sensitive receptors (cultural heritage, natural or
critical habitats) not being adequately screened
during Component 1, leading to thesesensitivities not being fully understood or
identified.

2

Initial E&S Screening ofsensitive receptors

Local community /environment

Design team to be mindful of data sources, limitations andassumptions, and ensure accuracy and adequacy of thedata collection process.
A

E

Mitigation of potential impacts on sensitive receptors
through screening and design-related avoidance. E&S
screening will be undertaken for each works site, todetermine assessment pathway, and feed into multicriteria
assessment for works prioritization.

M

Preparation Road Asset Management (PRIME) and Crash Database (SCORE) Systems

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Activity
Lack of or insufficient incountry training.

Source of Risk
National and State
Governments Local community.

Description of Potential Impact
Lack of or insufficient training and skills
development to ensure full understanding ofdata collection, analysis and management ofdata sets to provide meaningfully resultsorientated outcomes.

Assessment of
Risk

Mitigation Summary

PostMitigation
Residual
ImpactC

L

Rating3

C

M

Ensure training and skill development are implemented toensure appropriate engagement and input and buy-in fromstakeholders.

L

Component 3: Institutional and regulatory strengthening and capacity building
Inadequate training of
national and state officials

Institutional
structures

Training and capacity building undertaken
during Component 1 and 3 is not adequate toprovide national and state officials to either
support the Projects, meaningful input thedecision-making process, or carry the Projects
forward through operation, after the external
consultants are no longer involved.

3

A

H

Training and capacity building objectives to be included inTerms of References (ToRs) of external consultants aswell as in CIU workplan, including assessment of current
capacities, and upskilling and resourcing requirements
and monitoring.

L

Institutional and regulatory
reforms not sufficientInstitutional
structures

Inadequate strengthening of institutional
structures and regulation leading to lack ofcommunication between institutions and States
and an inability to effectively regulate climatechange risks on the roading network.

3

A

H

Existing challenges and experiences to be communicatedwith consultant undertaking Institutional Governance
Review, objectives to be included in Terms of References(ToRs).

L

Sensitive receptors (cultural heritage, natural or
critical habitats) not being adequately screened
for location and activities associated with
Material testing laboratory leading to thesesensitivities not being fully understood or
identified.

3

Initial E&S Screening oflocationandsensitive
receptors

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Suitable and realistic timeframes to be incorporated toallow meaningful engagement with all key institutional
stakeholders, including workshops.
C

M

Mitigation of potential impacts on sensitive receptors
through screening and design-related avoidance. E&S
screening will be undertaken for each works site, todetermine assessment pathway, and feed into multicriteria
assessment for works prioritization.

M

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Activity

Source of Risk

Description of Potential Impact

Assessment of
RiskC

Building design / renovation/ construction for material
testing laboratory

Construction anddemolition waste.
Risk to life
through poor
design. Inefficientuse of resources(e.g. water,energy,aggregates). Lackof climate
resilience.

Renovations, construction creates waste tolandfill.
Poor building design creates inefficient use ofaggregates, water and energy in construction
and during operation.
Poor building design leads to loss of life or
injury from natural hazards or fire.

3

L

RatingM

C

Mitigation Summary

PostMitigation
Residual
ImpactMitigation of potential impacts on sensitive receptors
through screening and design-related avoidance. E&S
screening will be undertaken for each work site, todetermine assessment pathway, and feed into
multicriteria assessment for works prioritization. Design
to take into account the following;

Water and energy efficiency.

Reuse of material in construction.



Waste minimization and recycling for demolition,
renovation and construction.



Ability to connect solar panels to roofs.

Resilience to natural hazards caused by climatechange.

Component 4 (SCORE only): CERC
Inadequate capacity andunderstanding of nationaland state officials

Institutional
structures

Capacity building undertaken is not adequate
to provide national and state officials
meaningful input in the decision-making
process to prepare and implement CERC andmanage E&S risks.

4

C

M

Training and capacity building objectives to be included inprojects activities to ensure capacity has been increased.

L

Initial E&S Screening of
CERC Project interventions/sensitive receptors

National/State/
Local community /environment

CERC Sensitive receptors not being
adequately screened (negative-eligible CERC
list) leading to these sensitivities not being fully
understood or identified.

4

C

M

Mitigation of potential impacts on sensitive receptors
through screening and design-related avoidance. E&S
screening will be undertaken for each CERC triggered
project, to determine assessment pathway, and feed into
multicriteria assessment for works prioritization.

L

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Table 5-5: Outcome of Assessment of Key Feasibility, Design and Pre-Construction Phase Environmental, Social, Health and Safety Risks for Component 2 for PRIME and
SCORE projects.

Activity

Source of Risk

1. Easement agreement (s)Easementagreement Land owners anddocumentation for existing land
users
primary and secondary road adjacent to works
easements not available for areas.
entire or sections ofproposed works areas.

2. Ecological biodiversity/habitats
Road / Bridge / Causeway Stream
and/buildings design.
coastalarea
biodiversity andhabitats.

3. Cultural heritage
Road / Bridge / Causeway /building design

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Cultural heritage
featuresandartifacts.

Description of Potential Impact

Assessment of
Risk

Mitigation Summary

PostMitigation
Residual
ImpactC

L

RatingRisk of land owner/user objection to proposed
works.

4

C

M

Improvement works for existing roads will be designed
through participatory design approach. Affected landowners and community will be consulted from preliminary
design stage and provide agreement to works design.
Property losses adjacent to roads will be minimized andwhere unavoidable will be restored through mitigation
measures outlined in the Projects Resettlement
Framework (RF).

L

Loss or modification of stream and coastal area
biodiversity and habitats.

3

A

H

Mitigation of potential impacts on ecological habitat as aresult of improvement works to existing roads andstructures through screening and design-related
avoidance. Biodiversity and natural ecological habitat
impacts will be screened and assessed for each works
site, if required, site-specific ESMP will be prepared toprovide the avoidance and mitigation measures.
Design team to have EHS clauses in bid documents andrequire Contractors Environmental and Social
Management Plan (CESMP).

L

Loss or modification of cultural heritage
features, artifacts, graves.

3

A

H

Mitigation of potential impacts on cultural, archaeologicalor historically significant sites through screening anddesign-related avoidance. Cultural heritage andarchaeological impacts to be screened and assessed foreach works site, and if required a site-specific ESMP is tobe prepared to outline specific avoidance and mitigation
measures.
Design team to have EHS clauses in bid documents andrequire CESMP from Contractors.

L

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Activity

Source of Risk

Description of Potential Impact

4. Permanent or temporary asset loss (e.g., land, buildings, fences, crops, etc.)
Loss of land and non-land Asset owners.
Permanent loss of land or restricted land use
assets.
due to land access requirements for projectworks. (Impacts identified through works designand due diligence process in advance of works.)

Temporary use of land forlaydown area.

Asset owners.

Temporary loss of land due to use of land forlaydown area.

5. Construction materials (e.g., aggregates) and waste materials generated
Use of aggregate materials Environmental
Use of material from non-sustainable sourcesin construction activities.
risk.
(i.e., coastal sand and coral reef materials).

Waste materials generated
during road construction
activities.

December 2021

Disposal of wastematerials.

Pollution arising from disposal of wastematerials at unlicensed facilities.

Final Draft

Assessment of
Risk

Mitigation Summary

PostMitigation
Residual
ImpactC

L

Rating3

A

H

Avoidance of severe impacts on livelihood or thoserequiring physical displacement through screening
process.
Due diligence to assess losses, consultation with affected
persons, preparation of resettlement instrument(resettlement plan or voluntary land donation plan).

L

3

A

H

Identification and use of Government land for laydown
areas/ land previously used for similar activities, etc.
If required Voluntary Land Donation (VLD) process to be
initiated. If no VLD, then rental allowance to be provided.
At end of rental period land to be returned in original
condition.

M

2

B

E

Only material from licensed local or international landbased sources (i.e., quarries) to be used (i.e. no coastal
sand and coral reef / rock to be used).
Where licensed local quarry sites do not meet compliancerequirements, they should develop and implement site
specific ESMP in line with relevant WBG EHS guidelines
for construction material extraction.
Design team to have EHS clauses in bid documents andrequire CESMP from Contractors.

M

2

A

E

Material reused in roading process where possible ordisposed of at permitted landfills.
Design team to include in bid documents:
a. Relevant EHS clauses related to disposal of wastematerial.
B. Requirement for Contractor to prepare CESMP, ‘Waste
Minimization and Management Plan (WMMP)’ and ‘Spill
Management Plan (SMP)’.

M

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Activity

Source of Risk

Description of Potential Impact

Assessment of
Risk
C

L

RatingMitigation Summary

PostMitigation
Residual
Impact

6. Coastal margin access
Loss of access to coastal Landowners,area.
wider community.

Permanent or temporary loss of access tocoastal margin due to adjacent works.

3

A

H

Design engineer to identify where coastal margin access
restrictions and issues may arise during preliminary
design.
Avoidance or minimization of access restrictions throughparticipatory design approach, to ensure coastal marginaccess is maintained during and following construction.
Access restriction impacts to be screened and assessed
for each works site, and if required a site-specific ESMP
is to be prepared to outline specific avoidance andmitigation measures, including consultation withlandowners, reinstatement of access etc.
Design team to have EHS clauses in bid documents toavoid unnecessary access restrictions or disturbance, andrequire Contractor to prepare CESMP.

L

7. Disruption to usual access
Replacement of bridges / Asset users / local
causeways.
community.

Permanent or temporary loss of access forusers / local community.

2

A

E

Design engineer to identify where issue will arise. Sitespecific ESMP to be prepared including consultation withlandowners, reinstatement of access, etc.
Design and construction team to ensure alternativeroute(s) / crossing (s) are available.
Where this is not possible then temporary crossing to beprovided.
Road access restrictions and disruptions to be screened
and assessed for each works site, and if required a sitespecific ESMP is to be prepared to outline specificavoidance and mitigation measures, including
consultation with landowners, reinstatement of access.
Design team to have EHS clauses in bid documents andrequire Traffic and Road Safety Management Plan
(TRSMP) and CESMP from Contractors.

M

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Activity

Source of Risk
Adjoining
owners.

land

Description of Potential Impact
Temporary restriction on use of adjoining
privately owned land adjacent to bridge /causeway alignment.

8. Erosion potential of stormwater / diverted surface waters
Change in waterflow as a Watercourses and Changes in erosion potential as a result in
result of culvert / bridge coastal areas.
changes in water flow.
installation.

9.

Assessment of
Risk

Mitigation Summary

PostMitigation
Residual
ImpactC

L

Rating

2

A

E

Design engineer to identify where issue will arise. Sitespecific ESMP to be prepared including consultation withlandowners, reinstatement of access, etc.
Use of private/customary land for temporary use to benegotiated between with land owners.
At end of rental period land to be returned in original
condition.
Access restrictions and disruptions to be screened andassessed for each works site, and if required a sitespecific ESMP is to be prepared to outline specificavoidance and mitigation measures, including
consultation with landowners, reinstatement of access etDesign team to have EHS clauses in bid documents andrequire TRSMP and CESMP from Contractors.

M

3

A

H

Design of structures to minimize erosion potential such asconcrete side drains / culverts, energy dissipation
structures installed.
Design team to have EHS clauses related to sediment anderosion procedures in bid documents and require Erosion
and Sediment Control Plan (ESCP) from Contractors.
Water flow / hydrology impacts to be screening screened
and assessed for each works site, and if required a sitespecific ESIA and ESMP is to be prepared to outline
specific avoidance and mitigation measures, including any
appropriate technical studies.

L

Surface water quality

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Activity
Discharges from operationalsurfaces.

Source of Risk
Surface waters.

Description of Potential Impact
New pathways for contaminants, including
refuse (e.g. trash, plastic bottles/bags, etc) toenter waterbodies.

Assessment of
Risk
C

L

Rating

3

A

H

Mitigation Summary
Design of features to minimize ingress of stormwatercontaminants (e.g., catchpits), and specifications forregular maintenance required.

PostMitigation
Residual
ImpactL

Design team to have EHS clauses related to stormwatercontaminants and discharges in bid documents andrequire ESCP, WMMP and SMP from Contractors.
10. Use and Accommodation of Imported Labor (if required)
Use and accommodation of Local community.
Environmental (increased pressure on existing
imported labor.
natural resources) economic and livelihoods(inflationarypressures,
exacerbate
vulnerability of marginal groups, etc),
infrastructure and services pressure, health(potential increases in violence, alcohol/drug
consumption, sexually transmitted diseases,etc), and social and community wellbeing.

3

A

H

Identify whether imported labor required.

M

If imported labor required then a Social Interaction Plan
(SIP) is to be prepared to include site workers induction,
rules regarding alcohol use, interaction with the local
community, establish requirement for stakeholder
committee/community liaison officer, etc

11. Design
Safety in Design / Road
Safety Assessments.

Local community.

Design not robust enough for local conditions
or not international best practice, and does nottake into account locally available material.

2

A

E

Design specifications included in design consultant TORs
(stating that design must adhere to appropriate
international best practices guidelines for the works).
Type and quality of locally available material
communicated include in ToRs to inform sound design, or
requirement for sourcing suitable material from offshore.

M

Design suitable for climatechange adaptation andresilience objectives.

Local Community /environment.

Design based on inaccurate climate change
projects and assumptions, including sea levelrise, extreme weather frequency and severity
etc, leading to insufficient road drainage
resulting in flooding and inundation issues.

2

A

E

Design specifications and objectives included in design
consultant TORs (stating that design must adhere toappropriate international best practices guidelines for theworks, and latest internationally accepted climate change
projections).

M

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Activity

Source of Risk

Description of Potential Impact

Assessment of
Risk
C

L

RatingAvoiding sensitive receptors(cultural heritage, natural or
critical habitats) throughdesign.

Local community /environment.

Sensitive receptors not being adequately
screened, leading to these sensitivities notbeen fully understood or identified during
design phase, resulting in inappropriate
design, or unnecessary impacts.

2

A

E

Design for transport noise
during operation, including
integrationofsuitable
mitigation measures, if
needed.

Local community.

Design does not adequately account fortransport noise impacts on sensitive receptors
during operation, such as noise fromincreased speeds.

3

A

H

December 2021

Final Draft

Mitigation Summary
Mitigation of potential impacts on sensitive receptors
through screening and design-related avoidance (e.g.
participatory design approach’).
Sensitive receptors will be screened and assessed foreach works site, if required, site-specific ESMP will be
prepared to provide the avoidance and mitigation
measures.
Design specifications to include traffic calming devices invillages and barriers on corners, speed signs etc,
particularly in the vicinity of sensitive receptors.

PostMitigation
Residual
ImpactM

L

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Table 5-6: Outcome of Assessment of Key Construction Phase Environmental, Social, Health and Safety Risks for Component 2 Physical Works for PRIME and
SCORE projects.

Activity
1. Air Quality / Dust
Generation of dust as a result ofconstruction activities in projects
work locations including laydown
areas.

2. Noise & vibration
Construction activity creating
noise and / or vibration
disturbance in projects work
locations including laydown
areas.

December 2021

Source of Risk

Description of Potential Impact

Assessment ofRisk
C

L Rating

Mitigation Summary

PostMitigation
Residual
ImpactSoil disturbance, roadsurfaceremoval,spillage from trucks
transporting material.

Dust creating nuisance (and potential
health issues) where road works occur inclose proximity to adjacent residential /commercial properties.

4

B

M

Construction vehicles shall be regularly serviced andmaintained to prevent the emission of visible particulates.
The number and size of stockpiles shall be minimized, andhave appropriate containment to prevent dust discharges.
Dust suppression (i.e. a water cart, or similar) shall be used
to dampen active work areas and stockpiles in dry
conditions.
Washing vehicle tires and sweeping the road on a daily
basis or as required to prevent the spread of soil and dust
outside of the works area.
Banning fires on site.

L

Local community.

Noise and / or vibration disturbance toadjacent households where road works
occur in close proximity.

3

A

H

The Contractor shall ensure noise attenuation is inaccordance with the WHO and WB EHS guidelines.
Consultation and engagement so people are fully informed
and can make alternative arrangements for work or
accommodation during works, in accordance with SEP.
Strict adherence to State working hour requirements.
Regularly maintenance of machinery, equipment andvehicles to ensure noise reduction e.g. mufflers, use of air
brakes, etc.
Reduced speed limits.
Monitor and investigate complaints through GM, andconsider noise barriers where appropriate.
Contractor to identify structures within zone of vibration
impact, and assess condition of structure.
Noise monitoring at site and sensitive receptors.

M

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Activity

3. Surface Water Quality
Construction activities in projects
work locations e.g., road / culverts/ bridges / causeways.

December 2021

Source of Risk

Description of Potential Impact

Assessment ofRisk
C

L Rating

Mitigation Summary

Contractors.

Noise/ vibration impacts on health ofworkers.

3

A

H

Contractor to ensure adherence to OHSP.
Workers provided with PPE including ear protection.
Regularly maintenance of machinery, equipment andvehicles.

Changes in water
quality in adjacentreceivingenvironment,
includingsurfacewater and groundwater aquifers.

Ground disturbance leading to runoff ofcontaminants(e.g.,
sediment,hydrocarbons, cement, etc) in stormwaterand changes in water quality of adjacentreceiving environment.

3

A

H

Ingress of contaminants (such ashydrocarbons) due to spillage in laydown
areas, refueling activities entering
groundwater.

3

A

H

Loss and/or discharge of hazardous
material into the aquatic and/or terrestrial
receiving environment, or groundwateraquifer.

3

A

H

Contractor to prepare and implement CESMP detailingprocedures to ensure ground disturbance in minimized,
and measures to control offsite movement of disturbed
sediments hazardous substance and other discharges,
effective stormwater control, slop excavation, in-stream
works and monitoring requirements.
Contractor to prepare and implement a SMP, detailingprocedures to minimize release of contaminants such asfuels stored in bunded areas, refueling activities on
hardstand areas etc.
Additional controls for hazardous substances including oils
and hydrocarbons are provided below.
Storage of all hazardous substances and chemicals(including fuel) and refueling is to occur at least 50 m awayfrom watercourses.
Conduct daily inspections of machinery with particularattention to repair of hydraulic and fuel systems to prevent
leakage.
Careful handling of unhydrated cement material and wet
cement and fuel to avoid spills.
The Contractor shall have spill kits available and staff be
trained in their use.
Immediate notification of PIU in case of any fuel or chemical
spill, to report the incident and should be reported to the
EPA/KIRMA within 24 hours.

Final Draft

PostMitigation
Residual
Impact
L

L

L

L

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Activity

Source of Risk

Description of Potential Impact

4. Aquatic Ecological Resources
Construction activities in projects Aquatic(i.e.,
work locations adjacent to freshwater
fish,
culverts/bridges/causeway.
habitat) & coastal
marineresources(fish,
coral
reef
habitat,seagrass
beds, etc).

5. Terrestrial / Riparian Ecological Resources
Construction activities in projects Sensitive terrestrial
work locations including laydown fauna/
fauna
areas.
particularlyinsensitive ecologicalareas.
Invasive species.

Terrestrial
fauna.

fauna

6. Waste Management and Construction Material
Disposal of solid or liquid waste. Environment.

December 2021/

Assessment of
Risk

Mitigation Summary

PostMitigation
Residual
ImpactC

L Rating

Ground disturbance leading to runoff ofcontaminants (e.g., soils, hydrocarbons,
cement, etc) in stormwater and depositionon downstream sensitive ecologicalenvironment.
Direct loss of habitat and/or resources infootprint of bridges / causeway.
Loss of endemic and/or protected species.

3

A

H

In addition to the mitigation proposed for water quality,
mitigation measures are to include identifying andplugging all discharge points, ensure upstream and owns
fish migration is not impeded, and design crossings(including bridges, culverts and causeways) to avoid
disturbance of sensitive habitat (e.g. mangroves, sea
grass etc) where possible. Where it is not possible aplanting regime is to be implemented to restore the lost
habitat.

L

Direct loss of habitat in construction
footprint or disturbance of terrestrial faunaand fauna

3

A

H

Contractor to implement site-specific ESMP detailingprocedures to minimize footprint and disturbance ofterrestrial fauna and fauna particularly in sensitive
ecological areas.

L

Introduction of invasive aquatic and / orterrestrial pest / weed species as a resultof construction activities.

4

B

M

Imported aggregates to be sourced from weed freelocations.
Washing of work vehicles.
Exposed soil to be reseeded and revegetated.

L

Uncontrolled disposal of solid or liquid
waste material into the aquatic and / orterrestrial receiving environment.

3

A

H

The Contractor to prepare a Waste Minimization andManagement Plan (WMMP), to cover all aspects of generalwaste generation, storage, disposal and reuse.
Workers to have access to rubbish receptacles, whichallow for the collection and segregation of wastes.
Solid wastes to be collected and disposed of at an
appropriately licensed disposal facility. Paper, bottles andcans shall be transported to local recycling facilities, if
available.

L

Final Draft

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Activity

Source of Risk

Description of Potential Impact

Assessment ofRisk
C

L Rating

Use of aggregate materials inconstruction activities.

Environmental risk.

Use of material from non-sustainablesources (i.e., coastal sand and coral reefmaterials).

1

B

E

Waste materials generated
duringroad
construction
activities.

Disposal of wastematerials.

Pollution arising from disposal of wastematerials at unlicensed facilities.

2

A

E

Permanent loss of land or assets, or
restricted land use due to land accessrequirements for project works.

3

A

H

7. Land and Access Restrictions
Permanent loss of land and non- Land and asset
land assets.
owners and users.

December 2021

Final Draft

Mitigation Summary
Only material from licensed local or international landbased sources (i.e., quarries) to be used (i.e. no coastal
sand and coral reef / rock to be used).
Where licensed local quarry sites do not meet compliancerequirements, they should develop and implement site
specific ESMP in line with relevant WBG EHS guidelines
for construction material extraction.
The Contractor shall provide a record of the quarry license
approval from aggregate suppliers (i.e. issued by
EPA/KIRMA) prior to start of construction.
The Contractor shall prepare a WMMP, to cover all
aspects of construction waste generation, storage,
disposal and reuse.
Road material that cannot be reused shall be transported
and/or stockpiled off-site for use on unsealed roads, ordisposed of at an appropriately licensed disposal facility.
Implementation of any construction related measures set
out in the land access procedures (e.g. Land Access Due
Diligence report, Voluntary Land Donation report or
Resettlement Plan), including consultation requirements
set out in the RF and SEP.
Contractor is to consult with the owners of the assets that
require relocation in order to determine the mostappropriate re-siting the affected infrastructures, andundertake relocation where appropriate.
Should unexpected impacts occur to land or assets as aresult of construction activities, community grievances areto be addressed through the Grievance Mechanism.

PostMitigation
Residual
Impact
M

M

L

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Activity

Source of Risk

Description of Potential Impact

Assessment ofRisk
C

L Rating

Mitigation Summary

Temporary loss of land and/or
permanent loss of non-landassets such as crops, fences,ornamental gardens, etc in roadalignment, laydown areas or
temporary diversion roads.

Asset owners.

Impacts due to construction affecting
private property or restricting access.
(Impacts that fall under construction
method for which the contractor is
responsible for determining).

3

A

H

Land required for construction facilities is to be secured by
the Contractor as required, via VLD if suitable. If no VLD
then lease agreement is to be negotiated and agreed
between the civil works Contractor and the land ownerprior to mobilization, and rental allowance to be provided if
appropriate (in accordance with RF).
At end of rental period, any temporarily acquired land is tobe rehabilitated to a pre-works condition or in a condition
acceptable to the land owner.
Should unexpected impacts occur to land or assets as aresult of construction activities, community grievances areto be addressed through the GM.

Disruption of road access forusers due to crossing works (e.g.
replacement of bridges / culverts/ causeways.

Road users.

Permanent or temporary loss or restrictionof access for road users / local community.

3

A

H

Contractor to maintain road access throughout
construction (i.e. alternative route(s) / crossing(s) aremade available).
The local community is to be informed of the upcoming
works (including maps, dates and times of operation)
through letter drops to all adjacent properties, and theinstallation of signage (as per SEP).
TRSMP to be implemented and adhered to throughout
construction.
Any road user complaints to be to be addressed throughthe GM and complaints register.

December 2021

Final Draft

PostMitigation
Residual
ImpactL

L

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Activity

Source of Risk

Description of Potential Impact

Assessment ofRisk
C

L Rating

Disruption of access to adjoining
properties due to works.

Residential
andcommercial
properties, and otherland owners.

Temporary restriction on access to, or useof, adjoining privately owned land adjacent
to works.

3

A

H

Disruption to Existing Services

Utility Providers
local community

Disturbance of underground or overhead
utility infrastructure resulting in a disruptionof services.

3

A

H

December 2021/

Final Draft

Mitigation Summary
Contractor to maintain access to adjoining properties
throughout construction.
Vehicular and pedestrian access to adjacent properties
and adjoining roads shall be maintained throughout
construction except for essential works where temporary
closure shall be minimized.
Any road closures are to be undertaken and managed inaccordance with the DoTC&I standard practices.
TRSMP to be implemented and complaints addressed
through the GM.
Contractor to engage with service providers prior to works
commencing to confirm the likely presence and locationsof services and develop a plan for minimizing disruption of
any services.
The Contractor shall be liable for any services disrupted asa result of the construction works.

PostMitigation
Residual
ImpactM

L102

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Environmental and Social Management Framework

Activity
8. Traffic Safety
Movementof
construction
vehicles.

Source of Risk

Local Community /Contractors/
Pedestrian&
Vehicular Traffic.

Description of Potential Impact

Potential human hazards due tomovement of vehicles and machinery on
all roads and potential for increase
accident risk around work areas.
These risks could include increased
traffic congestion, risk of traffic incidents,
and general road safety issues (such as
road crossing by pedestrians).
Disruption of key transportation networks(i.e. replacement of bridge or causeway)
could pose significant delays in journey
times and overall inconvenience to road
users.

Assessment ofRisk
C

L Rating

1

B

E

Mitigation Summary

Contractor to implement TRSMP in consultation with
DoTC&I and State representative agencies, which will
include as a minimum:Controlled crossing points for local community;Construction activities to be restricted to relevant
State working hour requirements;

Regular consultation with roadside residents as per
the SEP;

Implementation of strict speed limits in settlement
areas;



Project vehicles to be equipped with warning lights toensure high visibility to other road users;

Traffic control supervisor to be used;

Alternative routes and/or temporary crossings to be
identified;Strong enforcement of Project regulations regarding
drug and alcohol use and levels of fatigue; andPostMitigation
Residual
ImpactM

Implementation of GM during the Project to ensurecommunity concerns or issues are addressed.
Contractor to communicate TRSMP to local community as
described in the Stakeholder Engagement Plan (SEP) andworks specific ESMP’s.

December 2021

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Activity

Source of Risk

Description of Potential Impact

9. Use and Accommodation of Imported Labor (if required)
Use and accommodation of Local community.
Environmental (increased pressure on
imported labor.
existing natural resources) economic andlivelihoods (inflationary pressures,
exacerbate vulnerability of marginal
groups, etc.), infrastructure and services
pressure, health (potential increases inviolence, alcohol/drug consumption,
sexually transmitted diseases, etc.), andsocial and community wellbeing.

Assessment ofRisk
C

L Rating

3

A

H

Mitigation Summary

Establish/form stakeholder committee(s), where future
work plans, site requirements, labor and material
requirements and problems are discussed, in order toprioritize employment of locals, where appropriate.

PostMitigation
Residual
ImpactM

Implement Social Interaction Plan (SIP), including
undertaking weekly toolbox meetings with all site workers
on culture, tradition, custom and expectations of local
communities.
Transparency and open communication with thecommunities on issues that affect them.
Any imported labor related issues to be addressed throughthe GM and complaints register.

10. Labor Management
Use of underage people.

Contracted workers.

Use of people under the age of 18 inhazardous Project activities.

3

A

H

Contractor agrees to contract provisions that require nopeople under the age of 18 are to be employed inhazardous activities.

L

Implementation of the projects Labor Management
Procedures (LMP).
Forced labor.

Contracted workers.

Use of forced labor on the Project.

3

A

H

Contractors confirm that they are not using forced labor.

L

Where employment occurs directly with Government,
employees are not considered forced by virtue of the fact
as they have signed a contract.
Implementation of the projects Labor Management
Procedures (LMP).

December 2021

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Activity

Source of Risk

11. Cultural Heritage / Archaeology
Sites, features or artifacts of Cultural heritage.
cultural,archaeologicalor
historical significance.

Description of Potential Impact

Physical disturbance of cultural,archaeological or historically significant
sites (e.g. grave sites, historical artifactsetc) due to proposed construction
activities.

Assessment ofRisk
C

L Rating

3

A

H

Mitigation Summary

Sites in close proximity to the works are to be mapped andcommunicated to the Contractor workers to minimize risk of
disturbance.

PostMitigation
Residual
ImpactL

Should sites of cultural, archaeological or historicalsignificance be deemed at risk of indirect disturbance as aresult of Project activities, the CIU in consultation withgovernment/communities/traditional
leadersandlandowners are to develop strategies to protect these sites
in consultation with the local community and the relevant
State Government department.
A chance find procedure is to be implemented should
physical cultural resources be uncovered during
construction.

12. Health and Safety

December 2021

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Activity
Worker Health & Safety.

Source of Risk
Construction
workforce.

Description of Potential Impact
Potential injury to workers as a result ofconstruction activities.

Assessment ofRisk
C

L Rating

3

A

H

Mitigation Summary
Contractor to comply with the FSM Labor Code, an informall employees of their rights.

PostMitigation
Residual
ImpactM

Contractor to prepare and implement an OHSP which is tobe approved in writing by the PIU prior to commencing
works, and train workers in its content.
Contractor to conduct training for all workers on the OHSP
and health and safety matters as required by goodengineering practice.
Workers to be provided with appropriate PPE suitable forcivil work such as safety boots, helmets, gloves, protective
clothes, goggles and ear muffs for protection (asappropriate) at no cost to the workers.
Contractor to provide potable water supplies, first aid
facilities, a toilet and hand washing facilities at works sites.
All workers required to sign a Code of Conduct (CoC)
which outlines acceptable behavior for the workers andtheir role, including reference to GBV, SEA/SH.

December 2021

Final Draft

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Activity
Community Health & Safety.

Source of Risk
Local community.

Description of Potential Impact
Potential issues arising to local
community as a result of construction
activities in the vicinity of the works sites,
including risks associated with imported
labor.

Assessment ofRisk
C

L Rating

3

A

H

Mitigation Summary
Contractor to consult with adjacent landowners prior tocommencement of work on site, as directed by the SEP.

PostMitigation
Residual
ImpactM

Temporary signage and boundary fences are to be used
to deter pedestrian access into construction areas, andinform the community of works activities, timing and the
GM process.
Implement Traffic Management plan, road safety plan,
Health and safety plans including training of all workers
and use of PPE.
Contractor OHSP to include the requirement to educate allsite staff on the prevention and treatment ofcommunicable diseases including filariasis, dengue, zika,
hepatitis, HIV/AIDS and Covid-19.
The Contractor and all workers (including imported labor)
associated with the Project are to comply to FSM nationaland State Covid-19 health and safety management plans,
and international WHO standards, and include Covid-19
provision in the OHSP.
All contractor site staff required to sign a Code of Conduct

December 2021

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Table 5-7: Outcome of Assessment of Key Operational Phase Risks Component 2 Physical Works for PRIME and SCORE projects.

Activity

Source of Risk

1. Surface and Groundwater Quality
Discharges from operational Surface waters andsurfaces.
groundwater aquifers.

2. Flooding
Road flooding.

3. Road Integrity
Road Integrity.

4.

Description of Potential Impact

Assessment of Risk
C
L Rating

Mitigation

Post-Mitigation
Residual Impact

Introduction of road activity contaminantsfrom operational surfaces.
New pathways for contaminants, including
refuse (e.g. trash, plastic bottles/bags, etc) toenter waterbodies.

3

A

H

Regularly maintain and clear drainage
channels, culverts and stormwater
control features installed as part ofconstruction phase (e.g. catchpits), to
prolong life of infrastructure.

L

Road users andproperty owners.

Overflow of drainage systems due to poor
maintenance affecting road users andproperty owners.

3

A

H

Regularly maintain and clear drainage
channels, culverts and stormwater
control features installed as part ofconstruction phase (e.g. catchpits), to
reduce the potential for site inundation(i.e. flooding) during extreme weather
events, and prolong life of infrastructure.

L

Erosion.

Compromised road integrity due to water
movement creating erosion issues as a resultof upgrades / sealing of roads.

3

A

H

Regularly maintain and clear drainage
channels, culverts and stormwater
control features installed as part ofconstruction phase (e.g. catchpits), to
reduce the potential for site inundation(i.e. flooding) during extreme weather
events, and minimize erosion risk.

L

Road users and local
community.

Increase in accidents relating to increased
speeds on roads.

3

A

H

Evaluate potential for installation of
traffic calming devices in villages andbarriers on corners, speed signs, etc.

L

Health and Safety

Road Safety.

Consult with Police to enforce speed
limits.

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Activity

Source of Risk

Description of Potential Impact

Transport noise during operation.

Local community.

Increase of traffic noise from increased
speeds on roads.

Assessment of Risk
MitigationC
L Rating
3
A
H
Evaluate potential for installation of
traffic calming devices in villages andbarriers on corners, speed signs, etc

Post-Mitigation
Residual Impact
L

Consult with Police to enforce speed
limits.

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5.9

Environmental and Social Sensitivities Maps
To assist with identifying potential areas where impacts on environmental and social values
may arise from the PRIME and SCORE Projects, data from the PRIME primary (field
investigations) and secondary sources (primarily GIS data) for a range of parameters
including hazards in Section 4.3 have been mapped (see erosion and flooding), sensitive
receptors and identified road corridor assets (described below). During the PRIME primarydata collection program additional a number of strategic secondary roads were included.
These roads are indicative examples of secondary roads that may be included in the
SCORE project through the VA/CRRS studies.

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Figure 5-1 to Figure 5-4). The information used in these maps is provided in Appendix B.
Identifying areas of environmental and social risk assists with the early screening of areasof potential concern from an environmental and social perspective. Based on key attributes
outlined in an assessment of level of sensitivity for each state has been undertaken (Table
5-9 to Table 5-12).
Figure 5-1 to Figure 5-4 identify areas considered to be of ‘Medium’ or ‘High’ environmental
and social sensitivity depending on the nature of the works proposed. Note these locations
are considered indicative only and require further investigation.
Where areas are identified as ‘High’ sensitivity, engineering design may be required (whereappropriate) to avoid or minimize potential impacts. Potential impacts in relation to‘Medium’ sensitivity areas can be managed through implementation of mitigation
measures.
Table 5-8: Key environmental and social attributes enabling assessment of level of sensitivity

Sensitivities

High

Mediuma. Higher density of important assets (e.g.
residential houses, businesses, fences
walls, fruit trees, etc) located in roadeasement;b. Watercourse / culvert upstream of
biologically significant CMA area;c. Erosion / flood risk hazard zone;
d. Populated area

2 or 3 of the 4 attributes
required

1 of the 4 attributes
required

Further investigation required
to confirm potential impacts.
Risks to be aware of rather
than necessary limit works
from proceeding.

Impacts can be managed
throughsuitable
engineering design.

Notes:

Table 5-9: ‘High’ sensitivity areas - Kosrae

E&S Sensitivity

Box No.
1, 9, 102, 3
3
4
5, 6, 7, 8
11

Watercourse / culvert / bridge upstream or in biologically significant area; Erosion / floodrisk hazard zone; Important assets.
Watercourse / culvert / bridge upstream or in biologically significant area; Important
assets.
Watercourse / culvert / bridge upstream or in biologically significant area; Erosion / floodrisk hazard zone.
Watercourse / culvert / bridge upstream or in biologically significant area; Erosion / floodrisk hazard zone; Populated area.
Watercourse / culvert / bridge upstream or in biologically significant area; Erosion / floodrisk hazard zone; Important assets; Populated area.
Erosion / flood risk hazard zone; Important assets; Populated area.

Table 5-10: ‘High’ sensitivity areas - Pohnpei
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E&S Sensitivity

Box No.
1, 11, 16
2, 3, 4, 5, 6,
7, 8, 9, 10,
12, 15, 18, 19
11,
13

Watercourse / culvert / bridge upstream or in biologically significant area; Erosion / floodrisk hazard zone; Important assets.
Watercourse / culvert / bridge upstream or in biologically significant area; Erosion / floodrisk hazard zone. The road adjacent to the UNESCO heritage area “Nan Madol”.
Watercourse / culvert / bridge upstream or in biologically significant area; Erosion / floodrisk hazard zone; Important assets.
Erosion / flood risk hazard zone; Important assets.
Watercourse / culvert / bridge upstream or in biologically significant area; Important
assets.

16

Table 5-11: ‘High’ sensitivity areas - Chuuk

E&S Sensitivity

Box No.
1, 2, 3, 4, 5
5, 6

Watercourse / culvert / bridge upstream or in biologically significant area; Erosion / floodrisk hazard zone; Important assets.
Erosion / flood risk hazard zone; Important assets.

Table 5-12: ‘High’ sensitivity areas - Yap

Box No.
1-8
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E&S Sensitivity
Watercourse / culvert / bridge upstream or in biologically significant area; Erosion / floodrisk hazard zone.
Watercourse / culvert / bridge upstream or in biologically significant area; Erosion / floodrisk hazard zone; Important assets.

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2
1

4
3
5
6

7

8

9

11

10

Figure 5-1: Key E&S sensitivities on Primary and Secondary Road network – Kosrae (showing ‘high’ (red box) and ‘medium’ (orange box) sensitivities)

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1

19

2

18

17

16
15

3

4
5

14
13

12

11

6
10
9

8

7

Figure 5-2: Key E&S sensitivities on Primary and Secondary Road network – Pohnpei (showing ‘high’ (red box) and ‘medium’ (orange box) sensitivities).

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4

2
3
1

5

6

Figure 5-3: Key E&S sensitivities on Primary and Secondary Road network – Chuuk (showing ‘high’ (red box) and ‘medium’ (orange box) sensitivities).

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1

5
6

4

1

7

2
3

8

9

Figure 5-4: Key E&S sensitivities on Primary and Secondary Road network – Yap (showing ‘high’ (red box) and ‘medium’ (orange box) sensitivities).

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6.

Risk Management Procedures for Component 2
Works for PRIME and SCORE Projects

6.1

Environmental and Social Risk Screening
Once the climate resilient road works have been identified and prioritized for FSM as partof the PRIME funded VA and CRRS studies, two rounds of environmental and social
screening are to be undertaken by the CIU Safeguard Team (supported by environmental
and social consultants engaged by the PIU, as required) as part of the feasibility and design
process for Component 2 works of both projects. This screening process is outlined below:
1) Initial E&S Risk Screening (activity selection both projects / prioritization
works under PRIME) - an ‘Initial E&S Screening Form’ (Appendix C, Form 1) is tobe completed which identifies potential high-level environmental and social risks
and impacts of the proposed works using the Australasian Standard from Section
5.8 of this ESMF. Any extreme risks would require additional work to be determine
whether it could prevent the identified works from being implemented under the
PRIME and SCORE Projects.
2) Detailed E&S Screening (during preliminary design) –A second round of risk
assessment on the proposed road works is completed using Forms 2 (a and b)
and 3 in Appendix C. From this assessment, the road works sub-project will be
rated, based on World Bank ESF Risk Ratings10. The ESF Risk Ratings ofModerate, Substantial and High are based on four elements:
a. Sensitivity of the environment and social receptors and scale of the physicalworks, operations, demand for resources, creation of waste and emissions,presence of Indigenous Peoples, sensitivity of vulnerable peoples;b. The nature and magnitude of impacts (duration, intensity, reversibility,
complexity) and possibility of mitigation measures;
c. Capacity of the PIU and CIU, FSM legislation and availability of resources tomanage E&S risks;d. Contextual risks –COVID-19, geography of the four states and remotenessfrom markets for expertise, equipment or services;
The ESF Risk Ratings will be applied using the WB E&S Directive for Investment Project Financing,using the activity risk ratings from Forms 2 and 3 as follows:

Outputs from Screening Forms 2 & 3.

World Bank ESF Project Risk Rating(Activity-based risk assessment using
Australasian Standards from Section 5.8 –Moderate or Low except as identified below)(Highest risk rating applies)

Large Scale Earthworks are High or Extreme
risk (unmitigable).

Substantial

Biodiversity or cultural heritage risks areHigh (unmitigated).

Substantial

10 World Bank. 2019.

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Biodiversity or cultural heritage risks are
Extreme (unmitigable).

High

Issues with land, assets and/or livelihoods
that may lead to social conflict, assessed as
High or Extreme risk.

Substantial

Large scale impacts on land owners andoccupiers and asset owners/users assessed
as Extreme riskHigh3) Screening Report – preparation of an ‘E&S Screening Report’ after the works arefurther defined as part of the preliminary design process to feed into the design
and impact mitigation process. This report is to include:a. An outline of the Project environmental and social risk screening process;b. Completed ‘Environmental and Social Screening Forms’ (Appendix C,
Forms 2 to 4);c. A summary of the World Bank ESF Risk Rating (Moderate, Substantial,High);
d. A summary of the findings of the screening process, (as directed by the
Appendix C, Form 3 – E&S Assessment and Management Plan
Requirements; and Form 4 – Agreed E&S Documents); ande. Recommendations for the environmental and social assessment andpreparation of environmental and social risk management instruments.
The E&S Screening Report will be prepared by the CIU Safeguards Team (supported byenvironmental and social consultants engaged by the PIU, as required) and submitted
together with the feasibility study report to the WB for review and clearance.
On the basis of the environmental and social screening, the Project will adopt one of thefollowing approaches:4) Further redesign of the works to avoid/minimize environmental and social
impacts including potential land and/or asset loss where practical (in which case
the E&S Screening Report will need to be prepared again, after completion of theredesign). The design team, PIU, environmental and social consultants (ifrequired) and CIU Safeguards Team are to work together to identify risks andmitigation measures in design in compliance with the WB ESS, ESMF, EHS
Guidelines and Good International Industry Practice.
5) Implementation of the Generic ESMP in the event of Moderate World Bank ESF
Risk Rating works the generic ESMP is to be used.
6) Preparation of a works specific ESIA) and ESMP if works are assessed as
Substantial or High Risk using the World Bank ESF Risk Rating. This is to beprepared in parallel with detailed design and finalized in time to be included in thebid documents.
The E&S screening process is illustrated in the flow chart in (Figure 6-1). The scope ofthese documents is outlined in Section 6.2 below.

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Figure 6-1: E&S screening process.

The PRIME and SCORE Projects will also emphasis a ‘participatory design approach’
whereby the design of road improvements will prioritize works within the corridors ofexisting primary and secondary roads and minimize avoidable environmental and social
impacts such as loss of private property, where technically feasible. This approach will
provide potentially affected persons and communities and stakeholders an opportunity toparticipate in the decisions related to the design of road improvements that affect them(discussed further in the RF).
The E&S Screening Report will be prepared by the CIU Safeguards Team (supported byenvironmental and social consultants engaged by the PIU, as required) and submitted
together with the feasibility study report to the WB for review and clearance.

6.2

Preparation of ESIA/ESMPs

6.2.1

Generic ESMPA Generic ESMP is being developed under PRIME to be used for road works sub-projects
screened as having ‘Moderate’ risk (using the WB ESF Risk Rating), with works largely
contained the existing primary and secondary road corridors (such as road resurfacing,drainage improvements, installation of culverts, slope protection etc), and in locations
without high E&S sensitivities identified in Sections 5.9. .
Given the majority of PRIME and SCORE project Component 2 works are expected toresult in ‘Moderate’ risk the Generic ESMP is expected to be suitable for many of theComponent 2 works.
If works are screened as ‘Substantial’ or ‘High’ risk during E&S screening (using the WB
ESF Risk Rating) then a works specific ESA and ESMP will be required. The triggers forrequiring a works specific ESIA/ESMP are set out in the Environmental and Social
Screening Forms (provided in Appendix C, Forms 1-4).

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6.2.2

Works Specific ESIA and ESMPIn the event that potential works impacts are extensive and/or extend beyond the roadcorridor with a corresponding risk rating of ‘Substantial or High’ a works specific ESA
and/or ESMP is to be prepared.
Depending on the nature and scale of Component 2 works proposed for both projects, it
may be necessary for an ESIA to be prepared, to adequately develop appropriate
mitigation measures for the potential works impacts, including the potential preparation of
additional technical studies in order to inform the impact assessment. The exact scope of
the ESIA will depend on the nature and extent of potential impacts. An ESIA will be
required for any works screened as ‘High’. Adequate contingency funds to prepare ESIAs
should they be required has been included in the project budget.
An example of this could be improvements to Lelu Causeway in Kosrae under PRIME
which has been identified as one of the ‘urgent works’ under Component 2a. Due to thecauseway being the only practical access to Lelu township and potential for substantial
impacts on the coastal and marine environment if works are not undertaken in an
appropriate manner.
Should the E&S screening determine that an ESIA is required for the Component 2 works
then it should adhere to the indicative outline included in ESS1 – Annex 1.D as well as incompliance with FSM National and State Environmental Legislation and Regulations. As
a minimum the ESIA should include the following key elements:(i)

Executive Summary;(ii) Description of the road works;(iii) Baseline Data;(iv) Environmental and Social Risks and Impacts;(v) ESMP including Mitigation and Monitoring Measures; and(vi) Analysis of Alternatives.
Additionally, the works specific ESMP is to be broadly consistent with the structure of theGeneric ESMP, where relevant, and include as a minimum:(i)

Mitigation Measures;(ii) Monitoring Requirements;(iii) Capacity Building and Training;(iv) Implementation Schedule and Cost Estimates; and(v) Integration of the ESMP with other Project documents and Plans
Should a works specific ESIA/ESMP be required, the PIU may need to engage an external
E&S consultant to prepare these documents on its behalf and overseen by the CIU
Safeguards Team. Resources to engage E&S consultants have been secured by the
project.
The works specific ESIA/ESMP should also be prepared alongside, and integrated with,the design process, participatory design approaches, stakeholder engagement, and any
Land Access Procedures Plan/s required (such as the Land Access Due Diligence Report,
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Voluntary Land Donation Report or Resettlement Plan), as set out in the RF, as required
on a works specific basis.
In order to achieve the best outcome, the ESMP will need to be prepared in an integrated
way with the design consultant and with land access agreements. This would need to be
an iterative process where the ESMP informs design occurring concurrently with the design
process.

6.3

Civil Works Contractor Requirements

6.3.1

Environmental,
Documentation

Social,Healthand

SafetyClausesin

Bid

Environmental and social, health and safety clauses are to be incorporated in DoTC&I bid
documents for contracted works.
The CIU Safeguards Team will be responsible for the oversight of the environmental,social, health and safety activities of the Contractor will review draft bid documents andwill conduct periodic on-site visits to monitor and supervise progress.

6.3.2

Contractor Environmental and Social Management Plans
Contractors will be required to prepare Construction Environmental and Social
Management Plans (CESMP) to cover the environmental, social, health and safety risks
associated with work they are responsible for. Depending on the nature and scale ofworks, the CESMP will require some or all of the following topics. Where mitigation will be
extensive, due to complexity or scale, sub-plans may be prepared and implemented.
Mandatory topics to be covered incude;














Erosion and Sediment Control Plan (ESCP).
Surface Water and Groundwater Management Plan (SWGMP).
Pollution Prevention and Control Plan (PPCP).
Waste Minimization and Management Plan (WMMP).
Spill Management Plan (SMP).
Traffic and Road Safety Management Plan (TRSMP).
Labor Management Procedures (LMP).
Social Interaction or Community Engagement (including GBV action plan) Plan.
Community Health and Safety Plan (CHSP).
Occupational Health and Safety Plan (OHSP).
Emergency Management and Response Plans.
Subcontractor Management.
Monitoring and Reporting procedures.

Topics to be covered if required by the Works ESMP include;






6.4

Quarry Management.
Subcontractor Management.
Biodiversity Management.
Cultural Heritage Management.

Implementation of ESMP and CESMP
The design engineers, DoTC&I and other implementing agencies are to implement therelevant sections of the ESMP during feasibility, design, project prioritization, landownernegotiations and other activities. The Contractor is responsible for implementing the
CESMP. Supervision of the implementation of the ESMP and CESMP by the Contractor
will be carried out by a Design and Supervision consultant reporting to the PIU with training,oversight and auditing by CIU Safeguards Team.

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6.5

Risk Management for Technical Advisory Activities
The process for screening and assessing environmental and social risks is as follows:
1. CIU Safeguards Team reviews all TOR and provides the required clauses or scopeof work for the TA to comply with the WB ESS, the ESMF, RF, SEP, LMP and allother instruments for both projects.
2. CIU Safeguards Team assists in the evaluation of consultants or contractors forTA that includes E&S risk assessment or mitigation, to ensure that theteam/individual has the correct skills and experience.
3. CIU Safeguards Team reviews draft and final technical outputs against the ESS,
the ESMF, RF, SEP, LMP and all other instruments and make any
recommendations to the PIU for improvements or changes for both projects.
4. CIU support consultations to ensure they are consistent with the projects’ SEP.

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7.

Stakeholder
Participation

Engagement,

Consultation

andStakeholder engagement will be undertaken throughout the PRIME and SCORE Projects
including planning and design, construction and post construction phases (i.e., operation)
for all specific Component 2 works to be implemented under the PRIME and SCORE
projects, the SCORE component 3 Material testing laboratory and for all technical advisory
activities under Component’s 1 and 3 for PRIME and Component’s 1, 3 and 4 for SCORE
where relevant.
The stakeholder engagement process for the broader PRIME and SCORE projects aredescribed in detail in the projects combined SEP including stakeholder engagement
undertaken to date as part of Project preparation and those required throughout the PRIME
and SCORE projects.
Set out below is a summary of key considerations regarding stakeholder engagement
relevant to the ESMF.
A wide range of stakeholders have been identified for consideration throughout both
Projects (outlined in the SEP).
Each Component 2 works will have a discrete list of stakeholders identified and engagedwith:Land Owners and Occupiers – called Project Affected Persons (PAPs) under ESS5.



Local Communities (including nearby or indirectly affected villages, community
interest groups, road users, disadvantaged and vulnerable individuals or groups, etc)
and their traditional / community leaders.



Relevant Municipal and State Government departments and agencies.



Others (including NGOs, CBOs, businesses, utility providers etc).

A variety of mechanisms will be utilized to consult with the identified stakeholders during
implementation of the ESMF including:(i)Village meetings involving women, men and youth from communities;(ii) Separate meetings with specific interest groups and their representatives as
required (including women, youth, senior, religious, vulnerable households,
conservation groups, NGO/CBOs);(iii) Key informant interviews with relevant government staff (e.g. EPA/KIRMA) andcommunity/traditional leaders;(iv) Environmental NGOs and community groups interested in environmental andmatters; and(v) Informal conversations with passers-by, transport users and other interested
parties near the works site.
To ensure broader participation consultations are to be undertaken at venues, times andin language that do not disadvantage any particular groups (e.g. women, or vulnerable
households).

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Vulnerable groups are to be targeted through representative organizations including
women, disability and youth associations. Remote communities which are often low
income will be included through their traditional (e.g. chiefs) and formal representatives(e.g. senators).
Other considerations to be taken into account through the stakeholder engagement
process for both Projects are outlined in detail in the SEP.
Should grievances arise from technical advisory, design, institutional strengthening,
construction or operation impacts from activities associated with the PRIME and SCORE
Projects, a Grievance Mechanism (GM) has been developed through which affectedparties can resolve such issues in an efficient, unbiased, transparent, confidential timely
and cost-effective manner. This GM is outlined in the PRIME and SCORE Project RF and
SEP.
Consultations with stakeholders were undertaken during the preparation of the Project andrelevant E&S instruments, including the ESMF. Below lists the number of stakeholder
representatives from government, non-government, private sector, and civil society groups
during PRIME and SCORE preparations.
PRIME. A total of 108 stakeholder groups and members were engaged as part of the
Project preparation engagement activities across the four States, including:

National – 4 Government;

Kosrae – 17 Government; 15 Community groups; 7 ‘Other’ stakeholders;

Pohnpei – 10 Government; 2 Community groups; 2 ‘Other’ stakeholders;

Chuuk – 22 Government; 3 Community groups; 6 ‘Other’ stakeholders; andYap – 4 Government; 12 Community groups; 4 ‘Other’ stakeholders.

Differences in the number of certain types of stakeholders engaged in each State are inpart due to how organized and engaged certain stakeholder groups were, and how
effective community leaders were in bringing the stakeholders together. Additional effort
may be required during Project implementation to engage certain stakeholder groups if
they are identified as being potentially impacted by the physical works. This is similar withthe situation for SCORE.
SCORE. A total of 74 stakeholder groups were consulted as part of the project preparation
engagement activities across the for States, including:

National – 6 Government;

Kosrae – 6 Government; 2 Community groups; 4 ‘Other’ stakeholders;

Pohnpei – 10 Government; 2 Community groups; 8 ‘Other’ stakeholders;

Chuuk – 10 Government; 6 Community groups; 3 ‘Other’ stakeholders; andYap – 3 Government; 4 Community groups; 10 ‘Other’ stakeholders.

A total of 56 consultation meetings were held both for both PRIME and SCORE projects.
This included 42 consultation meetings for the PRIME project from 30 of July 2020 to 12
November 2020 and 14 for SCORE form 27 October to 2 November 2021. Information
presented, and feedback provided by the stakeholders along with how the issues are
addressed by the project are set out in the SEP. A summary of stakeholder engagement
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activities undertaken in outlined in SEP Appendix C, while consultation meeting minutes
are provided in SEP Appendix D.
The final draft of the ESMF, along with the other E&S Instruments, was made available by
DoTC&I to key stakeholders in each State to review and provide comment prior to the
documents being finalized. The ‘final’ ESMF as well as respective ESIA and ESMPs willbepublicly
disclosedontheWB
website(www.worldbank.org
andhttps://projects.worldbank.org/en/projects-operations/documentdetail/P172225?type=projects) as well as relevant FSM government websites(http://www.dofa.gov.fm/world-bank-projects/).
In addition, Stakeholders are to be regularly informed and updated on the PRIME and
SCORE Projects throughout by way of consultation meetings and public notices (e.g. radio,
newspaper etc, as appropriate), and signs and/or notice boards are to also be erected at
the works site. Details of disclosure activities and requirements are set out in the SEP.

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8.

Institutional Arrangements, Responsibilities and
Implementation

8.1

Institutional Responsibilities and Structures
Compliance with ESS will require the full participation of Project relevant implementing
agencies in collaboration with National, State and Municipal Government Officials. The
responsibility to implement all commitments in the PRIME and SCORE ESMF along with
the Generic ESMP (when finalized) or any works specific ESIAs/ESMPs prepared will be
distributed between these stakeholders. Estimated resourcing requirements andcorresponding budget for both projects safeguard requirements are detailed in section 9.
The relevant institutional structures to be established and utilized for the PRIME and
SCORE Projects including roles and responsibilities are shown in Figure 8-1 and described
below.

Figure 8-1: Implementation arrangements for the PRIME and SCORE Projects.

8.1.1

Coordination among the National and State Governments andDepartments
The PRIME and SCORE projects are designed to work with the National GoFSM, the four
State Governments and will be implemented over a five-year period following project
effectiveness. DoFA is the Executing Agency (EA) while the National DoTC&I is the
Implementing Agency (IA) working closely with each of the four States.
As the PRIME and SCORE Roads fall under the jurisdiction of the relevant State
Governments, Project Implementation Agreements (PIAs) with each of the States will also

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be required to help govern the PRIME and SCORE project activities in each State, with
one PIA for each of the following groups:(a) National DoTC&I, Kosrae State Government and Kosrae Department of Transportand Infrastructure;(b) National DoTC&I, Pohnpei State Government and Pohnpei State Office ofTransport and Infrastructure;(c) National DoTC&I, Chuuk State Government, and Chuuk State Department ofTransport and Public Works; and(d) National DoTC&I, Yap State Government, and Yap State Department of Public
Works and Transportation.
PIAs are required executed prior to the commencement of Project activities underComponent 2 to ensure agreement between all relevant parties on implementation roles
and responsibilities as well as to ensure that required coordination arrangements within
the states are in place. PIAs have been established with each State for PRIME andeffecting the PIAs for SCORE is in progress as of date of preparation of the ESMF. ThePIU and the States are required to establish PIAs for SCORE prior to commencement of
SCORE component 2 activities.
As each road authority is under its respective State’s control and to ensure good technicalcoordination, focal points have been appointed in each State to work on and manage dayto-day PRIME and SCORE activities associated with its land transport sector and to liaise
with the National DoTC&I. This will include assisting the CIU safeguard team with thecoordination of stakeholder meetings, data and information collection, communication
activities and general E&S activities. The CIU safeguard team will provide training andsupport to these positions.
Within the National GoFSM, DoTC&I has a Project Management Unit (PMU) that has
responsibility for the delivery of Overseas Development Assistance (ODA) funded
infrastructure projects (including the World Bank, Asian Development Bank, United States
Federal Aviation Administration, People’s Republic of China and the United Nations) withthe exception of energy (managed by the Department of Resources and Development) andtelecommunications (managed by the DoTC&I Communications Division). The primary
focus of the PMU is on program management with day-to-day project management tasksdeferred to project implementation units.
A PRIME and SCORE joint PIU will be established within DoTC&I. All contracts with
consultants, contractors and suppliers will be signed by the DoTC&I Secretary with theadministration and contract management tasks of the contract being implemented by thejoint PIU as their day to day responsibility. The DoTC&I Secretary will sign off on all
consultant and contractor invoices and authorize CIU to make payments.
During project implementation, the DoFA Centralized Implementation Unit (CIU)
Safeguards Team will assist DoTC&I with the environmental and social aspects.
Both the CIU and DoTC&I are existing units, and are familiar with WB ESF and projectspecific environmental and social risk management instruments from their experienceswith other WB-funded projects. The CIU has been able to carry out its environmental andsocial functions in a satisfactory manner and in close coordination with the WB. The
capacity of the CIU will be strengthened with the recruitment of an international social
safeguards specialist. The DoTC&I, through the PIU and project manager coordinate
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closely with the CIU safeguards team. DoTC&I and PIU will be provided with environmentand social risk management capacity building training from early in project implementation.

8.1.2

PIU
The PIU will coordinate the implementation of the PRIME and SCORE projects with
DoTC&I management, DoTC&I PMU, DoFA CIU, PIU State Focal Points, and the Statetransport agencies in a manner that is to be set forth in the PIAs that outlines the roles ofeach organization. The PIU will also be responsible for preparing and implementing bothprojects in accordance with annual work plans and budgets which will detail the Project’s
activities and eligible expenditures. The PIU will clarify, among other things, the necessary
state and intra-government cooperation and support necessary for both Projects.
The PIU will have overall supervision of ESMF implementation. Environmental and social
risk management will also be the responsibility of the PIU, supported by the CIU
Safeguards Team. The PIU will ensure the availability of an appropriate budget for ESMF
implementation.
E&S training, awareness and capacity building of the PIU will take place under PRIME and
SCORE project Component 1 and 3 and will be undertaken by the CIU Safeguards Team.

8.1.3

CIU
The already established CIU within the DoFA, the PRIME and SCORE Projects Executing
Agency (EA), is a functional unit that supports the implementation of the WB portfolio andincludes an environmental and social Safeguards Team.
In order to provide strong and efficient support throughout FSM, the CIU provides support
to core implementation functions needed for all WB portfolio projects in FSM including, but
not limited to, procurement, financial management, social and environmental risk
management, monitoring and evaluation, as well as outreach and communications. The
CIU team members responsible for these functions report to the CIU Program Manager
and provide services and hands on support to the PRIME and SCORE Project
Implementing Agency (i.e., DoTC&I) for preparation, implementation and capacity building
activities. The CIU will be supported during project implementation by environmental andsocial consultants for due diligence, community engagement and instrument preparation
as needed. Resources for these consultant services have been budgeted in the project.
Project implementation responsibilities however remains with the IA (DoTC&I).

8.1.4

Role and Composition of the PSC
To ensure the four States are adequately represented in decision making process, a
Project Steering Committee (PSC) has been established and chaired by DoTC&I.
The Secretary of DoFA is a member, along with a member appointed by the Governor ofeach of the four States. The PSC will provide general oversight and policy direction to
PRIME and SCORE projects stakeholders during Project implementation, convene key
stakeholders in the event of disagreement and periodically review both Projects progress.
The PSC will have a role in determining priorities for allocating Project funds after thecompletion of the VA and CRRS studies.

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8.2

Implementation Roles and Responsibilities
The management, coordination and implementation of the ESMF and other instruments
and its integral tasks will be the responsibility of the PRIME and SCORE PIU with support
from the CIU Safeguards Team.
It will be important for the PIU and other implementing agencies to ensure that theinstitutional capacity is in place before commencement of design of activities underComponent 2. This includes ensuring relevant positions in the CIU, PIU as well as State
focal persons are in place and that initial E&S management training has been provided.
Some of the main shortcomings of E&S frameworks include:(i) Lack of funds for planning, development and follow-up monitoring; and(ii) Lack of experience in framework implementation due to the absence of qualified
and experienced staff.
The organizational structure and management functions for implementing all projectsafeguard instruments are described below. .

8.2.1

JOINT PIU Project Manager and Project Officer
The joint PIU will be initially staffed with a PIU PRIME and SCORE Project Manager, anda PRIME and SCORE Project Officer, based in Pohnpei (National Government DoTC&I)
with additional PIU support to be recruited (such as State level or administrative support)
as required.
The joint PIU Project Manager will be responsible for working collaboratively with allnational level stakeholders and overseeing all State level stakeholder consultation
activities with support from PIU State Focal Points.
The joint PIU Project Manager will also be responsible for the following with support fromthe CIU Safeguards Team as required:

Approve the content of any future revisions to the ESMF, and other instruments
based on technical review and recommendations by CIU Safeguards Team before
sharing with the WB for review and clearance;Initiate the commencement of, and review the content of, the E&S screening forms
and report to be undertaken by the CIU Safeguards Team;

Implement and monitor all stakeholder engagement strategies/plans for both
Projects;



Coordinate, facilitate, and where appropriate participate, in face-to-face stakeholder
meetings with on-the-ground support from the PIU Focal Points, and CIU Safeguards
Team;



Oversee implementation of any recommended environmental and social mitigation
measures set out in the ESMPs for the specific works; andPrepare monthly and quarterly monitoring report/s as detailed in the individual
projects ESCP.

The Project Officer is to provide assistance and support to the joint Project Manager on
the above.

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8.2.2

PIU State Focal Points
A focal point in each State has been appointed by the PIU to work on and manage day-today activities for the PRIME and SCORE Projects such as coordinating and monitoring theimplementation of specific Component 2 works. The PIU State Focal Points have been
appointed from within the State Departments that manage Transport and Infrastructure.
The PIU State Focal Point will report directly to the joint PIU Project Manager, and act as
the key contact person for stakeholder enquires in each State with oversight from the joint
PIU Project Manager and CIU Safeguards Team, as appropriate.
The PIU State Focal Point will also be responsible for the following tasks:

8.2.3



Oversee all State level stakeholder engagement related activities for both Projects;Manage the grievance mechanism (outlined in the RF and SEP) at the State level,
including receiving, screening, resolving for forwarding grievances (e.g. to joint PIU
Project Manager, CIU Safeguards Team or others), as appropriate;Interact with related and complementary support activities that require ad hoc or
intensive stakeholder engagement;

Act as mediator between the Contractor and stakeholders;

Support CIU Safeguards Team (or E& S consultant/s) to undertake E&S screening
for Component 2 works; and

Proactively identify stakeholders, Project risks and opportunities (with support fromthe CIU Safeguards Team) and inform the PIU Project Manager to ensure that thenecessary planning can be done to either mitigate risk or exploit opportunities.

PIU Project Assistant
The PIU has recruited a Project Assistant to provide support to both Projects by ensuring
all administrative requirements are managed effectively. Main responsibilities include:

8.2.4



Document management, including capture and filing (physical and electronic) of
stakeholder and PAP documents and records.



Database management, including:oContinuously update stakeholder information (contact details, organizational
details, designation, engagement activities); andoContinuously update grievance information (grievance records, grievance
database, agreements, meeting registers).



Logistics management;Support with arranging accommodation and traveling where required; andAssist with printing of materials to be used during stakeholder meetings (posters,
pamphlets, Project Summary Documents, letters, attendance registers, maps,
newsletters etc).

CIU Safeguards TeamThe CIU Safeguards Team currently and will continue to undertake a range of stakeholder
engagement activities as part of its portfolio of WB funded Projects and has existing

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relationships with a many of stakeholders in each State which will be important to utilize
for the PRIME and SCORE projects. The CIU safeguard team due to the extensive
safeguard requirements of both projects will be supported by additional national
environmental and social consultants throughout project implementation. These positions
will be managed by the CIU safeguard team and will be located within the individual states.
Specialized international safeguard support may be required and will be contracted asneeded. Provision for these consultant services has been budgeted within the project.
In relation to implementation of both projects safeguard instruments, the PIU will require
support from the CIU Safeguards Team in particular for capacity building and E&S
technical support throughout the Projects and to ensure the safeguard instruments are
implemented appropriately and is consistent with the requirements of ESS5.
In relation to implementation of the ESMF, the CIU Safeguards Team will be responsiblefor:

Ensuring the E&S risk screening is undertaken for each Component 2 works of bothprojects (with local support from PIU State Focal Points);Applying the ESMF and other instruments to all Components, including review ofTechnical Advisory TOR and draft and final outputs;

Prepare, or oversee the preparation of, Generic ESMP, works specific ESIA/ESMPs
for the works (if required), for the works, including the preparation of TOR, selectionof consultants, and review of draft and final outputs;Support external consultants to prepare any works specific ESIA/ESMPs required,and review and provide recommendation to PIU Project Manager for approval prior
to the completion of detailed designs;

Ensure environmental and social clauses and relevant E&S instruments are included
in Contractor bid document, including environmental and social protection andmitigation measures are included;

Manage the design and supervision consultants who will be engaged to manage
both projects including the physical works, safeguard compliance, audits etc., toensure environmental and social protection and mitigation measures are
implemented by Contractors;

Oversee the implementation of specific mitigation measures outlined in the ESMPs
and CESMP;Manage grievances and EHS incidents as required, providing technical support toresolving issues and incidents;



Storing data (including grievance records), collating and interpreting stakeholder
feedback and providing details to the PIU, DoTC&I, design team and others asnecessary;Provide E&S reporting on a quarterly basis as part of WB reporting;

Assist to obtain all relevant permits from EPA, KIRMA and federal agencies; andProviding technical and capacity building support to the PIU and other project
implementing agencies on the implementation of instruments, as the PIU does notcontain E&S expertise

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The CIU Safeguards Team may need additional social and environmental risk
management support to implement the growing WB portfolio in FSM including the PRIME
and SCORE projects. Specialist consultants may be required on an ad hoc basis by the
CIU to prepare environmental and social assessments, E&S instruments and/or to conduct
specialist supervision or monitoring services.

8.2.5

Civil Works Contractors
The Contractor engaged to undertake road works construction will be responsible forsupporting the PIU in SEP activities, including undertaking stakeholder engagement
related to construction of the specific physical works outlined in the Contractor’s SIP, aswell as preparing a CESMP and implementing any environmental and social protection andmitigation measures as outlined in the bid documents, ESMF and CESMP. Specifically,
the Contractor is required to:

8.3

Have Occupational Health and Safety (OHS), environmental and social specialist on
their team with relevant experience.

Support the PIU State Focal Points in engaging with stakeholders relating tocommunicating the scope and timing of works (either by attendance at meetings,
installation of notice boards, door knocks/letter drops, etc.);

Negotiation with landowners/users in relation to temporary use of land required forconstruction relation activities (e.g., laydown and storage/stockpile areas, worker
camps, amenities, etc.) and assessment of temporarily used land after
reinstatement/restoration to a condition acceptable to the land owner;

Arranging with landowners regarding reinstalling physical assets (such as fences,
walls etc) located directly within the Project footprint as set out in the ARAP for the
specific works;Receiving complaints and grievances by stakeholders and forwarding to the PIU
State Focal Point during works construction, and resolution of grievances if they are
related to the Contractor (in coordination with the Projects Manager and CIU);

Implement OSH, environmental, social, community health and safety and security
measures relevant for the scope of works under their CESMP;

Respond to corrective action requests by the supervision consultant, PIU or CIU;
and



Regularly report OSH, EHS, progress, incidents, issues, grievances to the PIU.

Implementation Process
All activities required to implement the ESMF, including the Generic ESMP or any works
specific ESIA/ESMP required will be completed in line with the respective requirements forthe specific activities and works of both projects.

8.3.1

Capacity Building Training
The CIU will provided capacity building training to the PIU staff and state focal points
responsible for the Project on E&S risk management and mitigation. The training program
will be developed following project approval and be delivered within three months of theeffective date and as new project team members join the Project throughout
implementation. Topics will include an overview of the ESF requirements; Overview ofDecember 2021

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ESMF; RF, Land Access Procedures and Participatory Design; Stakeholder Engagement;
Grievance Redress Mechanism; Labour Management Procedures; and Monitoring andReporting. The roles and responsibilities of different key agencies in E&S risk management
will be included within training modules.

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9.

Budget and Financial Arrangements
PIU and DoFA shall ensure that the total cost of ESMF implementation (including time
inputs, material and reimbursements) are budgeted for within the PRIME and SCORE
Projects Budget from both counterpart and project funds, and shall cover the following:(i)Engagement of national external E&S consultants to support the CIU with E&S
Screening and/or preparation of works specific ESIAs/ESMPs;(ii) Technical analysis or assessment required as part of works specific ESIA;(iii) Implementation of any environment or social mitigation measures recommended
in the ESMPs, including any environmental monitoring requirements;(iv) Supervising the Contractor’s CESMP implementation and follow up of incidents,
non-compliances and other matters;(v) Consultation and stakeholder engagement; and(vi) Internal monitoring and implementation of the ESMF and other instruments (ESCP,LMP etc.).
While the types of activities and investments to be carried out under the PRIME and
SCORE projects are known (refer Section 2.3), the extent of the works that can becompleted will depend on the results of the VA and CRRS to be carried out underComponent 1 of PRIME.
Budget allocation for environmental and social risk management is to be assessed
separately for each works based on the scope of climate resilience road works underComponent 2 for each project, and refined in the works ESMP.
An indicative budget of US$1,250,000 for both projects (US$605,000 for each project) has
been estimated for the GoFSM to implement the E&S risk management requirements ofthe ESMF over five years as outlined in Table 9-1. Funds will be sourced from both
Government counterpart and project grant funds. A separate budget has been secured as
project grant funds to engage additional environment and social consultants to support the
CIU as needed for the project.

Table 9-1: Indicative budget for implementing the ESMF

Item

Description

Amount (US$)
PRIME

SCORE

Preparation of ESIA and
ESMPs

Preparation of works specific ESIA and
ESMP under Component 2, both projects.

$310,000$310,000

Purchaseofenvironmental monitoring
equipment and associatedtraining.

Assumed handheld water quality meters
and noise meters purchased for each of thefour States. Includes purchasing, annual
servicing and calibration fluids for five
years, includes technical training.

$20,000$20,000

Monitoring
activities

Includes expenses to cover works
monitoring across all four States throughout
Project. Includes travel for key PIU and CIU
staff from Pohnpei to other States, and$50,000$50,000

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Item

Description

Amount (US$)
PRIME

SCORE

travel for the PIU Focal Point within eachState (including flights, car hire, fuel etc.)11
Obtaining permits from
EPA/KIRMA and otherregulatory authorities

Includes EIA/KIRMA permit fees for works
etc.

Implementationofresettlement framework,
ARAPs
and
implementation of GM.
Miscellaneous
stakeholder consultation
meetings and workshops,
including travel.

$15,000$15,000

Includes land acquisition and asset
relocation costs, replacement cost studies
and operation of the projects GM as well as
contingency.

$143,000$143,000

Includes venue, refreshments, printing etc
for numerous meetings across all four
States through Project. Includes travel for
key PIU and CIU staff from Pohnpei to otherStates, and travel for the PIU Focal Point
within each State (including flights, car hire,
fuel etc) as well as contingency.12$77,000$77,000

PROVISIONAL SUM PER PROJECT$625,000$625,000

TOTAL PROVISONAL SUM$1,250,000

Any environmental and social mitigation measures required for works construction (suchas sediment controls measures, replanting of riparian vegetation, costs for disposal ofwaste material) is to be included in the Contractors budget.
Training and capacity building objectives to be included in Terms of References (ToRs) of
external consultants as well as in CIU workplan. Training and capacity building
requirements for PRIME and SCORE are essential activities under the CIU safeguard team
general activities which are already funded separately.

11 Travel for international CIU Safeguards Team member/s to be covered under DoFA CIU budget.

Travel for international CIU Safeguards Team member/s and any separately engaged environment and social
consultants to be covered under DoFA CIU budget, and project budgets for the consultants, respectively.

12

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10. Monitoring and Reporting
10.1

Monitoring and Reporting
Monitoring is essential to ensure successful implementation of all instruments associatedwith the PRIME and SCORE projects. The CIU Safeguards Team, will be responsible forestablishing a monitoring program that will monitor, measure and assess theimplementation and overall success of both projects safeguard instruments and mitigation
measures recommended, including either the Generic ESMP or works specific ESMP (ifrequired), land access plans (such as ARAPs), SEP and LMP, including identifying issues
and facilitate timely responses.
The PIU will be required to ensure the Contractor’s bid documents include:(i)

The works specific ESMP or Generic ESMP;(ii) Standard Environmental and Social Contract Clauses;(iii) Roles and responsibilities are clearly explained; and(iv) Suitable budgets are allocated.

10.1.1 Construction Monitoring and Reporting
10.1.1.1 Monthly Monitoring
During the site preparation and construction phases for works, the following key progress
indicators are to be measured internally by the PRIME and SCORE Project Manager withinformation and data provided by the projects construction supervisor consultants, PIU
state focal points and/or CIU Safeguard Team on a monthly basis:(i)

Compliance with ESMP and CESMPs (and other Contractor Plans required);(ii) The status of implementation of any recommended environmental and social
mitigation measures; and(iii) The findings of monitoring programs.
Monitoring of environmental and social impacts effects will be undertaken daily by theConstruction Supervision Contractor during construction, in accordance with theEnvironment Monitoring Plan in the CESMP to be prepared by the Contractor and approvedby the PIU and CIU Safeguards Team prior to commencement of construction works.
The PIU State Focal Point are to undertake weekly monitoring for the works site throughout
the construction period (or at an alternative frequency agreed to by the PIU and Contractor
if required depending upon the progress of works). Monitoring by the PIU will be basedon frequent visual observations of works construction activities, preparation of necessaryplans and reports, engagement and consultation with stakeholders (as directed by the
SEP), and reviewing and reporting on any Project-related complaints and/or grievances.
Visual monitoring of a works site for adherence to environmental controls should include:

Correct storage of diesel and other potential contaminants;

Site tidiness;Waste disposal; andDecember 2021

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The effectiveness of drainage, erosion and sediment controls.

A visual assessment of watercourses in the vicinity of the works is to be undertaken by theState Focal Point during the weekly monitoring visit, for any observable changes insuspended solids or oil/grease downstream of works. If changes are observed (i.e.
discoloration in water column) or works are being undertaken in the watercourse or stream
banks at the time, water quality monitoring is to be undertaken within watercourses usinga hand-held water quality meter.
Noise monitoring may be required as part of the weekly monitoring by the PIU State Focal
Point for works sites in close proximity to sensitive receptors. If excessive noise frommachinery is suspected by the State Focal Point, noise monitoring is to be undertakenusing a handheld noise meter at i) the works site, and ii) any sensitive receptors identified
in close proximity to the works site (such as residential houses, schools, businesses,
churches etc), during the operation of machinery and construction activities.
Prior to the commencement of works the PIU State Focal Point is to undertake baseline
monitoring of the works site for both water quality and noise monitoring is to be undertaken
as described above, with the results to be used as a baseline to which construction
monitoring is to be compared.
The CIU Safeguard Team, and EPA/KIRMA may also visit the site at any time to ensure
adherence to the ESMP.
Periodic post-construction monitoring will be carried out by DoTC&I during the Defects
Notification Period which extends for 365 days after the completion of construction.
10.1.1.2 Incident Reporting
Should an environmental incident, such as a spill of hazardous substances, or a social
incident such as serious injury or death occur during the course of site works, theContractor Site Manager is to immediately notify the PIU State Focal Point, who is then to
forward the incident to the PIU Project Manager, CIU and EPA/KIRMA. The Site Manager
is to take prompt and immediate action to minimize any impact and where necessary, liaise
with all relevant authorities. The Site Manager is to, in liaison with the PIU and CIU, direct
an appropriate course of action and shall record the date, time and nature of the incident,
full details of the causes and effects, further investigations to be undertaken, person
responsible for such investigations, outcomes of the investigation, actions and resolutionof the incident (including preventative measures implemented to prevent recurrence).
Preventative measures are to be subject to monitoring and review. Incidents will be
included in any audit reports during site works.
The WB must be informed within 24 hours of a severe injury of fatality or a significant
environmental incident.
10.1.1.3 Works Completion Report
At the completion of works activities a completion audit is to be undertaken to establish
whether the commitments set out in the ESMP and CESMP have been fully complied withduring implementation. This report should detail any issues and resolution encounteredduring works implementation and any residual issues or management measures required.
The report should also include photographs of site reinstatement
The completion report will be carried out by the PIU, with support from the CIU Safeguards
Team, and summarize whether the objectives set out in the ESMP and CESMP have been
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achieved. The monitoring requirements set out in the RF should also be detailed in thisworks completion report.
10.1.1.4 Schedule of Construction Reporting
Reporting requirements during works construction are outlined in Table 10-1: Sch.
Table 10-1: Schedule of construction reporting

Frequency ofSubmission

Responsibility

Prior tocommencement ofworks

Contractor

PIU Project Manager and
CIU Safeguards TeamCESMP updates

As required

Contractor

PIU Project Manager and
CIU Safeguards Team

Other Contractor
Management Plans(refer Section 6.3.2)

Prior tocommencement ofworks

Contractor

PIU Project Manager and
CIU Safeguards Team

Updates to any
Contractor
Management Plans

As required

Contractor

PIU Project Manager and
CIU Safeguards Team

Monthly Construction
ReportFirst week of month(for month prior)

Design/Construction
Supervision Consultants

PIU Project Manager and
CIU Safeguards Team

Incident reporting

Within 24 hrs ofincident

Contractor (SiteManager)

PIU Project Manager and
CIU Safeguards Team, thento EPA/KIRMA and WorldBank

Complaints andGrievances Reporting

Within 24 hrs ofgrievance

Contractor (SiteManager)

PIU Project Manager and
CIU Safeguards Team

Works Completion
ReportAfter completion ofworks andreinstatement of site

PIU (State Focal Point)

PIU Project Manager and
CIU Safeguards Team

Report Type
CESMP

Submit to:

10.1.2 Six monthly PRIME and SCORE Projects Monitoring and Reporting
Half yearly monitoring reports are to be prepared for all components of the PRIME and
SCORE projects by the PIU including the following information:(i)

Status of each activity and the related environmental and social risks, including asummary of the findings from monthly reports on physical works;(ii) Achievement of targeted indicators, including objectives attained and not attained
during the period;(iii) Issues or problems encountered, complaints/grievances received and progresswith resolving the grievances;(iv) EHS incidents, and progress with resolution and close out; and(v) Schedule for the next period.

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11. References
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ADB 2015. Understanding Land Issues and Their Impact on Tourism Development: A Political
Economy Analysis of Pohnpei, Federated States of Micronesia.
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Division of Statistics, Office of SBOC 2010. Summary Analysis of Key Indicators from the FSM 2010
Census of Population and Housing.
Division of Statistics, Office of SBOC 2012. 2010 Census of Population and Housing National andState Basic Tables.
Falanruw, M., T. Cole, A. Ambacher, K. McDuffie & J. Maka 1987. Vegetation Survey of Moen,
Dublon, Fefen and Eten, State of Truk, Federated States of Micronesia, USDA Forest Service,
Resource Bull. PSW-20, 6pp+ 3 maps.
Falanruw, M.C., C.D. Whitesell, T.G. Cole, C.D. MacLean, A.H. Ambacher. 1987. Vegetation surveyof Yap, Federated States of Micronesia. USDA, Pacific Southwest Forest and Range
Experiment Station, Resource Bulletin PSW-21, Berkeley, CA.
FSM 2003. Strategic Development Plan 2003-2023, Government of FSM
FSM 2009. Nationwide climate change policy 2009,
FSM 2010. State-Wide Assessment and Resource Strategy 2010 – 2015 +Government of FSM.
FSM 2014. Household Income and Expenditure Survey 2013/14 Main Analysis Report.
FSM DoTC&I 2015. Federated States of Micronesia Infrastructure Development Plan FY2016FY2025
FSM Department of Health, Education and Social Affairs Division of Education 2015. EDUCATIONFOR ALL 2015 National Plan. Government of FSM
FSM 2015. Universal Periodic Review Report, FSM Government.
FSM 2017. Chuuk Joint State Action Plan for Disaster Risk Management and Climate Change,
Government of FSM.
FSM 2020. First Voluntary National Review on the 2030 Agenda for Sustainable Development June
2020, Government of FSM.
IUCN (2020) International Union for Conservation of Nature’s (IUCN) Red List of Threatened
Species.
OEC

2017.
“Micronesia”.
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EconomicComplexity.
http://atlas.media.mit.edu/en/profile/country/fsm/#Exports (accessed 24 May 2017.

Ramsay, Douglas. 2000. Kosrae Shoreline Management Project.
Raynor, B and Kostka, W 2003. Back to the Future: Using Traditional Knowledge to Strengthen
Biodiversity in Pohnpei, Federated States of Micronesia. Ethnobotany Research &Applications 1: 55-63.

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SPC 2005. FSM Household Income and Expenditure Survey. FSM Division of Statistics - Office of
Statistics, Budget and Economic Management, Overseas Development Assistance andCompact Management.
SPREP 2019. Proceedings of the Pacific Regional Consultation on Water in Small Island Countries– Country Briefing Papers
Standards Australia / Standards New Zealand 2006: Environmental Risk Management – Principles
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Takesy, A. 2014. Action Plan for PoWPA and Target 11. FSM Department of Resources andDevelopment.
TNC 2019. A blueprint for conserving the biodiversity of the Federated States of Micronesia. The
Nature Conservancy.
US Army Engineers 1989. Kosrae Coastal Resource Inventory. Prepared by US Army Engineers,
Honolulu.
Weeks, R., 2019. Spatial analysis in support of development of the Kosrae protected area network.
Technical report prepared for The Nature Conservancy 2019.
Wortel et al. 2003. Federated States of Micronesia. Fourth National Report 2010. Implementationof Article 6 of the Convention on Biological Diversity.
WHO 1999. Guidelines values are for noise levels measured out of doors. Source: Guidelines forCommunity Noise, World Health Organization
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Appendix A

Baseline Resource Report

Refer separate report.

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Appendix B Data used in E&S Sensitivities Maps

Table 1: Types of sensitive resources or hazards and their location - Kosrae

Attribute

Type

Locations

Coastal change & inundation- Finfokoa & Pukushruk (Lelu)- Pal and Mosral, Yeseng, Kuplu and from Yewak
to Tenwak (Malem)- Finfoko and Wiya (Tafunsak)

Flooding and erosion hazards

Numerous

Ecological

Areas of Biological Significance‘Areas of Biological Significance’:39-05: Yela-Okat Terminalia Mangrove ABS
39:12: Foko Finfoko Marine ABS
39-04: North East Kosrae Marine ABS
39-07: Tofol FW Marsh ABS
39-09: Lelu Marine ABS
39-08: Foko Puk Marine ABS
39-07: Malem Marsh ABS
39-11: Malem Utwe Mangrove ABS
Protected/Managed Areas:- Tafunsak- Awarne (includes Lelu Causeway)- Olum Watershed- MalemSocialAssets (such as trees, buildings, fences,
gardens, etc)

PhysicalNumerous

Table 2: Types of sensitive resources or hazards and their location - Pohnpei

Attribute

PhysicalType
Erosion – Prone land (based on soil type,slope angle, stability of soils, etc)

Numerous

Flood-Prone land (based on soil type,elevation, etc)

Numerous

Coastal erosion (areas
requiring stabilisation)

Ecological

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Locationspotentially

Areas of Biological SignificanceFinal Draft

Key locations:- Ipat & Dolleki (Net Municipality)- Nansalohhi to Maramasok (Uh Municipality)- Nanrohi to Nanwei (Kitti Municipality)‘Areas of Biological Significance’:36-01: Pohnpei Central Forest ABs
36-14: Dausokele Estuary ABS
36-19: Dien Mangrove ABS
36-07: Alokapw Marsh ABS
36-08: Nan Pailong ABS
36-0_: Dolopwail-Metipw Marine Reserve ABS

Federated States of Micronesia PRIME & SCORE Projects
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Attribute

Type

Locations
36-0_:Senpehn-Lehdau
MangroveABS(Sapwalap Mangroves ABS)
36-05: Tewmen Island ABS
36-02: South Pohnpei Marine ABS(including: Lapinsed ABS, Rohi to Mwudok MarineABS)36-10: Southern Kitti Marine ABS
36-09: Nan Mand Forest ABS (Sapwatkai Forest
ABS)36-09: Palikir-Paies ABS
36-16: Dau Mwoakote Estuary ABS
Protected/Managed Areas:- Enipen Mangrove Reserve

Stream crossings
SocialNumerous

Assets (such as trees, buildings, fences,
gardens, etc)

Numerous

Table 3: Types of sensitive resources or hazards and their location - Chuuk

Attribute

Type

Locations

Coastal stabilisation areas

Key locations with ‘High’ coastal stability issues:- Mechitiw to Pou Bay- Pou Bay
- Meseltruk- Fanachau to Nemwan- Mwan (bridges x2)

EcologicalConservation Areas‘Areas of Biological Significance’:24-19: Pou Bay ABs
24-34: North Weno Marine ABS

SocialAssets (such as trees, buildings, fences,
gardens, etc)

PhysicalNumerous

Table 4: Types of sensitive resources or hazards and their location - Yap

Attribute

Type

Locations
Key locations with ‘High’ coastal stability issues:

Physical

Ecological

December 2021

Coastal stabilisation areas

Conservation Areas‘Areas of Biological Significance’:
02:02: Marbaa Forest ABS
02:05: East Harbour Marine ABS
02:03 Northern Yap Channels ABS
02:20: Ngolog Bay ABS
Protected/Managed Areas:- Tamil traditional management zone (upper reaches)

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Attribute
SocialDecember 2021

Type

Locations

Assets (such as trees,buildings, fences, gardens, etc)

Numerous

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Federated States of Micronesia PRIME & SCORE Projects
Environmental and Social Management Framework

Appendix C Environmental
Forms

&

SocialScreening

FORM 1 – Initial E&S Risk Screening(To be completed by CIU Safeguards Team, with on-ground support from PIU State Focal Point where appropriate)
Note: Refer ESMF Risk Assessment & Impact Identification table (Section 5.6.1) for overview of potential impacts, risks andmitigation summary.
Timing: To be completed after Component 1 Assessments (e.g. VA/CRRS), and prior to preliminary design
Purpose: 1) To identify high risk environmental and social aspects of the proposed works;
2) Inform confirmation of eligibility of works for funding
Name of Works:
Location of Works:
Description of Works:

Date of Form Completion:
Name of Person Completing
Form:
Date of Site Visit:
People consulted to date (toinform completion of form):
Attached concept description(circle one)

Yes / No

1.0

Environmental

1.1

Any vegetation clearance (incl. riparianvegetation) or works within a stream
upstream of or within areas of biologicalsignificance).

Potentially High orExtreme Impact

Low or Moderate
Impact (can be
managed)Activity

NO Impact

Impact Screening(without mitigation)13(Put only 1  in eachrow)

13 Use Risk Rating tables in ESMF to determine level of potential impact.

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Justification(Nature,scale,
duration of
impacts or
sensitivityofreceptors)

Recommended
ActionFederated States of Micronesia PRIME & SCORE Projects
Environmental and Social Management Framework

1.2

Any disturbance of (either works locatedwithin, or potential impact upon) protected
coastal marine areas (CMAs).

1.3

Is the site in an area identified as aprotected or conservation area.

1.4

Works within an identified hazard zone
(e.g. erosion, flooding, coastal
inundation).

2.0

Socio-cultural

2.1

Any likely physical displacement /relocation of people.

2.2

Any likely economic displacement (e.g.
temporary or permanent land acquisition,
disturbance of physical assets, crops/fruit
trees etc).

2.3

Any identified cultural sites (e.g. graves,historic buildings etc) directly adjacent toroad easement in vicinity of the works (i.e.
within 50m of site) or otherwise could be
affected by physical works.

2.4

Any potential access restriction tosensitive receptors / essential services(e.g. hospital, school, church etc).

2.5

Risk to community health & safety fromthe proposed works (i.e. communities inclose proximity to work site) or
construction workforce (e.g.
imported/migrant labour related risks)?

2.6

Is there a risk of UXOs being present in
the works footprint?

Potentially High orExtreme Impact

Low or Moderate
Impact (can be
managed)Activity

NO Impact

Impact Screening(without mitigation)13(Put only 1  in eachrow)

Justification(Nature,scale,
duration of
impacts or
sensitivityofreceptors)

Recommended
ActionFORM 2 – Environmental and Social Screening(To be completed by CIU Safeguards Team, with on-ground support from PIU State Focal Point where appropriate)
Timing: To be completed after concept or preliminary design)
Purpose: 1) To scope potential environmental risks from proposed works that could be minimized through participatory
design; 2) Inform E&S Assessment and Management Plan Requirements (Form 3);3) To inform scope of Terms of Reference for and E&S Consultants to be engaged.
Name of Works:

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Federated States of Micronesia PRIME & SCORE Projects
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Location of Works:
Date of Form Completion:
Name of Person Completing
Form:
Date of Site Visit:
People consulted to date (toinform completion of form):
Attached concept description(circle one)

Yes / No

Form 2a – Environmental Risk Screening

1.0

Physical

1.1

Dust / noise / vibration
impacts on sensitive
receptors (e.g. residential
communities, businesses,
essential services etc).

1.2

Generation and dischargeof solid and liquid waste(e.g. spoil, roadingmaterial, refuse, domestic
waste/ wastewater,
hazardous substances
etc).

1.3

Erosion and sedimentation
risk as a result of works(e.g. stream bank, slope,
coastal margin, channel
modification and hydrology
etc).

1.4

Works within an identified
hazard zone (e.g. erosion,flooding, coastal
inundation zones).

1.5

Is construction material
required for the design(e.g. rock/ aggregate/asphalt/ cement) able tobe sourced locally from a

Moderate to Extreme
ImpactNO Impact

Potential Impact

Low Impact

Potential Impact(without
mitigation)14 ()Describe

Yes
No
Describe:

14 Use Risk Rating tables in ESMF to determine level of potential impact.

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Federated States of Micronesia PRIME & SCORE Projects
Environmental and Social Management Framework

Moderate to Extreme
ImpactNO Impact

Potential Impact

Low Impact

Potential Impact(without
mitigation)14 ()Describe

licensed facility (e.g.
quarry)15.
1.6

Could an alternative
design be explored todecrease / avoid physicalenvironmental impacts3.

Yes
No
Describe:

2.0

Ecological

2.1

Removal of terrestrial
vegetation and/or habitat(incl. riparian vegetation).
(a) Native / naturalvegetation.
(b) Invasive / exotic
vegetation (e.g.
weeds).
(c) Privately owned trees/ crops / gardens(refer Form 2b).

2.2

Potential impacts on
freshwater ecosystem,
including:(a) Direct disturbance offreshwater habitat(e.g. works footprint
within watercourse).
(b) Indirect disturbanceof freshwater habitat(e.g. fromsedimentation, water
quality pollution).
(c) Risk of barriers tofish passage.

2.3

Works within or potential
disturbance of coastal
marine area (CMA)

2.4

Yes
15 Discuss with design engineer, if required

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Federated States of Micronesia PRIME & SCORE Projects
Environmental and Social Management Framework

Moderate to Extreme
ImpactNO Impact

Potential Impact

Low Impact

Potential Impact(without
mitigation)14 ()Could an alternative
design be explored todecrease / avoid
ecological impacts or
improve ecologicaloutcomes3.

Describe

No
Describe:

Form 2b – Social & Resettlement Risk Screening

1.0

Land

1.1

Impacts on land outside of
the road easement?

Moderate to Extreme
ImpactLow Impact

Potential Impact

NO Impact

Potential Impact(without mitigation)16()DescribeNo
Yes (Temporary Use)
Yes (Permanent Loss)

1.2

Estimated extent of land
loss outside of roadeasement.

Estimated area:

1.3

Estimated number ofprivate landowners areaffected?

Estimated No. of landowners:

1.4

Is the ownership status
and current usage of land
to be acquired known?

Yes
No
Describe:

16 Use Risk Rating tables in ESMF to determine level of potential impact.

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1.5

Moderate to Extreme
ImpactLow Impact

Potential Impact

NO Impact

Potential Impact(without mitigation)16()

Easement paperwork
available andobtained?

Describe

Yes
Available, not yet obtained
No easement paperwork available
Not yet sure if easement
paperwork available (to be
confirmed)

1.6

How is this land to beprovided:

Voluntary Land Donation (VLD)
Lease / Rental
Willing-seller-willing-buyer
Available Government land
Involuntary acquisition
To be confirmed
Describe:

1.7

Could an alternative
design be explored todecrease / avoid land
loss17?

Yes
No
Describe:

2.0

Assets2.1

Are there likely to be lossof physical assets and/or
crops/productive trees
due to works footprint or
associated facilities?

2.2

Estimated number ofasset owners affected?

2.3

What type of assets areaffected:

Yes
No
Estimated No. of landowners:

Residential house
Business/commercial structure

17 Discuss with design engineer, if required

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Federated States of Micronesia PRIME & SCORE Projects
Environmental and Social Management Framework

Moderate to Extreme
ImpactLow Impact

Potential Impact

NO Impact

Potential Impact(without mitigation)16()Describe

Secondary structure (e.g. fence,
wall, driveway, pavement, shed orsimilar)Crops (including type)
Productive Trees
Perennial Trees
Cultural sites (e.g. grave sites,
historic buildings etc)
Describe:

2.4

Could the assets berelocated or repaired?

Yes
No
Describe:

2.5

Could an alternative
design be explored todecrease/avoid asset
loss?

Yes
No
Describe:

3.0

Livelihoods

3.1

Will the works have any
impact on people’s
livelihood (e.g. economic
displacement)?

Yes
No
Describe:

3.2

Estimated number ofpeople/households withlivelihoods affected?

3.3

What kind of livelihoods
are likely to be impacted?

Estimated No. of people/households:

Business/commercial – Owner
Business/commercial – Employee

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Federated States of Micronesia PRIME & SCORE Projects
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Moderate to Extreme
ImpactLow Impact

Potential Impact

NO Impact

Potential Impact(without mitigation)16()Describe

Agricultural / Farming
Fishing
Other:___________________________
Describe:

3.4

Could an alternative
design be explored todecrease/avoid livelihood
impacts?5

Yes
No
Describe:

4.0

Access Restrictions

4.1

Are there likely to beaccess restrictions?

Yes
No
Describe:

4.2

What kind of access
restriction are expected?

Pedestrians (including closure ofroad verges)
Driveways – Residential
Agricultural / Farming
Driveways – Business/commercial
Transport Network
Access to essential services
Coastal margin
Other (e.g. natural resources,
communal land/facilities, services
etc)

4.3

December 2021

Yes

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Federated States of Micronesia PRIME & SCORE Projects
Environmental and Social Management Framework

Moderate to Extreme
ImpactLow Impact

Potential Impact

NO Impact

Potential Impact(without mitigation)16()Is an alternative means ofaccess required (e.g.
temporary diversion orwater crossing etc)?

4.4

Describe

No
Describe:

Could an alternative
design be explored todecrease/avoid access
restriction impacts?

Yes
No
Describe:5.0

Other Social Impacts

5.1

Impacts on Sensitive
receptors in close
proximity to the works(e.g. residential
communities, businesses,
essential services etc).

5.2

Disproportionate Impacts
on vulnerable groups orroad users

5.3

Risk to community health& safety from the
proposed works (i.e.
communities in close
proximity to work site).

5.4

Risk posed to thecommunity from theconstruction workforce(e.g. imported/migrantlabour related risks).

5.5

Risk of UXOs in works
footprint, and resultant
risk to worker health andsafety.

FORM 3 – E&S Assessment and Management Plan Requirements(To be completed by CIU Safeguards Team, with on-ground support from PIU State Focal Point where appropriate)
Timing: To be completed after concept or preliminary design together with Form 2 and 4
Purpose: 1) To confirm which whether work specific ESIA/ESMPs are required;
2) To determine which Land Access Procedure Plans are required
Name of Works:

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Location of Works:
Date of Form Completion:
Name of Person Completing Form:

Assessment()Potential Impact

Yes
1.1

1.2

1.3

1.4

Does the Generic ESMP adequately address thepotential environmental and social risks identified
in Form 1 and 2?

Is the site in an area, or could potentially impact
an area, identified as a protected or conservationarea.

Do the works involve land loss outside of the roadeasement, asset loss, or loss of income sources
or impacts livelihoods?

Documents RequiredNo(Note: If ‘No’, then works specific ESIA &ESMP required)(Note: If ‘Yes’, then works specific ESIA &ESMP required)(Note: If ‘No’, then Land Access Due
Diligence Report required).

Will the land and/or assets be acquired via
Voluntary Land Donation (VLD)?
(Note: If ‘Yes’, then Voluntary Land
Donation Report (VLDR) required)

1.5

Will the land and/or asset loss, or livelihood
impacts require financial compensation, as per
entitlement matrix in RF?

(Note: If ‘Yes’, then Resettlement Plan
(RP) required)

FORM 4 – Agreed Environmental and Social Documents Required(To be completed by CIU Safeguards Team, with the support of PIU State Focal Point where appropriate)
Timing: To be completed after concept or preliminary design together with Form 2 and 3
Purpose: 1) To confirm which ESMPs or land access plans are to be prepared and/or implemented for the works;
2) To confirm which additional management plans are to be prepared by the Contractor (as informed by theESMF).
Name of Works:
Location of Works:
Date of Form Completion:
Name of Person Completing
Form:
Name of Person Approving:
As per the PRIME E&S Management Framework (ESMF) the following safeguard documents are to
be prepared/implemented for the above works:

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Federated States of Micronesia PRIME & SCORE Projects
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Generic ESMPWorks specific ESMPWorks specific ESIAAs per the PRIME Resettlement Framework (RF) the following safeguard documents will be prepared
for the above works:
Land Access Due Diligence Report
Voluntary Land Donation Report
Resettlement Plan

Signature:

Signature:

Signed by:Signed by:(Completed Form)(Approver)

Date:

Date:

December 2021

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