East Micronesian Cable Project (EMC)

Addendum to Original Environmental andSocial Impact Assessment (ESMP) –Kosrae State FSM only

World Bank Project No: P130592

June 2020

FSM CIU Safeguard Team
Department of Finance and Administration
This Environmental and Social Management Plan (ESMP) Addendum is a document of theborrower. The views expressed herein do not necessarily represent those of WB’s Board of
Directors, Management or staff, and may be preliminary in nature.
In preparing any country program or strategy, financing any project, or by making any
designation of or reference to a particular territory or geographic area in this document, theWorld Bank does not intend to make any judgments as to the legal or other status of any
territory or area.

Acronyms
AP
APM
BMH
CA
CIU
CLS
cm
DTC&I
DFMR
DRC
DR&D
DREA
EA
ECBP
EEZ
EIA
EIS
EMC
ERP
ESA
ESIA
EMP
ESMP
FSM
FSMTCC
GRC
GRM
ha
HSMP
HSP
IA
IP
IPP
IPPF
KIRMA
KCSO
km
m
m2
MC
MPA
MRD
NBSAP
nm
NORMA
OAE
OP
PCR
PIA

Affected People
Administrative Project Manager
Beach Man Hole
Conservation Area
Central Implementing Agency
Cable Landing Station
Centimeters
Department of Transportation, Communication & Infrastructure –National Government
Department of Fisheries and Marine Resources – Kosrae State
Development Review Commission
Department of Resource and Development – FSM National
Government
Division of Resource Economic Administration
Environmental Assessment
Environmental Code of Practices
Exclusive Economic Zone
Environmental Impact Assessment
Environmental Impact Statement
East Micronesian Cable
Emergency Response Plan
Environmental and Social Assessment (WB)
Environmental and Social Impact Assessment
Environmental Management Plan
Environmental and Social Management Plan
Federated States of Micronesia
FSM Telecommunications Cable Corporation
Grievance Redress Committee
Grievance Redress Mechanism
Hectares
Hazardous Substance Management Plan
Health and Safety Plan
Implementing Agency
Indigenous Peoples
Indigenous Peoples Plan
Indigenous Peoples Planning Framework
Kosrae Island Management Resources Authority
Kosrae Conversation & Safety Organisation
Kilometers
MetersMeters squaredManagement Committee (EMC)
Marine Protected Area
Marine Resources Division FSM National Government
National Biodiversity Strategy and Action Plan
Nautical Miles
National Oceanic Resource Management Authority
Open Access Entity
Operational Policy (WB)
Physical Cultural Resources
Project Influence Area

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PMU
PPE
RAP
RPF
TMP
TPM
TOR
WB
WWP
WWII
UXO

Project Management Unit
Personal Protective Equipment
Resettlement Action Plan
Resettlement Policy Framework
Traffic Management Plan
Technical Project Manager
Terms of Reference
World Bank
Waste Management Plan
World War Two
Unexploded Ordnances

LIST OF FIGURES
Figure 1:
Figure 2:
Figure 3:
Figure 4:
Figure 5:
Figure 6:
Figure 7:
Figure 8:
Figure 9:
Figure 10:
Figure 11:
Figure 12:

Figure 13:
Figure 14:
Figure 15:

Figure 16:

Proposed submarine cable alignment connection for the island nationsof Kosrae (FSM), Nauru and Kiribati (adopted from the original ESIA).
Typical layout of a beach manhole landing facility.
Fibre optic cable options.
Examples of a submarine cable ploughs used in tropical waters.
Schematic showing typical conduit thrusting methodology.
Proposed Shallow Water Marine Cable Alignment.
Proposed Terrestrial Cable Alignment.
Proposed Location of the Cable Landing site and BMH.
Photos of the Proposed BMH Site.
New Site Location for the projects Cable Landing Site.
Photos of the Proposed CLS Site.
The location of the marine assessment survey sites including the 6
Dive Sites (SD) and the 4 specific Free Dive intertidal and subtidal reef
systems (red) in relation to the Lelu channel and proposed cablealignment (not to scale).
The location of the 6 intertidal reef transects in relation to the Lelu
channel and the proposed cable alignment (not to scale).
Location of the sunken vessel and planes within Lelu Harbor.
Representative photos of the road easement associated with the fiber
cable terrestrial alignment, (a) road in close proximity to BMH, (b) roadin close proximity to the CLS, (c and d) main bridge and (e & f) coastal
shoreline.
Proposed cable alignment showing area that requires UXO
assessment.

LIST OF TABLES
Table 1:
Table 2:
Table 3:

Relevant National and State Legislation for Kosrae.
Project Area of Influence delineations and conditions.
Summary and continued relevance of the original ESIA annexes.

East Micronesian Cable Project – ESMP Kosrae Component Addendum Update – June 20203

Table of Contents
1. INTRODUCTION ........................................................................................................... 8
1.1
1.2
1.3
1.4

Proponent and Purpose of ESIA .............................................................................. 8
Project Rationale ......................................................................................................... 9
Project Status & Documentation ............................................................................ 9
ESIA Methodology ...........................................................................................................10

2. POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK ............................... 11

2.1 Resource Management ..................................................................................................11
2.2 Land and Tenure .............................................................................................................12
2.3 Legal Framework ............................................................................................................13
2.4 International and Regional Treaties ........................................................................14
2.5 World Bank Safeguard Instruments ............................................................................14

3. PROJECT DESCRIPTION.......................................................................................... 17
3.1 Project Components .......................................................................................................17
3.2 Project Description ............................................................................................................19

4. BASELINE DATA ........................................................................................................ 24
4.1
4.2

Marine Assessment.........................................................................................................24
Terrestrial Assessment .................................................................................................31

5. ANALYSIS OF ALTERNATIVES .............................................................................. 34
6. ANTICIPATED IMPACTS AND MITIGATION MEASURES .............................. 35

6.1 Introduction ..........................................................................................................................35
6.2 General Environment ........................................................................................................35
6.2.1 Deep Ocean Waters .................................................................................................................. 35
6.2.2 Intertidal Coastal Marine Areas .......................................................................................... 36
6.2.3 Terrestrial Areas ....................................................................................................................... 37
6.3 Poverty and Gender Impacts ..........................................................................................38
6.4 Land Acquisition & Resettlement .................................................................................38
6.5 Risk Assessment & Impact Identification Methodology .......................................39
6.6 Outcome of Risk Assessment & Impacts Identification.........................................39
6.7 Other Potential Impacts & Benefits ..............................................................................39
6.7.1 Cumulative Impacts ................................................................................................................. 39
6.7.2 Irreversible & Irretrievable Impacts ................................................................................. 40
6.7.3 Transboundary Impacts ......................................................................................................... 40
6.7.4 Environmental & Social Enhancements/Benefits ....................................................... 40

7.0 INFORMATION DISCLOSURE, CONSULTATION & PARTICIPATION.......... 41

7.1 Introduction ..........................................................................................................................41
7.2 Disclosure ..............................................................................................................................42
7.6 Ongoing Consultation & Participation ........................................................................42

8 ENVIRONMENTAL & SOCIAL MANAGEMENT PLAN ....................................... 43
8.1 Introduction ..........................................................................................................................43
8.2 Performance Indicators....................................................................................................43
8.3 Implementation Arrangements .....................................................................................44
8.3.1 Overview....................................................................................................................................... 44
8.3.2 ESMP Implementation Arrangement ................................................................................ 45
8.4 Institutional Capacity Assessment................................................................................45
8.5 Mitigation & Monitoring ...................................................................................................46
8.5.1 Environmental............................................................................................................................ 46
8.5.2 Social Development Programs & Resettlement Costs................................................ 47
8.5.3 Total costs .................................................................................................................................... 47

East Micronesian Cable Project – ESMP Kosrae Component Addendum Update – June 20204

8.6 Reporting & Monitoring Requirements ......................................................................47
8.6.1 Environmental Codes of Practice ....................................................................................... 47

9.0 GRIEVANCE REDRESS MECHANISM (GRM) ...................................................... 48
10.0

CONCLUSIONS & RECOMMENDATIONS ....................................................... 49

11.0 APPENDICES – UPDATED ESMP ......................................................................... 52
ANNEX 11.1 Ownership Documents of the Proposed Beach Man Hole (BMH),
Sansrit School, Kosrae. .............................................................................................................52
ANNEX 11.2 Ownership Documents of the Proposed Cable Landing Site (CLS) in
Kosrae. ...........................................................................................................................................54
ANNEX 11.3 Chance Find Procedure. ..................................................................................56
ANNEX 11.4 The Kosrae Components Grievance Redress Mechanism (GRM). ....57
ANNEX 11.5 Environmental and Social Impact Mitigation and Monitoring Table
Updated for Kosrae Component Only – Marine and Terrestrial Cable Alignment Scope of Works............................................................................................................................61

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EXECUTIVE SUMMARYThe Governments of the Federated States of Micronesia (FSM), Kiribati and Nauru
have secured their joint participation in a regional fibre optic cable system to link the
FSM island state of Kosrae, and the island nations of Kiribati and Nauru, to theexisting Hannon‐Armstrong (HANTRU)‐1 cable, which currently connects the FSM
states of Pohnpei and Chuuk to Guam. The proposed multi‐national cable system isknown as the East Micronesia Cable (EMC).
The Government of FSM has received assistance from the World Bank (WB) througha grant “East Micronesian Cable” (EMC) project to provide a submarine
telecommunication fibre optic cable. The Kosrae submarine cable alignment has
been finalised and will originate from a submarine branch line connected to the EMC
offshore from the island of Pohnpei southwest to Kosrae. The agreed submarine
cable alignment for the island of Kosrae is to enter the natural deep water reefpassage and channel through the islands outer barrier reef entering Lelu harbor. It
then is to follow the channel veering south entering the shallow subtidal and intertidal
waters on the southern side of the harbor. The cable will terminate (Beach Man Hole- BMH) on the southern shoreline at the Sansrit school (5019’13.27N and
163001’33.04E), which is located on reclaimed state government land. The terrestrial
component of the cable alignment will be deployed underground within the Kosrae
state road easement to terminate at the projects Cable Landing Site (CLS) locatedwithin Tofol on government land within an existing building complex.
An Environmental and Social Impact Assessment (ESIA) was developed for theoriginal project, including the three nations associated within the EMC that provided apreliminary assessment of the potential impacts and mitigation options associatedwith this project. Final site specific deep sea submarine, shallow water and terrestrial
cable alignment locations were unknown at the time the assessment wasundertaken. Subsequently, through further data collection and stakeholder
discussion the cable alignment for Kosrae state has been finalised.
Thus this report provides an addendum to the projects original ESIA including site
specific shallow water marine and terrestrial ecological and social data assessment
which provides an updated Environmental and Social Management Plan (ESMP) thatspecifically addresses the potential risks associated with the delivery of this project.
This information is reported herein and is to be read in conjunction with the EMC
projects original ESIA report for the Kosrae component only. The original ESIA reportstructure and information relevant to the Kosrae Addendum has been included herein
and up dated as required.
Information detailed within this addendum has been incorporated into a Kosrae
specific Environmental Management Plan (EMP) based on the original projects EMP
to further strengthen the environmental management of the open ocean (deep sea),
shallow water and terrestrial ecological systems potentially impacted by the cable
deployment.
The marine ecological assessment of Lelu harbor identified the potential of
Unexploded Ordnances (UXO) resulting from World War Two (WWII) within the
direct area of influence for the submarine cable alignment within the shallow water
marine areas (Lelu channel through to BMH) and as such a professional assessmentof their presence needs to be undertaken to ensure impacts from UXO are known
and managed.

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The EMC Kosrae subcomponent project will require limited land based infrastructure,
resulting in minimal localized terrestrial and marine‐based impacts, which are limitedin scale (immediate footprint of the works) and extent and can be fully mitigated if the
projects EMP compliance is maintained. There are no threats to the area’s marine,
coastal and terrestrial biodiversity associated with the project. As such the potential
impacts of the works on these environment are considered to be minor, temporary,
mitigatable and overall insignificant.
There will be no involuntary land acquisition and all land utilized within the project isgovernment owned and/or leased and within designated official easements (road).
The submarine cable will affect a corridor no more than 3 m wide on the sea floor in
the open ocean and nearshore coastal zone.
Given the small‐scale impact of the marine work, and the fact that nearly all of thework is on board a vessel at sea, no negative social impacts are expected. Sensitive
deep water marine ecological sites such as sea mounts and hydrothermal vents will
be avoided to protect the cable and avoid potential environmental impacts. Similarly,
specific cable alignment corridor has been developed for the inshore shallow water toensure impacts to the subtidal and intertidal coral reef and sea grasses ecosystems
are negated.
The construction of the BMH facility on land and the deployment of the terrestrial
component of the cable to the CLS will require a sub‐contractor. Key potential impact
relates to the disturbance to road users and adjacent land uses from the micro
trenching of the cable within the Government owned road easement. Specific socialand environmental mitigation and monitoring activities have been included in the
updated EMP to ensure the management of these activities.

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1. INTRODUCTION
1.1 Proponent and Purpose of ESIAThe Government of the Federated States of Micronesia (FSM) has secured
assistance with funding from the World Bank (WB) for a regional fibre optic cable tolink the FSM State of Kosrae, and the island nations of Kiribati, and Nauru, to theexisting Hannon‐Armstrong (HANTRU)‐1 cable (Figure 1) which currently connects
the FSM States of Pohnpei and Chuuk to Guam.
The FSM Department of Transportation, Communication & Infrastructure (DTC&I)
remains the Implementing Agency (IA) for the Kosrae component of the EMC. The
newly developed FSM Telecommunications Cable Corporation (FSM TCC) known as
the Open Access Entity (OAE) will implementation the project on behalf of DTC&I.
One of the main challenges facing the region is the need to overcome its remotenessand dispersed geography by developing infrastructure to connect people
domestically and internationally. The EMC Project is intended to provide essential
backbone infrastructure to promote and support social and economic development
across all sectors in each country and within the region. The long term viability of theregion hinges on domestic and international economic integration. The new fiber
optic cable procured under the EMC project will connect the Pohnpei Spur to Kosrae
and on to Nauru terminating in Kiribati. The length of the new cable will beapproximately 2,000 kilometers (km). A significant portion of the cable is well beyond
the territorial seas of the participating countries. The original Environmental andSocial Impact Assessment (ESIA) and the Environmental and Social Management
Plan (ESMP) addendum update (this report) have been prepared to identify all
potential environmental and social impacts that may arise as a result of
implementation of the project and to mitigate any impacts, with a focus on deep sea,nearshore marine, coastal zones and terrestrial systems which form the Project
Influence Area (PIA). Terrestrial infrastructure is relatively limited in extent andutilizes existing government owned infrastructure, facilities and rood easements.
Figure 1: Proposed submarine cable alignment connection for the island
nations of Kosrae (FSM), Nauru and Kiribati (adopted from the original ESIA).

East Micronesian Cable Project – ESMP Kosrae Component Addendum Update – June 20208

1.2 Project Rationale
The proposed project will support investment in a submarine fibre optic cable thatwould connect Kosrae, with Pohnpei to Guam and from there to the rest of the world
via the global Internet. At present, Kosrae relies entirely on satellite for Internet
connectivity. The high cost, and the variable and limited availability of international
bandwidth are major constraints to their ability to participate in the global Information
age and the concomitant opportunities for economic and social development thatarise when cheap and accessible high speed Internet services are made available.
The proposed project will contribute to improved public services (including online
government services such as health, education and financial services), will support
the tourism sector, and will facilitate better trade and communication among northPacific island economies.

1.3 Project Status & Documentation
At the time of preparation of this document (addendum), a project plan for thedelivery of the submarine cable to the island of Kosrae through to the terrestrial
Cable Landing Site (CLS) has been agreed and finalized. As such this addendum
has been designed to update the project original ESIA to reflect the updated project
information. The addendum update uses the WB Environmental and Social
Assessment (ESA) policy framework.
As identified in the original ESIA, a site specific marine benthic ecologicalassessment of the shallow waters associated with the Lelu harbor cable alignment(December 2019) was undertaken. This report documents the marine ecological andenvironmental parameters persisting at this proposed shallow water site andprovides clear impact mitigation and management mitigation methods that have been
incorporated into the projects updated ESMP to ensure the management andmitigation of these impacts. The report is presented separately to this addendum.
The original land due diligence assessment remains relevant to the project, albeit
much of the previous information in not specifically relevant to the final alignment site.

East Micronesian Cable Project – ESMP Kosrae Component Addendum Update – June 20209

Kosrae state government land ownership of the BMH and CLS are provided in Annex
1 and 2, respectively.

1.4 ESIA Methodology
The original ESIA included the following methodology:▪

▪

▪

An initial evaluation of potential cable alignments was undertaken based on incountry consultations with officials from the respective Governments. Then,further scoping activities were undertaken to evaluate these locations based
primarily on eliminating the requirement for private or custom owned landacquisition and minimizing coastal zone environmental impacts. This initialscoping exercise identified a number of BMH sites and CLS that facilitatedthe completion of the evaluation for this ESIA.
In addition, the original ESIA assessment included a review of relevant
secondary information sources, site visits, key stakeholder interviews, andpublic consultations to determine existing environment conditions in the PIA
corridor, at BMH sites and along landside routes where cables may belocated. This was followed by an analysis of the potential impacts that the
installation and operation of the fibre optic cable could have on the corridor’snatural and socio‐cultural environment. Data collected included the following:➢ Potential land acquisition requirements;➢ Sensitive environmental receptors within the PIAs, includingConservation Areas, Fish
Attraction Devices (FADs) and special
tourism sites, such as dive sites;➢ Marine ecology of the coastal zone and nearshore waters likely affectedby the cable project, including benthic and coral reefs conditions along
the PIA corridor;➢ Poverty and gender conditions in relation to the proposed work;➢ Social impacts of faster and more reliable Internet connections; and➢ Cultural heritage and archaeological sites within the PIA corridor.
Preliminary evaluation of the marine and terrestrial ecological resources wasundertaken in late October and early November 2016 and documented in an
ecological assessment report. Information obtained was then used to assess
potential environmental impacts and identify potential mitigation options
during cable deployment and included in the original ESMP.

The methodology used to update the original baseline information and subsequent
mitigation and management protocols have been included in this addendum. The
resulting ESMP developed herein is based predominantly on the ecological andsocial baseline data collected during the addendum preparation, with a large
proportion based on the marine ecological assessment undertaken in November
2019. The marine ecological assessment report is a standalone report and should
be referred as required.

East Micronesian Cable Project – ESMP Kosrae Component Addendum Update – June 202010

2. POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK
2.1 Resource Management
The original ESIA provides a detailed account of the state government and as such isrepeated below. Changes that have been made have been inserted directly into thetext to reflect recent name changes of a number of agencies.
There are a considerable number of government and semi‐government agencies
involved with marine resource management at national and state levels in the FSM.
Each State operates independently in fisheries matters within State territorial waters(shoreline out to 12 nautical miles).
The FSM Government’s Marine Resources Division (MRD) of the Department of
Resources and Development (DR&D) is responsible for providing the government(national and state) with technical information, advisory services and support fordevelopment and management activities in marine resources including fisheries,
aquaculture and coastal resource management. It is additionally responsible for non‐living marine resources within the 200 nautical mile (nm) Exclusive Economic Zone
(EEZ). A major function is to liaise with foreign and international agencies concerning
marine resources.
The FSM National Oceanic Resource Management Authority (NORMA) has been
established to regulate the use of and to manage and conserve the resources within
the nations 200 mile EEZ. One of the NORMA’s key functions is to adopt andpromulgate regulations for the conservation, management, and exploitation of allliving resources in the EEZ.
In Kosrae, the Department of Fisheries and Marine Resources (DFMR) under theDivision of Resource Economic Administration (DREA) is the state agency
responsible for the management and development of marine resources. The Kosrae
Island Management Resources Authority (KIRMA) is the state agency responsible forassessments relating to land usage, permitting for developmental programs,
identification of Conservation Areas (CA), enforcement, development ofenvironmental regulations, and development and implementation of environmental
management plans. An Environmental Impact Assessment (EIA) is required to be

East Micronesian Cable Project – ESMP Kosrae Component Addendum Update – June 202011

prepared (Section 19.104 of the State Code) if a development or activity affects “theenvironmental quality of fishery waters”.
The Kosrae Conservation and Safety Organization (KCSO) is a non‐governmentalorganization whose purpose is “to further develop projects relating to awareness andprotection of the natural environment and to public health and safety; to conduct
community programs and related programs applicable to these projects within
Kosrae ...”The Kosrae National Biodiversity Strategy and Action Plan (NBSAP) outlines thestate of the nation’s biological resources and the current biological and human‐
related threats that affect there continued existence.

2.2 Land and Tenure
The State Government controls a major part of the land in Kosrae, namely
government owned lands, mangrove areas, nearshore areas, and lagoon areas.
Primarily, government lands are of the interior, above the “Japanese line” 1 andforeshore areas. Kosraean’s can own land but not outsiders (foreigners). The land isowned in “Fee Simple” with a certificate of title issued when the registration process
is complete for individual landowners. However, if the land is inherited by multiple
heirs or if customary family land is held in common, then a Tenancy in Common title
is issued.
Accessing land through usufruct or access rights (customary practice) was common
for hunting or gathering purposes. Nowadays, this is more common in the upland andgovernment owned
areas. Accessing land and use rights for productive lands,
particularly in settled areas, is done through leasing agreements.
As a protectorate measure, foreign ownership of land is through leasing titles only.
Kosrae state law allows locals and foreigners alike to lease for up to a 55‐year term
renewable for an additional 55 years. Although this provides secure access and use
for the lease period, issues such as land ownership disputes, lack of certainty, poor
surveying capabilities, absence of records, and uncertain parameters for customary
usage often hinder foreign investment. As in other Pacific island land tenure systems,
land transactions are often made under customary practice, which is frequently
undocumented. This makes accurate determination of ownership rights and pricing ofland difficult to determine.
The Kosrae constitution is the primary rule of law in the State of Kosrae. In its
preamble, it declares “Kosraean’s are one, as people, in their language, in theirtraditions, and in their family and communal life”. The Preamble acknowledges thebounty and beauty of Kosrae pledging to preserve those natural riches. Thus thelegal foundation for the State’s environmental protection and conservation, bothhuman and physical, is laid.
The Kosrae State Code Title 11, Land and Environment, sets out the requirements
regarding the acquisition and use of land. Under Title 11, the Governor can transfer
title or interest in public land on behalf of the State of the Government but only with
the Legislature’s resolution. The Governor also has the authority to designate
suitable areas of the public land for homesteading to eligible persons.

1

A line which sets aside the upper elevation of Kosrae Island; land above the line is designated as Government andthe land below the line is where private owned designated begins.

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In managing land and land use, the Kosrae State Code provides for land use
planning, surveying practice, homesteading and establishment of the Land Court.
The Land Court determines and registers land titles. Further, the deed of trust allows
for the transfer of an estate in real property or freehold or leasehold interest in real
property to secure an obligation. This practice allows land transactions for monetaryor customary obligations.

2.3 Legal Framework
As described in Section 2.1, there is significant legal provision in existing law for
managing and conserving the environment of Kosrae. Table 1 (Table 2.1 in theoriginal ESIA) lists state and national laws relevant to the Kosrae portion of the EMC
Project.
The state 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 development is environmentally sustainable”. The DRC has the authority
to enter, enforce, and issue injunctions, mandamus, or other remedies requiring
compliance through the Attorney General. Further, the DRC has the authority toprotect the environment and antiquities.
The State can acquire an interest in private land for public purpose. The Constitution
and Article XI, Land and Environment, provides for fair compensation should there bea need for land acquisition for the purpose of resettlement. The process must be
done in good faith with reasonable effort to avoid substantial hardship to theinterested parties2.
An EIA may be required particularly if any development or activity affects theenvironmental quality of fishery waters, which is determined following consultation
with the Director of the DFMR. If an EIA is required then the Director has the right tosubmit comments before a decision is made by any State Government Authority
such as the DRC.
Based on the initial and subsequent consultation regarding the marine and terrestrial
scope of works of the Project an application has been submitted to determine
whether an EIA is required for the installation and use of the cable and associatedfacilities, for State approval. This ESMP and associated projects documents (e.g.
marine benthic assessment) will be substituted for the State EIA.
Table 1: Relevant National and State Legislation for Kosrae
NATIONAL LEGAL FRAMEWORKFSM Constitution
The supreme law and it establishes the national, state, andmunicipal governance.
FSM Environmental
Provides for the protection of the environment, culture,
Protection Act 1984
historic and natural aspects of Micronesian heritage.
Marine and Freshwater Identifies the uses for which waters of FSM shall be
Quality Standards
maintained and protected (water quality).
Regulations 1986
Trust Territory Solid
Establishes the minimum standards for the design,
Waste Regulations
construction, installation, operation and maintenance of1979
solid storage, collection, and disposal systems.
FSM Earthmoving
Earthmoving activity permits are issued by the Secretary of
2

Palik vs Kosrae, 5 FSM Intrm. 147.152-154 (Kos. C. Ct. Tr. 1991)

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Regulations 1988
Human Resources.
FSM EPA
Requires the National Government and its agencies toEnvironmental Impact
submit Environmental Impact Statement (EIS) to theAssessment
Secretary of Human Resources prior to any “major” action
Regulations 1989
significantly affecting the quality of the human environment.
FSMC Title 26
Policy to protect and preserve the diverse cultural heritage
Historical Sites andof the people of Micronesia.
Antiquities
KOSRAE STATE LEGISLATION
Constitution of thePrimary rule of law in the state of Kosrae.
State of Kosrae
Kosrae State Code,Established the Kosrae EPA (known as KIRMA)
Title 17, Chapter 4
Kosrae Code, Section
Land use and subsidiary regulations
11.201
Kosrae Code, Section
Foreign fishing agreement
14.1302
Kosrae Code, Section
Endangered species
11.1601
Kosrae Code, Section
Water quality
13.514
Kosrae Code, 13.523
Unauthorized procuring of marine life
Kosrae Code, Section
Endangering a species
13.524
Kosrae Code, Section
Protection of antiquities and traditional culture
11.1401
Kosrae Code, Section
Littering
13.506

2.4 International and Regional Treaties
The original ESIA references the international treaties and conventions the FSM is asignatory to. Information detailed in this annex remains the same and no changes
have been made. This information has not been repeated herein and the original
ESIA report should be referred for clarification as required.

2.5 World Bank Safeguard Instruments
The Kosrae project remains a category B and the original safeguard Operational
Policies (OP) and instruments – as described in the original ESIA remain the same.
The project triggers: OP 4.01 (Environmental Assessment); OP 4.04 (Natural
Habitats); OP 4.11 (Physical Cultural Resources). The details as provided in theoriginal ESIA and are repeated below. The original ESIA evaluation of compliancedocumented remains the same (Annex 8 in the original report). This annex has notbeen repeated herein and the original ESIA report should be referred for clarification
as required.
Operational Policy 4.01 – Environmental Assessment
The WB requires an Environmental Assessment (EA) Category A and B Projects
proposed for WB financing to ensure they are environmentally sound and sustainable,
thereby improving decision‐making. Operational Policy (OP) 4.01 requires (i) detailed

East Micronesian Cable Project – ESMP Kosrae Component Addendum Update – June 202014

qualitative and quantitative analysis to determine project impacts, (ii) determination of
tangible measures to prevent, minimise, mitigate or compensate for those adverse
impacts, (iii) public consultation and disclosure as part of the EA process and (iv)requires an Environmental Management Plan (EMP) to address set mitigation alongwith monitoring and institutional measures to be taken during design, implementation,
operation and maintenance phases of the project. This policy is triggered for the
Kosrae project. Therefore project has been classified as a Category B, as theimpacts are readily mitigatable and reversible. The original ESIA and update
addendum ESMP satisfy the EA requirements of OP4.01.
Operational Policy 4.04 – Natural Habitats
OP 4.04 requires the conservation of natural habitats and specifically prohibits the
support of projects that involve significant conversion or degradation of critical
habitats, as defined by the policy. The policy further requires the EA to identify
impacts on biodiversity and species and to determine endemism, endangered
species and to determine project impacts on these species and to propose
acceptable mitigation and monitoring measures. This OP is triggered as natural
habitats may be disturbed temporarily during cable laying within the deep andshallow water marine ecosystems and neighboring terrestrial environments (e.g.
streams and coastal shorelines). No Marine Protected Areas (MPA) and/or terrestrial
Conservation Areas (CA) are located within the PIA.
The updated ESMP has benefited and been informed by the results of the submarine
cable alignment assessment of the marine benthic ecological survey assessment of
the subtidal and intertidal reef and foreshore in Kosrae undertaken in November
2019. This site specific marine assessment supersedes the preliminary assessment
undertaken during the original ESIA. Although there are areas of sensitive habitat(i.e., corals and seagrass beds) adjacent to the proposed cable alignment they are
not directly impacted and mitigation measures have been developed to avoid andminimise disturbance. Significant deep sea benthic habitats, such as hydro‐thermal
vents and seamounts, will be surveyed during the detailed design phase and avoided.
There are no natural habitats in the footprint of the terrestrial infrastructure aspects ofthe project (e.g. cable is within the primary road easement).
Operational Policy 4.11 – Physical Cultural Resources
OP 4.11 seeks to avoid the disturbance and/or destruction of Physical Cultural
Resources (PCR) as defined by this policy by the projects activities. PCR includes
places of worship, buried artifacts, cemeteries, and archaeological assets, etc. The
policy further requires; (i) EA to undertake an exhaustive desk review and/or site
investigation to pre‐identify and locate PCR’s in the PIA; (ii) EA/EMP to propose
management measures; and (iii) to include “chance find” clauses in civil works
contracts during construction and maintenance stages.
No PCR were identified during the original ESIA baseline surveys, nor where there
any PCR identified during the additional ESMP assessments. Due to the small
infrastructure footprint, there is a low likelihood of PCR being discovered during
construction. A chance find procedure was developed in the original ESIA andremains relevant to the project. The chance find procedure has been reviewed andincluded in Annex 3 of this report. The policy is triggered as a precautionary measure
in case a PCR is discovered.

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WB safeguard Operational Policy 4.10 – Indigenous People and Operational Policy
4.12 are not triggered by the scope of works for this project. The original ESIA
assessment remains the same, this included:
Operational Policy 4.10 – Indigenous Peoples
OP 4.10 requires engagement in a process of free, prior and informed consultation
with Indigenous Peoples (IP’s), as described by the policy in situations where IP’s
are present in, or have collective attachment to, the project area and for the
preparation of an Indigenous Peoples Plan (IPP) and/or Indigenous Peoples
Planning Framework (IPPF).
An assessment completed by the WB into theapplication of OP4.10 in Pacific Islands Countries concluded that the Kosrae projects
do not trigger this policy. This remains relevant to the project and the updated ESMP.
Operational Policy 4.12 – Involuntary Resettlement
This policy addresses direct economic and social impacts from the projects activities
that will cause (a) involuntary taking of land resulting in loss of income sources or of
livelihoods and (b) involuntary restriction of access to legally designated parks andprotected areas resulting in adverse impacts on the livelihoods of the displaced
persons. This policy requires siting of project infrastructure to be chosen as to avoid
these impacts altogether or to minimise them to the extent possible. Where thesecannot be avoided, the policy requires the preparation of either or both of these
instruments: (i) Resettlement Policy Framework (RPF), (ii) Resettlement Action Plan
(RAP). The policy also requires meaningful consultations with potentially affected
people. The policy prohibits community donations of lands for location‐specificinfrastructure.
All land acquisition associated with the project will be voluntary. All land required by
the project is owned or leased by the Kosrae State government. The projects originalland due diligence study (see Appendix 3 in the original ESIA) and the current
updated ESMP has identified that all land to be used for this project will begovernment owned as such none of which will cause any involuntary resettlement. If
private or custom‐owned land is required (extremely unlikely), this will be acquired
voluntarily, using lease or easement arrangements. Therefore this policy is not
triggered.
The original ESIA Land Use Plan remains in part relevant to the project and as such
this information has not been repeated herein. The original ESIA report should bereferred for clarification as required.

East Micronesian Cable Project – ESMP Kosrae Component Addendum Update – June 202016

3. PROJECT DESCRIPTION
3.1 Project Components
The EMC Project involves installing a submarine fibre optic cable from Pohnpei to
Kosrae (approximately 550 km) and to Kiribati (approximately 1,250 km) with either
an intermediate landing or a spur to Nauru (approximately 250 km). The newly
constructed portion of the EMC system will total over 2,000 km, much of it in deep
ocean water (refer Figure 1).
The key components of the EMC subsea and terrestrial infrastructure for the Kosrae
subcomponent includes:
▪

▪

▪
▪
▪

Fibre optic cable and repeaters (approximately every 200 km) laid on the sea
floor in deep ocean areas and use a combination of cable laying directly onto
the benthic substrate (sea floor) and trenching in shall waters associated with
Lelu harbor through to the BMH using a trenching machine in shallow waters.
At the shoreward end of the cable entering Lelu harbor and terminating at theBMH, the cable will be covered with lightweight armor protection consisting ofstandard articulated piping and if hard substrate is available bolted to thesubstrate.
A BMH landing facility will comprise a small concrete manhole approximately
2m x 2m x 2m (Figure 2) will be located within the state government owned
land within Sansrit Elementary school adjacent to the intertidal reef flat.
Terrestrial cable will be delivered within the existing primary road corridor
easement from the BMH to the projects CLS.
The Kosrae CLS has changed location from the original ESIA reported FSM
Telecommunication Corporation earth station premises and is now located tothe east of this site at the “old Telecom site” which is state government land
(refer Figure 10 & 11).
Figure 2: Typical layout of a beach manhole landing facility.

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The subsea cable, consisting of doubled armored cable to 200 m depth and single
armored cable to 1,000 m depth (refer Figure 3), will range in diameter from 4-7.5 cm.
Figure 3: Fibre optic cable options.

The subsea cable will be laid directly onto the sea floor in waters deeper than 200 m
and either laid directly onto the sea floor (due to the cable weight will sink into thebenthic substrate) or buried in a trench dug by a towed submarine plough in waters
less than 200 m, which is inclusive of the sea floor from the entrance of Lelu harborthrough to the BMH. The trench, which will be approximately 25 cm wide by 50‐75
cm deep, is opened and then closed once the towed plough lays the cable into thetrench (Figure 4). The trenching requires a corridor no more than 75 cm wide.
Figure 4: Examples of a submarine cable ploughs used in tropical waters.

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The delivery of the cable between the BMH and the CLS will be deployed within theexisting road easement associated with the primary road using several methods
including trenching (which may require removal of vegetation where present) using asmall excavator or thrusting, whereby cable conduit is pushed underground inadvance of pulling the cable (see Figure 5). This technique is often used where there
is sensitive infrastructure is present at the surface (i.e., road crossings, driveways,
buildings, sensitive vegetation, etc).
Figure 5: Schematic showing typical conduit thrusting methodology.

3.2 Project Description
The projects final cable deployment alignment has been agreed and as such theinformation detailed in the projects original ESIA has been superseded. As such theoriginal information detailed in the ESIA should be replaced with the information
detailed below. The projects marine benthic ecological assessment undertaken in
November 2019 provides the background information that has been used to finalize
the shallow water cable alignment. This report should be referred for additional
information.
Marine Waters Component: The submarine cable will be connected to the existing
submarine cable approximately 20 km north of the island of Pohnpei and will be
deployed directly onto the sea floor to pass north of the island of Kosrae (refer Figure1) continuing further west to Nauru and Kiribati. A branch line will be connected tothe main cable and laid directly onto the sea floor to enter Kosrae by passing directly
through the Lelu channel (eastern side of the island) entering Lelu harbor (southernside) and landing at a BMH at the Sansrik Elementary School (Figure 6). This site
corresponds to the BMH site number 6 reported in the original ESIA.
Figure 6: Proposed Shallow Water Marine Cable Alignment.

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Terrestrial Component: The cables terrestrial alignment is to follow the islands
main road (within the easement through to a new agreed CLS located to the east of
the original suggested site (Figure 7). All cable terrestrial delivery systemcomponents will be placed underground and located within state owned/leased land
and remain within the states road easement.

Figure 7: Proposed Terrestrial Cable Alignment

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Beach Man Hole (BMH): The BMH is located within the grounds of the Sansrik
Elementary school land parcel (5019’13.27N and 163001’33.04E). The school islocated on state government owned land and includes a small parcel of land thatallows access through a road easement to the property and primary road (Figure 8).
Land ownership documents for the elementary school are attached in Annex 1.
Figure 8: Proposed Location of the Cable Landing site and BMH.

The BMH site is located on the foreshore and intertidal reclaimed reef flat, fully
fenced, contains 3 functioning school classroom buildings and associatedinfrastructure and has direct access to the main road via a gravel driveway with anapproximately length of 30 m (33 yards). The fenced land parcel has a perimeter of
128 m (250 yard) and an approximate land area of 3,815 m2 (3,190 yard2).
The site has been reclaimed and cleared of original vegetation during the 1970’s andremains highly disturbed land parcel. No natural flora and fauna exists (Figure 9).
Figure 9: Photos of the Proposed BMH Site.

East Micronesian Cable Project – ESMP Kosrae Component Addendum Update – June 202021

Cable Landing Site (CLS):The CLS no longer is to be located within the FSM Telecommunications Corporation
Earth Station in Tofol as describe in the original ESIA, it is now to be located at the“old Telecom site’ (5019’30.99N and 163000’45.21E) located on state government
owned land directly east of the states police-goal complex, within Tofol (refer Figure10). Land ownership documents for the CLS are attached in Annex 2.

Figure 10: New Site Location for the projects Cable Landing Site.

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The new CLS site is elevated, fully fenced, contains 3 main buildings in various
levels of disrepair, an old currently unused satellite dish, various equipment currently
stored on site and has direct access to the main road via a gravel driveway on
government owned road easement land with an approximately length of 50 m (55yards). The fenced land parcel has a perimeter of 155 m (170 yard) and an
approximate land area of 1,492 m2 (1,884 yard2).
The site has been cleared of original vegetation during the 1960’s and remains ahighly disturbed land parcel. No natural flora and fauna exists (Figure 11).
Figure 11: Photos of the Proposed CLS Site.

The final location of the shallow water cable alignment, BMH position, road easement
cable location and exact positions within the CLS will be determined once technicalcontractors have evaluated the project and provided final cable deployment sites.
Precautionary notifications highlighted in the original ESIA and included herein are to
be followed.

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4. BASELINE DATA
The projects original ESIA provides a very general summary of the biological –ecological attributes of Kosrae (as required by the original Terms of Reference TOR) and as such can be referred for general information as required. However, atthe time the original ESIA report was developed the submarine shallow water andterrestrial cable alignment corridor were unknown and as such there is limited
information provided on the preferred shallow water marine and terrestrial cablealignment within the Projects Influence Area (PIA) associated with the agreed final
proposed cable alignment path. Thus very limited information was documented toensure key significant biological resources (flora and fauna) and ecological systems
are not impacted due to the scope of works. This is essential information to ensure
WB safeguard requirements are met.
As such a projects specific marine benthic ecological assessment was undertaken in
November 2019 to detail the ecological and biological attributes of the proposed
cable alignment and provide recommendations on the cable alignment corridor andenvironmental mitigation actions. This report was developed as a standalone
document and with key recommendation reported herein. This report should bereferred when additional background information is required. Similarly, a site specificterrestrial review of the proposed land based cable alignment path has been
undertaken to provide site specific information pertaining to the environment andecological systems associated with the road easement between the BMH and CLS
sites.
Information detailed in these ecological – biological reports are summarized below.
This information has been used to develop the projects suggested shallow water andterrestrial cable alignment and up dated marine and terrestrial Environmental andSocial Management Plan (ESMP), which will guide the project contractors to ensure
WB safeguard policies and the FSM National and Kosrae State environmental laws
and regulations are maintained throughout the projects development cycle.

4.1 Marine Assessment
A marine baseline survey assessment was undertaken on the marine benthic abiotic
and biotic habitats (intertidal and subtidal) and marine resources (vertebrate andinvertebrate) within and adjacent to the proposed submarine cable alignment
entering Lelu channel and terminating at Sansrit school on the southern side of Lelu
harbor. The assessment undertaken was divided into three separate marine areas,(Figure 12 and 13) which include:a. The marine benthic assessment of the intertidal and subtidal benthic
ecosystems associated with the reef systems adjacent to the proposed
submarine cable alignment corridor which included four free dives sites
covering a total combined assessed area of 3.74 hectares (ha);b. The marine benthic assessment of the sea substrate (floor) within the channel
and harbor along the proposed submarine cable alignment corridor (Lelu
harbor channel to shallow water adjacent to the BMH) which included six
SCUBA dives site; andc. The marine benthic assessment of the intertidal reef flat ecosystems locatedon the northern and southern reefs adjacent to the Lelu harbor channel,
which included six transect sites covering a total linear length of 1.4 km and a
total area assessed of 0.56 ha. This section includes a brief description of thesubmarine cable proposed terrestrial landing site (BMH – Sansrit School).

East Micronesian Cable Project – ESMP Kosrae Component Addendum Update – June 202024

Figure 12: The location of the marine assessment survey sites including the 6
Dive Sites (SD) and the 4 specific Free Dive intertidal and subtidal reef systems(red) in relation to the Lelu channel and proposed cable alignment (not toscale).

Figure 13: The location of the 6 intertidal reef transects in relation to the Lelu
channel and the proposed cable alignment (not to scale).

The northern and southern coastal waters adjacent to the Lelu channel and outerharbor possess an extensive and dynamic intertidal and subtidal coral reef
ecosystem. This includes an expansive shallow water intertidal reef flat that is
exposed during low spring tides and contain extensive inshore healthy sea grassbeds, a distinctive outer reef crest and edge possessing spur and groove systems in

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the southern and northern outer reef margins and upper and lower reef slopes thatposses a steep vertical decline through to the seabed. Within the Lelu channel thereef slope on the southern side is almost vertical with a distinctive reef wall.
Significant and diverse hard coral percent coverage, morphological form and species
abundance are found predominately on the reef edge through to the lower reef slope
at all sites assessed. Higher hard coral species diversity, abundance and variety ofmorphological forms were recorded within the Lelu channel than within the harbor
reef systems. These parameters decrease rapidly once the harbor is entered.
The benthic substrate associated with the proposed cable alignment within Lelu
channel and southern side of the harbor is relatively homogenous and almost
exclusively dominated by soft substrate sediment composed of coral sand andterrigenous fine silt. Levels of silt on the sea floor increase further into the Lelu
harbor. The substrate is devoid of sessile invertebrates, however supports in areas ahealthy population of mobile burrowing marine worms and echinoderms. The key
marine assessment findings include:
The Marine Substrate (sea floor):
•

•
•

•
•
•

•
•

The seabed substrate associated with the proposed submarine cablealignment path is relatively homogenous throughout the area assessed, has arange of water depth between 14 and 45 m and is characterized by a bottom
layer of coarse sand derived from terrigenous and coral reef origins with afine silt top layer.
The presence of coral fragments, rocks and boulders associated with the sea
floor within the proposed cable alignment direct PIA are rare and most likely
buried due to sedimentation deposition.
The depth of the silt layer decreases towards Lelu harbor channel and is
replaced predominately by sand towards the center of the channel andbeyond, however fluctuations in the depth of the sediment sand silt layer andresulting water turbidity is directly related to tidal and weather conditions
prevailing at any given time.
The relatively high level of suspended silt and sand based substrate locatedat all assessment sites has a significant detrimental effect on the ability ofsessile benthic marine resources to settle (recruit) and survive in these area.
No sessile (non motile) benthic invertebrate species were recorded at any ofthe deepwater substrate dive assessment sites located within the proposed
submarine cable alignment pathway.
Mobile benthic invertebrates and vertebrates (including finfish) recorded very
low population and species numbers throughout the areas assessed. Marine
worm (Polycheate) burrows were located at all dive assessment sites. These
invertebrate resources are highly mobile and adaptive to environmental
disturbances. As such these invertebrates would be expected to self relocate
if the benthic substrate and sediment profile is disturbed.
Anthropogenic garbage, machinery parts and infrastructure equipment werelocated on the sea floor in all assessment sites.
There is a possibility of UXO associated with the sea floor within the cablealignment pathway associated with WWII conflict. The likelihood of theirpresences in unknown. Investigations should be undertaken.

The Reef Systems:•

There are no coral reef systems nor hard coral communities located within the
projects proposed cable alignment pathway (direct PIA).

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•

•

•
•
•

•

•
•

•

•

•

Coral reef systems are located adjacent to the proposed cable pathway(within the projects potential indirect PIA). These reef systems are healthy
and maintain diverse invertebrate benthic sessile resource assemblages andare located on either side of the Lelu channel, along the margins of the outer
sections of Lelu harbor and patch reefs within the harbor and as such are
adjacent to the proposed cable alignment.
These coral reef systems include a distinct zonation; shallow water intertidal
reef flat that is exposed during low spring tides (varying in width 75 m – 280
m either side of the channel), subtidal reef flat (varying in width 10 - 30 m),
distinctive reef edge and crest (3-10 m width), and upper and lower reef slope(5-10 m width) which for the most part have a vertical drop of between 30 80% (the southern side of Lelu harbor is almost vertical wall) that terminates
directly onto a sand silt dominated seabed with depths ranging between 8 m
in close proximity to the BMH through depths in excess of 45 m within the
Lelu channel.
Coral fragments, rocks and boulders are located in close proximity to the reef
systems. They are all but absent within the channel and harbor associatedwith the proposed cable alignments PIA.
All reef sites assessed possess a well developed intertidal and shallow water
subtidal coral reef ecosystem.
Hard coral percentage live coverage, morphological form, species diversity
and abundance in general were similar throughout the sites assessedreflected the natural environmental forces affecting the different reef locations.
A general decrease in these coral parameters was recorded from theentrance to the Lelu channel through to the inner harbor.
The channels southern reef system recorded higher hard coral percent
coverage, species diversity and a larger range of morphological forms than
the northern channel reef site. Both channel sites recorded considerably
higher live reef parameter levels that those recorded within the harbor patch
reef and southern harbor reef margins in close proximity to the cable landingsite (BMH).
The cable marine landing site (adjacent to the BMH) is devoid of a hard coral
reef system rather is dominated by a sand silt benthic substrate that does notsupport benthic sessile invertebrate or vertebrate populations.
Hard coral percent live coverage for the northern and southern channel reef
systems for the intertidal reef, reef crest and edge and reef slope varied
between 0-2 % and 0–2%, 0-10 % and 0–25%, and 5-80 % and 10–50%,
respectively. The patch reef assessed recorded 0-10%, 0-15%, 5-25%
coverage for the above parameters.
Hard coral sub massive and massive (e.g. Porities sp., Favites sp., Monitipora
sp., Lobophyllia sp., Goniopora sp.) and to a lessor degree digitate (e.g.
Acropora sp., Pocillopora sp., Porities sp.), small branching (e.g. Acropora sp.,
Pocillopora sp, Millepora sp), encrusting (e.g. Acropora sp., Echinophora sp.,
Turbinaria sp.) and solitary (e.g. Fungia sp. and Heliofungia sp.)morphological forms dominated the subtidal reef flat, reef edge, crest andupper and lower reef slope at all assessment sites.
The large sub massive and massive hard coral “bommie or coral head”
morphological forms (predominately Porities sp.) were abundant at all sites
accessed with a number of large colonies in excess of 4 m circumference
located along the southern channel reef slope. These are well outside the PIAof the proposed cable alignment.
Both remnant and newly recruited hard coral colonies of varying sizes werelocated at all sites, albeit at a lower level within the patch reef, providing direct
evidence of natural hard coral recruitment is active in these areas.

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•
•

•

•
•

•
•
•

•
•

•
•

•

•

There was an absence of soft corals at all sites assessed.
The intertidal reef systems either side of the channel that extends into theharbor possessed extensive and healthy sea grass beds dominated by two
species (Enhalus acrorides and Thalassia hemprichii). No sea grass wasrecorded within the PIA of the proposed submarine cable alignment.
Marine macro algae density, coverage and diversity recorded low densities at
all sites with the largest percent coverage recorded within the subtidal reef flaton top of the patch reef within the harbor. The dominant macro algae
recorded at all sites was several species of calcium carbonate green algae(Halimeda sp.), whilst the patch reef possessed healthy populations densitiesof the green algae (Caulerpa racemosa) commonly known as sea grapes.
The inner shoreline sections of Lelu harbor support an extensive and diverse
mangrove forest, however these trees are well outside of the projects direct
or indirect PIA and no impacts are expected from the project activities.
Finfish population numbers and species diversity was low at all sites
assessed. Species that were present were juveniles and include reef dwellingplankitvores (small fish), herbivores (e.g. Acanthuridae, Scaridae) and there
was a noticeable lack of predator reef fish.
Very low numbers of reef associated invertebrates (apart from corals) wererecorded at all assessed sites. Those that were recorded have no or little
subsistence or commercial value (e.g. non commercial sea cucumbers).
Reasonable levels of rubbish (e.g. plastic and glass bottles), machinery andold equipment were located on the substrate throughout the marine areas
assessed. These should be removed.
Several adult individual Crown of Thorns starfish (COTS) and their distinctive
hard coral feeding scars were located during the assessment. The southern
reef system recorded the highest numbers (5), however as these species are
cryptic and generally nocturnal it is likely that the population on these reefs ishigher than recorded during the assessment.
There was no hard coral bleaching, however there was small scale evidenceof disease associated with the hard coral communities at both the northern
channel reef and patch reef assessment sites.
5 marine green turtles (Chelonia mydas) were recorded swimming within thechannel and outer harbor during the assessment. These individuals were sub
adults and were most likely foraging on the reefs. These animals are highly
mobile and as such they would not be negatively impacted during the
deployment of the cable. There has been no recorded turtle nesting on the
shoreline beach of Lelu harbor for well over 4 decades.
There were no threatened, endangered or endemic hard coral species
located during the assessment, nor any state, national or international
endangered or protected species (apart from the turtle discussed above).
There are no marine or coastal designated Marine Protected Areas (MPA) or
areas of significant biodiversity within or in close proximity to the proposed
submarine cable alignment. The patch reef assessed has been discussed by
the state government as a potential site for fisheries management area but
has yet to be formally designed. It is expected that the deployment of thesubmarine cable will have no direct or indirect impact on the benthic
resources associated with this patch reef system.
The proposed cable alignment will not impact any state or national sites ofcultural, customary or heritage significance. The historical plane and vessel
wrecks within Lelu harbor are located well outside the proposed cablealignment.
The benthic substrate associated with the proposed cable alignment isdominated almost exclusively of sand and silt and as such the benthic habitat

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within the projects direct PIA can be considered to have very low habitat andecological value to the marine ecological systems of Lelu harbor andsurrounding marine ecosystem.
The recommended shallow water cable alignment defined from the information
detailed in the marine benthic assessment report includes the placement of thesubmarine cable directly onto the sea floor from the Lelu channel entrance through to
the BMH. The cable needs to be delivered through the center of the channel andthen south directly towards the BMH. The cable is to be placed well outside of theintertidal and subtidal reef flat and reef slope systems ensuring the cable is placed
within the soft benthic substrate found throughout the harbor sea floor (refer Figure6). The cable should not be placed anywhere near the living reef systems.
Key Environmental and Biological Impacts:
The proposed scope of works associated with the deployment of the submarine
cable entering Lelu channel traversing through the southern side of Lelu harbor andterminating at the terrestrial landing site at Sansrit school will result in a very small
marine environmental footprint both above and below the water.
Impacts on the marine environment and coastal waters associated directly with andsurrounding the submarine cable alignment are expected to be very minor, localized
to the immediate footprint of the works, and easily managed through standard deepsea cable laying engineering good practice mitigation measures. There are no
threats to the area’s marine and coastal biodiversity associated with the project. As
such the potential impacts of the works on the marine environment are considered tobe minor, temporary, easily mitigatable and overall insignificant.
The potential impacts of the project on the marine biological environment include:(i) Localized and temporary increased suspended sediment levels adjacent toand either side of the submarine cable alignment areas potentially affecting
marine habitats and associated resources during construction activities. Tidal
fluctuations will predict the movement of sediment.
(ii) Spillage/leakage of oil and other pollutants into the marine environment fromplant and equipment used during the deployment of the submarine cable(construction phase) of the project.
Benthic habitats associated with the environmental footprint directly within andadjacent to the proposed submarine cable alignment comprises almost exclusively ofsand/silt substrate (some coral rubble and rock in shallow areas) with a paucity ofbenthic sessile invertebrates. As such the proposed scope of works will have anegligible potential impact on these habitats, its resources and is acceptable.
There is potential for localized and temporary increased suspended sediment levelsin the marine environment during the disturbance of the sea floor as a result of thecable deployment. Such impacts are expected to be very minor due to; i) the low
habitat value of the benthic environment; ii) prevailing high suspended sedimentconditions in the area during periods of heavy rain and/or rough sea conditions; andiii) the limited physical construction activities proposed.

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Potential Impact Mitigation Measures:
The potential impact of increased suspended sediment levels from the works can befurther minimized through implementation of the following mitigation measures during
the construction phase of the project:(i) Deploy silt curtain/s around the termination location (shoreline adjacent to theBMH) of the submarine cable during all construction and redevelopment
activities to directly manage and reduce the dispersion of benthic substrate(silt) disturbed during construction, and(ii) Ensure due diligence when operating machinery during all work activities toprevent and manage petrochemical spillage and contamination of the waters
associated with the project.
The contractor will be required to ensure all equipment is properly maintained and tofollow all necessary precautions to prevent spillage of petrochemicals into the marine
environment as set out in the hazardous materials section of the projects updated
EMP. Provided such measures are properly implemented the potential impacts on
the marine environment will be insignificant.
The overall potential impact of the works on the marine biological environment is
expected to be very minor, localized and overall insignificant provided standard
mitigation measures associated with good engineering practice as identified above
are implemented. Furthermore due to the nature of potential minor impacts of thescope of works it is recommended that no specific marine monitoring program isrequired other than close supervision of the work to ensure that the above
recommended mitigation measures are implemented and effective throughout themarine construction works.
Unexploded Ordnances – UXO
The project original ESIA identified the potential of UXO associated with the cable
deployment in Kosrae and recommended that once the final alignment path isidentified an UXO assessment maybe required. As such the project Marine Benthic
Ecological Assessment details the past history (literature review and stakeholder
conversations) of WWII activities within Lelu harbor and concluded that there is apotential risk issue with UXO within the submarine cable PIA – recommending a risk
assessment be undertaken to identify this issue and mitigation activities developed.
This assessment needs to be undertaken before the cable is deployed.
Background historical references and discussions with local dive industry, marine
resources and stakeholders in Kosrae (November 2019) clearly indicated that Lelu
harbor during WWII received in the order of 30 tons of bombs from American aircraft.
The bombing of Lelu resulted in the island and foreshore demolished and included
the sinking of the Japanese navy cargo ship “Ebon Maru” which remains resting on
the bottom of the Lelu harbor. As such all anecdotal discussion with key stakeholders
indicated that there is the possibility that UXO remain within the Lelu harbor area andthat no past marine identification and removal has taken place within the harbor.
WWII equipment including UXO has been removed from the Lelu Island shoreline
and interior.
Therefore, due diligence and careful consideration needs to be undertaken during all
stages of cable deployment from the entrance of the Lelu harbor through to the BMH(Sansrit school) for the possible presence of unexploded WWII ammunition that may
be present in the substrate.

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It is recommended that a detailed assessment of the cable alignment be undertaken
during the initial cable bathymetric survey assessment undertaken by the contractor
to ensure unexploded ordnances are located and removed before the cable isdeployed. This is essential if cable trenching will be undertaken within the harbor.
Potential impacts decrease if the cable is laid on the sea floor if trenching is notundertaken.
Moreover, resting on the sea floor within Lelu harbor are two aircrafts (PBM Mariner
crashed 1951 and a Navy plane (HU-16) crashed in 1972) and 3 ships including awhaling ship (they think was the “MV Waverly”) reported sunk in 1836, Japanesecargo vessel (Ebon Maru) sunk in 1945 and an unknown vessel. Both planes and all
vessels are located on the sea floor on the north western side of the harborsubmerged coral reef in the center of the harbor – towards the Lelu dock (Figure 14).
All are located well outside of the PIA and as such will not be impacted by the project.
Figure 14: Location of the sunken vessel and planes within Lelu Harbor.

4.2 Terrestrial Assessment
The original ESIA provided very limited information detailing the terrestrial flora andfauna adjacent to the primary road boundaries associated with the proposed cablealignment (Sansrit school BMH through to the new CLS). This is not significant to the
updated ESMP (this report) as the fiber cable alignment will be buried within the roadeasement, which is periodically cleaned by the State government to ensure road
usage and stakeholder access. There are however are a number of plants – trees(majority are grasses and introduced weeds) that have encroached onto the roadeasement in parts that may be required to be removed. There removal is directly
related to the side of the road the cable will be deployed underground within the roadeasement.
Road easement cleaning of vegetation occurs periodically by the state (roadcleaning), telecommunication, water, power utility providers and landowners andthere is no compensation provided. Removal of this vegetation, predominately grass
and weeds (non natives) encroaching on the road corridor is supported and is an

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acceptable activity and as such general stakeholder discussion indicated that this is
fully accepted as part of the road easement arrangements. If large vegetation (e.g.
trees) are required to be removed then specific discussions need to be undertakenwith the land owners adjacent to the road corridor to seek permission (Figure 15 a &b).
In addition, the terrestrial cable deployment route includes crossing several
permanent streams (Figure 15 c & d) and there are several areas that the roadcorridor in located very close to the coastal shoreline (Figure 15 e & f). Considerationof the position of the underground cable within the road easement needs to be
mindful of these habitats and long term potential negative impacts of climate change.
Figure 15: Representative photos of the road easement associated with thefiber cable terrestrial alignment, (a) road in close proximity to BMH, (b) road inclose proximity to the CLS, (c and d) main bridge and (e & f) coastal shoreline.

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The original ESIA Table 4.1 “project influence areas delineations and conditions”
remains suitable for the project and as such has been included herein to be used to
guide the ESMP update. The terms have been refined to ensure practicability andusability for the Kosrae submarine cable project. This is duplicated and presented
below in Table 2.
Table 2: Project Area of Influence delineations and conditions.
Environment
Project Influence Area (PIA)
Offshore (3 nautical miles The accuracy of the placement of the submarine cable(nm) from the coastline)on the sea floor reduces with depth and the increased
influence of ocean currents. A 500 m corridor either sideof the cable has been adopted as a precautionary limit
for the PIA
Coastal Waters (<3 nm
As the accuracy of the submarine cable placementfrom the coastal line)
increases, the PIA reduces. Taking a precautionary
approach, a 100 m corridor either side of the cable (200m total) has been used for the foreshore PIA.
Inshore Waters (subtidal
10 m wide (5 m on either side of the cable) area when
& Intertidal reef systems)
traversing the subtidal and intertidal reef systems
approaching the shoreline.
Beach Man Hole (BMH)
A 10 m radius from the center point of the new terrestrial
structure within existing state government easementsfor public works.
Terrestrial cableA 10 m corridor has been assessed for any terrestrialalignment route.
trenching activities.
Cable Landing Site (CSL) A 10 m corridor around the perimeter of the new and or
existing terrestrial structure within existing state
government easements/land for public works.
Important Species
Offshore:
Habitats – Marine▪ A 2 km clearance of the submarine cable when
encountering sea mounts and/or hydrothermal
vents.
▪ Sonar usage to stop, once cetaceans arelocated within 2 nm of the ship.
Inshore:▪ 10 m minimum corridor for all benthic important
habitats including coral reefs, sea grass beds
and mangrove forests.
▪ A 50 m corridor from any Conservation Area
and/or Marine Protected Area.
Important Species
10 m corridor for all natural terrestrial ecological habitats
Habitats – Terrestrial
and or riparian ecosystems.

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5. ANALYSIS OF ALTERNATIVES
The original ESIA provides a full description and account of the processes
undertaken for the Kosrae component project alternatives and remains relevant. The
information detailed has led to the final cable alignment route. This information is notrepeated rather the original ESIA report should be referred if this information isrequired.

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6. ANTICIPATED IMPACTS AND MITIGATION MEASURESThis section developed in the original ESIA report provided a sound account of theKosrae projects expected impacts and remains applicable and useful for thedevelopment of the updated ESMP. Thus the information detailed in the originalreport will not be repeated herein in its entirety, rather specific sections andinformation have been updated and included under the original ESIA headings. This
includes additional site specific information resulting from the marine assessment toreflect actual impacts not perceived impacts as documented in the original ESIA.

6.1 Introduction
The EMC Project has the potential to create a variety of impacts, which can bepositive, negative, negligible or neutral depending on the receptors involved. The
impact of the Project on the physical, ecological and social environment has beenassessed using methodology described in this chapter of the original ESIA report.
The impact assessment process initially involved the identification of the Project’s
activities and potential environmental and social impacts resulting from each activity
during project phases. Project activities include preconstruction activities, cableinstallation (construction), operation, and ongoing maintenance. Within the original
ESIA, and the updated ESMP (this document) impacts are defined as “any change tothe physical, biological or social environment, whether adverse or beneficial, whollyor partially resulting from an organization’s activities, products or services”.

6.2 General Environment
6.2.1 Deep Ocean Waters
This section remains as reported in the ESIA. It includes:
The environmental issues associated with submarine cable deployment andmaintenance has been identified in relevant international literature. Disturbances andimpacts caused by cable laying and maintenance should be viewed in the context ofthe frequency and extent of these activities. The one off disturbance associated withcable placement is restricted mainly to a strip of seabed less than 5–8 m wide andunless a cable fault develops, the seabed will not be disturbed again within thesystem’s design life (approximately 25 years).
By comparison, commercial bottom trawl and dredge fishing operations are repetitiveand more extensive and a single bottom trawl can be tens of metres wide, sweep
substantial areas of seabed in a single operation and is likely to be repeated at thesame site frequently. A single impact, such as a cable placement or burial, ispreferred to continuous, multiple or recurring impacts.
The United Nations Convention on the Law of the Sea (UNCLOS) advocates the
freedom to lay, maintain and repair cables outside territorial seas, but these are notnecessarily inconsistent with the need to protect deep‐ocean habitats andecosystems, described as follows:▪

Cable deployment in the deep ocean, i.e. laying of a 17–20 mm diameter tube
on the surface of the ocean floor, has a minor if not negligible one‐off impact;
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▪

Cable repairs can result in substrate disturbance. However, cable failures indeep water are relatively rare and are mainly caused by major natural events.

In addition, the submarine cable industry, together with environmental regulators,
attempt to reduce or avoid any impact on vulnerable deep‐water ecosystems by:▪

▪

Utilizing modern seabed mapping and navigation systems that allow
identification of benthic habitats in unprecedented detail and accuracy.
Together with modern cable laying techniques, it is now possible to deploy
cables to avoid ecologically and biologically sensitive areas; andAvoiding the deployment of cables on or through habitats such as seamounts,
submarine canyons and hydrothermal vents, which are also unsuitable ascable routes due to the risk of natural hazards. For example, under water
deep sea canyons are often swept by powerful currents that may abrade or
break cables; and seamounts can be volcanically active and subject tolandslides and hydrothermal venting.

Modern deep water submarine fibre optic cables are composed of several pairs of
hair‐like glass fibres, a copper power conductor and steel wire strength member,which are all sheathed in high density polyethylene. Where extra protection isrequired (as for areas of rocky seabed or strong wave and current action) additional
steel wire armor is included. Of these materials, cable grade polyethylene isessentially inert in the ocean. Processes such as oxidation, hydrolysis (chemical
breakdown in water) and mineralization are extremely slow; the total conversion ofpolyethylene to carbon dioxide and water would take centuries.
The effects of ultraviolet light (UV‐B) (the main cause of degradation in most plastics)
are minimized through the use of light‐stabilized materials, burial into the seabed andthe natural reduction in light penetration through the upper ocean, where the photic
zone rarely extends beyond 150 m depth. Any mechanical breakdown of a cable’s
plastic sheathing to fine‐grained particles on the energetic deep water reef systems
associated with Kosrae, a potential hazard for marine life, is minimized by armouring
and burial.
In addition, the diesel powered vessels used to survey the seabed and lay cable (asdescribed in Section 3.1) will emit greenhouse gases. As the relative contribution ofthese ocean going vessels to overall greenhouse gas emission is so small it isconsidered insignificant “de minimis”.
Offshore anchoring for fishing and/or commercial container vessels in the waters of
the FSM and Kosrae State is limited due to significant water depths. Hence, theoverall potential environmental impacts arising from the Project in the deep ocean
are limited. Anchoring of ocean going commercial vessels offshore from the Lelu
harbor (entry point of the submarine cable into Kosrae) is not used and as such it isextremely rare that a vessel will anchor in this area. The key potential environmental
interactions resulting from the project are associated with the nearshore areas wherecable requires burial to avoid potential entanglement with fishing activities and otherhuman activities.

6.2.2 Intertidal Coastal Marine Areas
A range of potential impacts could arise between the submarine cable entering theshallow marine coastal environment through to the BMH. The key potential impacts
to both reef and soft bottom benthic environment and resources include:

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▪
▪
▪
▪

Direct loss of habitat along the cable route;
Physical effects of sedimentation on benthic communities as a result
suspension of fine materials and off‐site deposition during cable laying;
Reduction in water clarity due to increases in water‐borne suspended solids
concentrations and potential impacts on fish communities; andTemporary restrictions to local villagers to fishing areas during the installation
period only.

Overall the potential impacts are not expected to be significant due to:▪ The area disturbed represents a very small proportion of the total intertidal
habitat present;▪ Minimal benthic ecosystems and resources (flora and fauna) interaction andimpact:▪ Ability of the marine benthic community to recolonize over time; and▪ The short duration of the installation activities.
The UXO assessment of the cable alignment from the entrance of the Lelu harborthrough to the BMH is required to ensure damage to the cable and personnel aremanaged (Figure 16).
Figure 16: Proposed cable alignment showing area that requires UXO
assessment.

6.2.3 Terrestrial Areas
The proposed location of the CLS at the “old Telecom site” on the eastern outskirt ofthe in the township of Tofol, and is located approximately 2.6 km from the projects
BMH (Sansrit Elementary School).
The terrestrial cable route is along the Kosrae primary road corridor and will belocated within the road easement where the existing telecommunications
infrastructure (copper cable) is installed. Evaluation of the potential route indicates it
is comprised of a combination of minor vegetation that encroaches on the roadcorridor (easement) in parts and includes road intersection, business and personal
driveway crossings, and several small stream crossings (concrete bridges). There
are no activities of a particular sensitive nature along the proposed route access toEast Micronesian Cable Project – ESMP Kosrae Component Addendum Update – June 202037

which would be unnecessarily impeded, however business and home road accessmay be interrupted during construction and as such appropriate stakeholder
awareness, notification and timing requires agreement.
The design team will need to specify which side of the road (both sides have aneasement) that the cable is to be deployed along the route between the BMH and
CLS. As the shore side road easement roughly one km northwest of the BMH (refer
Figure 15 e & f) is directly exposed to the shoreline and as such the road as well as
the cable would require structure strengthening in terms of a rock revetment wall.
The use of the inland side of the road to avoid the above issue is recommended forconsideration.
Overall, the potential environmental impacts of cable installation are not expected tobe significant due to the fact:▪ The vegetation present is sparse and is typically comprised of a range ofcommon species and there is nothing of particular conservation concern
present (the road easement is cleaned periodically by the state governmentand or adjacent land owners); and▪ The installation period is of short duration so disruption to traffic andhome/business access will be temporary. All physical disturbances are to be
replaced.
The use of methods (i.e., cable thrusting under sensitive areas) will mitigate any
potential impacts. The proposed CLS itself has no ecological resources of any
description on or immediately adjacent to the site that would be impacted.

6.3 Poverty and Gender Impacts
Section 6.3 of the Baseline Data Report in Appendix 6.3 of the original ESIA report
describes the relevant poverty, vulnerable population and gender issues associatedwith the FSM and state of Kosrae. This information remains relevant and useful tothe project and should be referred for additional background information.
In terms of potential impact overall, the Project will ensure lower cost Internet accessfor consumers, including low income households. As a result, the Project willcontribute to improved social welfare, provide expanded access to information andservices, and increase income‐earning opportunities.
In addition, the Project is
expected to have a positive impact on women’s access to affordable Internet
services. This is important as access to affordable, high‐speed Internet in
employment particularly in the education and health sectors is known to be
associated with economic and social empowerment. Improved Internet access canfacilitate new livelihood opportunities for women who tend to stay on the island.
An added benefit is in the area of disaster risk management such as: (a) facilitating
the deployment of disaster risk monitoring tools and applications that require large
volumes of data transmission (including access to regional databases) by improving
the quality and reducing the cost of Internet; (b) providing additional options/media
for early warning systems and post‐disaster communications.

6.4 Land Acquisition & Resettlement
The Land Due Diligence report addressing the issue of involuntary resettlement for
Kosrae, is provided in Appendix 3 of the original ESIA report. A considerable
proportion of the information detailed in this report, due to the final cable alignment

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location is now out of date. However, information pertaining to land usage,
management and access remains directly relevant to the project and should bereferred to if additional information is required.
The report concludes that the BMH and CLS sites will be located on Government
owned land, and as there will be no need for private or custom owned land to be
used or accessed, nor is there any involuntary land acquisition required. The cableterrestrial routes will follow public road easement and as a result a project
Resettlement Policy Framework (RPF) is not required.

6.5 Risk Assessment & Impact Identification Methodology
The original ESIA risk assessment methodology and associated tables (6.2
Qualitative Measures of Consequent and 6.3 Qualitative measures of Likelihood)remain relevant and useful to the project. These are not repeated herein and should
be referred if additional information is required.

6.6 Outcome of Risk Assessment & Impacts Identification
The original ESIA risk assessment presented in Tables 6.4 and 6.5 remain relevantto the project and as such no changes are suggested. These are not repeated hereinand should be referred if additional information is required.
The original risks determination using the ESIA described process remain the samewith all risks identified and “extreme” and “High” have been determined as “low”
following implementation of mitigation measures identified in the projects ESMP. No
additional information is required and as such the original document should bereferred for additional background information.

6.7 Other Potential Impacts & Benefits
6.7.1 Cumulative Impacts
The original ESIA indicated that no cumulative impacts are anticipated. This isconsistent with the new assessment and as such remains the same. This includes:▪ The submarine cable installation involves the placement of a small diameter
solid cable (containing no liquids, and not needing transmission of electricity)
in a narrow trench on the seabed and careful placed (via divers and/or acable floated into place as required) in coastal waters over a short distanceand a relatively short period of time. There are no other known activities
occurring at the same time that the cable is to be placed on the seafloor.
▪ The installation of the terrestrial component of the cable requires theplacement of a small diameter cable (containing no liquids, and not needingtransmission of electricity) in a narrow trench within the road easement fromthe BMH through to the CLS, which is then backfilled, compacted andcovered. The CLS requires the removal and/or refurbishment of an existingbuilding resulting in minor construction activities, all of which is on state
government land.
In addition, there are no expected cumulative social impacts due to the small project
footprint, and the fact that it is not expected to cause permanent access and/or lossof communal inshore fishing grounds and local people’s livelihoods.

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6.7.2 Irreversible & Irretrievable Impacts
The original ESIA concluded that there will be no irreversible or irretrievable impacts
resulting from the project, this assessment remains valid. Implementation of
measures outlined in the up dated ESMP will serve to mitigate any potential impacts.

6.7.3 Transboundary Impacts
The original ESIA identified transboundary impacts are likely to be limited to:▪ Potential emission of greenhouse gases from the survey and cable laying
vessels and machinery used to deploy the cable within the road easement;and▪ Impacts on ecosystems, endangered species and habitats.
Concluding overall, the impacts of greenhouse gas emissions are expected to be no
more than minor given the relative contribution of the vessels compared to otheremitters, and no endangered species and habitats were identified that could be
potentially adversely affected following implementation of mitigation measures.
The conclusions remain relevant to the project.

6.7.4 Environmental & Social Enhancements/Benefits
The original ESIA findings remain relevant to the project and no changes arerecommended. The Project will not only improve people’s access to income andsocial services, but may also enhance social networks and contact with family
members living abroad. Faster Internet is expected to facilitate regular and affordable
connections among local and overseas‐based groups, particularly women’sorganizations who rely on Internet for communication. A fibre optic system wasinstalled on Pohnpei, FSM, in 2010 and improvements in health care and education
services have been reported. Better Internet connections should also help withremote medical services and distance education.

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7.0 INFORMATION DISCLOSURE, CONSULTATION &PARTICIPATION
7.1 Introduction
The original stakeholder consultations remain valid as documented (documented in
the ESIA Appendix 6 and Appendix 7 details the attendees). Since this report has
been completed a number of key stakeholder discussions and meetings have been
undertaken to further discuss the projects development, at the national and statelevel. Details of these activities are documented with the OAE and/or WB (e.g.
project missions) and should be referred as required.
In addition, the FSM National Department of Financial Administration (DoFA) Central
Implementation Unit (CIU) marine safeguard team undertook a number of key
stakeholder discussions pertaining to the methodology and logistical arrangements
associated with the marine benthic assessment. These are documented in the annex
section of the marine benthic assessment stand along report and should be referred
as required.
Further stakeholder engagement, awareness and information exchange will be
undertaken as the project is initiated to ensure key stakeholders are fully briefed on
the project. Specific community awareness information exchange will be undertakenwith all community members whom maybe directly impacted by the scope of works,
the majority of which are land owners (private and business) adjacent to the cableterrestrial alignment.
The original ESIA stakeholder discussions include:▪ Stakeholder meetings and public consultations were held during the site visit
to Kosrae by the safeguards team from 14th to 23rd October, 2016.
▪ Overall, stakeholder feedback during meetings and public consultation wasvery encouraging and positive. Primarily, people just wanted information on
the nature and timeframe for the project. In fact, the limited connectivity in
Kosrae prompted a lot of people to demand quicker implementation of the
Project. The desire to obtain better Internet and communication services at anaffordable rate was high. This sentiment remains high on community’s
aspirations.
▪ Government and non‐government organizations indicated the aspiration tooffer more products and better services particularly private businesses andfinancial institutions (banks). In addition, there is a high rate of emigrationfrom Kosrae in search of better economic opportunities. Better
communication will be welcomed by Kosraean families with loved ones living
abroad, whom wish to keep close contract with family members at home.
▪ A key issue raised related to land access and ownership. However, it was
mentioned that the priority was locating the BMH and CLS sites on
Government land. Further, it was highly likely that the existing utility corridor(telephone and electricity lines) would be used for the fibre cable networking
on land. The purpose provision in the Government easement lease, whichclearly identifies the 60 feet wide easement, will accommodate the duct routeof the fibre cable from the BMH to the CLS. However, an issue was raisedthat landowners may potentially claim that land on the seaward side of theroad, which has been eroded in recent times, belongs to them when in fact it
is within the road easement. To avoid the issue of ownership and to ensure

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▪

long term viability of the cable in these areas, it is proposed that the cable beinstalled on the inland side of the road.
The issue of accessing inappropriate information specifically by children was
raised by women. The response was described as an issue of managing therisk. Education will need to be provided on how to manage access to Internet
content at home.

7.2 Disclosure
The original ESIA was publicly disclosed on the Implementing Agency (IA) website
Department of Transportation, Communication, & Infrastructure (DTC&I) and wasavailable in hard copy at government office. A public notice was released to let
stakeholders know that the documents are available to view. In addition the WB
disclose this document on their websites.
The updated ESMP (this document) once finalized will be publically disclosed on the
FSM IA website (DCT&I), DOFA – CIU and the WB.

7.6 Ongoing Consultation & Participation
Throughout the projects implementation (pre construction, construction andoperational phases) the project’s IA (DTC&I and OAE) will be responsible for keeping
the public and stakeholders informed of progress. Further consultation will be
undertaken before and during the detailed submarine and terrestrial cable
deployment. The projects IA will develop a consultation plan for their project and will
be supported by an in‐country Project Management Unit (PMU) and an individual
Project Coordinator (PC) to implement the plan. The DOFA CIU Safeguard teamwill assist all project partners to ensure the up dated ESMP is managed andmonitored throughout the life of the project.
The projects specific Grievance Redress Mechanism (GRM) has been up dated andhas been disclosed on the FSM IA website (DTC&I), DOFA – CIU web sites.
Understanding and access to the projects GRM will be included in the stakeholder
awareness program. The up dated GRM is attached in Annex 4.

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8

ENVIRONMENTAL & SOCIAL MANAGEMENT PLAN
8.1 Introduction

The original ESIA Environmental & Social Management Plan (ESMP) was organized
into two cross‐referenced tables, namely the Environmental and Social Mitigationtable (ESMiT) and Environmental and Social Monitoring table (ESMoT). Throughinternal discussion the projects updated ESMP has been upgraded to include:i.
Reduced to one single table, which includes mitigation and monitoring
aspects; andii.
Additional requirements for the terrestrial scope of works (pre-construction,
construction and operational phases) to be more user friendly and to reduce
repetition.
The updated table details the mitigation measures and monitoring actions that the
Implementing Agency (IA) has committed to implement, from the planning through tothe operating period of the project. This approach makes for an ESMP that ispractical and can be easily used. The ESMP will inform the terrestrial Contractor’s
ESMP which will be prepared following detailed design. These tables are to be
included in the respective bid documents.
The up dated ESMP table is included in Annex 5.

8.2 Performance Indicators
The original ESIA performance indicators and their justification remain applicable tothe project and as such only minor changes have been made to reflect the known
cable alignment path, including marine and terrestrial components. The indicators
included:
Given that nearly all of the potential negative impacts could arise during cableinstallation, and that robust environmental contract clauses will be able to avoid all
impacts, key performance indicators will be as follows:i.
Confirmation that the ESMP tasks are defined as specific individual orgrouped environmental and social clauses in the contract bid documents forcable laying (marine and terrestrial);
ii.
Confirmation that environmental management criteria are included as part ofthe cable laying contractor/s selection process, including their experience
preparing and implementing ESMPs, working in sensitive tropical locations
such coral reefs, seagrass meadows, mangrove forests, coastal and riparian
ecosystems and offshore seamounts;iii.
The DOFA CIU Safeguard team have marine – terrestrial ecology and social
expertise and will support the Implementing Agency (IA) by providing
assistance with ESMP implementation, contractor briefing on marine andterrestrial habitat protection, contractor ESMP supervision (including
observations during cable laying within the reef), and participation incommunity consultation;iv.
A written record of the briefing on safeguards and inspection ofvessels/machinery, according to the tasks as they are defined in the ESMPand contract specification, completed with the survey and cable placement
contractors, as soon as the contractors have been selected.
v.
Compliance monitoring checklists prepared and being used by the contractor
and safeguards consultant and due diligence notes, completed as defined in

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vi.

vii.

the ESMP, and making the notes available in an easily accessible file for thecontractor, PC, PMU, and others to use.
A written mitigation and monitoring completion report, listing all mitigation andmonitoring measures defined in the ESMP, their implementation timing,monitoring and any follow up actions; and,A written record of interviews with local fishers, farmers and landowners
adjacent to the terrestrial cable alignment discussing any cable placement
issues.

The DOFA CIU Safeguard team will be responsible for preparing a performanceindicator report on behalf of that party’s PMU, by listing the seven items above andproviding a short text to indicate how these items were implemented and theirsuccess as of the start of the operating period of the project.

8.3 Implementation Arrangements
8.3.1 Overview
The original ESIA report included all three EMC countries as required. The below
describes the up to date country arrangements and details the requirements of theKosrae component.
The EMC Project involves three countries (FSM, Kiribati and Nauru), each with theirown project funding supported by either the World Bank (FSM) or ADB.
The
development and implementation of the joint components of the EMC Project areadministered through the East Micronesia Cable Management Committee (MC),which is comprised of one members from each of the participating countries andfunctions as the projects overall central Project Management Unit (PMU). The MC
will hire an Administrative Project Manager (APM) who’s role is to support the MC
and is responsible for the management of all project components that are jointly own
by the three nations (in general everything under water) and essentially functions as
the project coordinator.
Each of the three project recipient nations is individually responsible for project
development and management requirements within their own territory, which
includes the BMH, CLS and front, haul cable. To manage the FSM and Kosrae
component sections of the EMC, two Technical Project Manager (TPM) positions areto be recruited to manage the technical requirements of the marine and terrestrial
components, respectively of the project. The TPM will report to and be managed by
the OAE. The implementing agency for the Kosrae (FSM) component of the project isthe FSM DTC&I, whilst the OAE will manage the EMC project.
The IA is responsible for implementing the ESMP and complying with the safeguards
policies of the WB. Two cable laying contractors will be contracted by the OAE on
behalf of the IA to supply; i) all undersea components of the project up to the BMH
and; ii) all terrestrial components including the BMH through to the CLS.
The
projects IA will be responsible for day‐to‐day project delivery including thesupervision of the cable laying contractors. The OAE will continue this role once theproject is completed for the purpose of owning and operating the long term interest in
both the undersea and terrestrial components of the EMC.
The IA throughdiscussions with relevant project contractors is responsible and has identifying thefinal location of land based infrastructure (BMH, CLS and cabling), securing land
access (lease or easement), and will procuring contractors, supervise the marine andland‐based works, in association with the DoFA CIU Safeguard team deliver andEast Micronesian Cable Project – ESMP Kosrae Component Addendum Update – June 202044

manage the projects stakeholder consultations and manage complaints andgrievances.

8.3.2 ESMP Implementation Arrangement
The original ESIA suggested implementation arrangements have under gone minorchanges and are updated in the below section. The key change includes theinclusion of the DOFA CIU Safeguard team (International Safeguard Advisor andNational Safeguard Coordinator) as the Safeguard Advisor role and the inclusion of a
Kosrae based safeguard assistant to assist in the day-to-day management ofsafeguard compliance issues during the implementations of the project (near shore
and terrestrial construction phases).
ESMP activities relating to cable laying will be coordinated and managed by the IA
OAE on behave of DTC&I, which may delegate some/all responsibility to the DoFACIU Safeguards team as needed for the duration of the implementation period.
ESMP activities during undersea cable laying are to include:▪ Ensure safeguards clauses (EMP) are included in the cable laying bid
documents;▪ Review and clearance of the terrestrial cable laying Contractor’s CEMP;▪ Review and comment on detailed design, detailed marine surveys and othertechnical outputs;▪ Remote and site‐based supervision of the cable laying contractor, particularly
when the cable is being laid in the nearshore / foreshore environments;▪ Updates to the ESMP, if required; and▪ Reporting safeguards activities and progress on a quarterly basis.
ESMP activities during the terrestrial cable laying include:
▪
▪
▪
▪
▪
▪
▪

Ensuring land acquisition and resettlement is voluntary and is carried out inaccordance with WB safeguards policies (if required);
Ensuring land access documentation is obtained before construction starts;
Managing consultation, disclosure of information, keeping records ofconsultations and providing feedback to relevant agencies;
Receiving and recording grievances and complaints, and managing theirresolution;
Remote and site‐based supervision of local contractors for compliance with
the ESMP, including managing any non‐compliances and incidents;
Obtaining local permits or environmental approvals, including preparing any
documentation and communications with environment agency staff; andReporting safeguards activities and progress on a quarterly basis.

Training, oversight, support and capacity building to the IA and/or OAE as required,but particularly for consultation, voluntary land acquisition, management of non‐compliances and incidents, and obtaining local permits and approvals.
A DOFA CIU safeguard team serves as additional support to Kosrae States Kosrae
Island Resource Management Authority (KIRMA) to monitor and manage the project.

8.4 Institutional Capacity Assessment

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The projects original assessment of the capacity of the FSM and Kosrae state to
manage the safeguard requirements of the project remains valid and is supported.
The original narrative included:
Kosrae State appears to have competent staffs that work in the various
environmental consenting agencies, which have had some experience withprocessing EIAs associated with infrastructure projects support by developing
partners, including the WB.
Therefore, in light of the fact that the impacts of thisproject are expected to be minor in nature and extent, the capacity within theenvironmental agencies appears adequate, and there is not considered to be anyneed for changes to related institutional or organizational arrangements, capacity
development or training measures. The IA have indicated that they have capacity
to take on the responsibilities required to implement the Project subject to provisionof technical assistance offered by the WB.
The DOFA CIU Safeguards team has extensive experience in the implementation of
WB safeguards associated with submarine cables and other infrastructure projects.
The IAs and their respective project implementation teams will coordinate with the
DOFA CIU Safeguards team to ensure that the contractor/s complies with ESMP
requirements, which will be incorporated into contract(s). In addition, the cablesupplier, installation contractor and building contractors will be required to havesufficient ESMP implementation skills and resources within their team for theduration of their contract.
The WB will support the IA and DoFA CIU safeguard team as needed (requested),
and will provide ongoing safeguards support for the duration of the project. No
specific training is proposed.

8.5 Mitigation & Monitoring
8.5.1 Environmental
The original ESIA ESMP identified mitigation and monitoring actions have been up
dated to reflect the development of the project. These now include:
Marine: Monitoring will be required during cable installation in the field (likely to beless than one week), when the cable placement is ongoing nearshore. For the deep
ocean work the oceanographic survey is expected to be completed several weeks
ahead of the cable placement operation.
Terrestrial: Monitoring will be required during cable installations in the field (likely to
be up to 3 weeks) on a part time basis.
It is also expected that the DoFA CIU Safeguard team will actively participate instakeholder awareness activities needed to ensure community understanding andcompliance of the cable delivery, for both the marine and terrestrial safeguard
components.
As the safeguard team works for DoFA CIU and as such costs are funded throughother FSM projects, safeguard costs to this project have been reduced. However the
Safeguard team is based in Pohnpei and as such would require additional travelassociated costs to be provided by the project. This is expected to be up to
US$10,000. In addition, funds need to be considered for the engagement of a Kosrae
based local safeguard assistant for the duration of the cable construction period andEast Micronesian Cable Project – ESMP Kosrae Component Addendum Update – June 202046

additional time before and after to assist in stakeholder awareness and informationexchange programs. Expected costs would be up to US$6,000.

8.5.2 Social Development Programs & Resettlement Costs
The original ESIA estimated activities remain valid whilst the costs to deliver these
activities has been estimated at a maximum of US$5,000, a lower value thanoriginally costed. Justification for this includes:➢ Social mitigation and monitoring will involve at least five tasks as identified in
the projects up dated ESMP (Annex 5). Cost of community awarenessactivities such as community meetings/public consultations and informationmaterials prior to construction, during and after construction is expected to beup to US$5,000 for the complete development period.
As access on
Government or State land will be voluntarily donated, there is no landacquisition required for the project and therefore no budget allocated.

8.5.3 Total costs
The estimated total project costs for the environmental and social mitigation andmonitoring activities is estimated to be US$21,000 inclusively. This figure does notinclude the DOFA CIU Safeguard teams costs as these are provided under separate
funding package.

8.6 Reporting & Monitoring Requirements
All updated reporting requirements are specified in the ESMP (see Annex 5). In
summary quarterly progress reports from the DOFA CIU Safeguards team to theprojects IA (DCT&I and OAE) is required, and 6 monthly project report to WB (as per
normal reporting requirements under funding agreements).
At the end of the construction period the DOFA CIU Safeguard team in conjunction
with the OAE will prepare mitigation and monitoring completion report for the IAs tosubmit to the WB as required. The contractor will be required to submit progress
reports to the IAs, in addition to the oceanographic survey findings and a semi‐
annual summary of ESMP implementation. The DOFA CIU Safeguard team in
conjunction with OAE through its respective IA will prepare and submit a semi‐annualcompliance monitoring summary report, as well as the construction period mitigationand monitoring completion reports, once the facilities are fully installed. Monitoring
requirements are detailed in the ESMP.

8.6.1 Environmental Codes of PracticeThrough previous submarine cable development projects an international
Environmental Code of Practices (ECBP) for the deployment and installation ofsubmarine cables have been developed. The projects original ESIA refers to thisdocument and has acknowledged that these codes are relevant to this project. The
conclusions drawn remain valid and as such these codes remain as reported in theoriginal ESIA.
The ECBP lists many of the items defined in the updated ESMP and adds further
detail on boundaries and restriction to be adhered to by contractors conducting workin the marine and coastal environment. These codes had been prepared as acompanion volume to the original ESIA. These codes have not been repeated herein

East Micronesian Cable Project – ESMP Kosrae Component Addendum Update – June 202047

and reference to the original ESIA annex document should be undertaken as
required.

9.0 GRIEVANCE REDRESS MECHANISM (GRM)
The original ESIA GRM proposed was a generic framework system applicable foreach of the three nations involved in the EMC project. The GRM was scaled to therisks and adverse impacts of the project. If promptly addressed, concerns andcomplaints of potentially affected people using a clear and transparent process thatis gender responsive, culturally appropriate, and at no costs and without retribution,
can be resolved. The mechanism will not impede access to national or state judicial
or administrative procedures. The projects management unit will inform Affected
People (AP) about this GRM before commencement of any civil works, as part of theconsultation process. A grievance redress committee will be established to:▪ Record, categorize and prioritize the grievances;▪ Settle the grievances in consultation with complainant(s) and otherstakeholders;▪ Inform the aggrieved parties about the solutions; and▪ Forward the unresolved cases to higher authorities.
The Kosrae specific component GRM has been further developed since the originalsubmission of the ESIA through consultation with key national government (DTC&I),
projects management entity (OAE), Kosrae state government departments and semiautonomous entities within the state (KIRMA). The agreed updated GRM is includedin Annex 4 and has been disclosed on all required websites and is currently
operating.

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10.0 CONCLUSIONS & RECOMMENDATIONS
Overall, the proposed Kosrae component of the EMC Project will require very limited
land based infrastructure (BMH and CLS connected terrestrially via a cable alignment
path buried within a state road easement) with minimal marine and terrestrial based
impacts which are limited in scale and extent and can be fully mitigated, requiring no
involuntary land acquisition.
The project will impact a marine corridor of no more than 3‐4 m wide (including thefootprint of the submarine water‐jet trenching machine on the sea floor if used and toa maximum depth of 0.75 m beneath the sediment) and a terrestrial corridor width ofless than 1.0 m within the states road easement. The cable, about 4 cm in diameterat its largest in the shallow water areas of Lelu harbor through to the BMH, will beburied in nearshore areas and for all terrestrial connections.
The marine cable route will be resurveyed by the cable laying contractor but is tofollow, as closely as possible the suggested alignment route identified by the project
marine benthic assessment, which will ensure avoidance of sensitive marine habitats.
The cable placement is to be guided by experienced divers who will place the cableaccording to instructions from a marine ecologist based on the findings of the marine
benthic assessment report. These measures will serve to mitigate any potential
negative impacts on the marine environment.
The inclusion of UXO survey to ensure the shallow water marine cable alignment isfree from these items is recommended. It is thus recommended that the marine cableconsultants include this in their planning of the alignment when entering the Lelu
channel through to the BMH.
All priority land options to be traversed by the cable and associated infrastructure are
either government owned or leased, including all shallow water marine seafloor
areas.
Given the small scale impacts of the work within the marine and terrestrial
environment no negative social impacts are anticipated during any stage of the
project if the projects up dated ESMP is adhere to. The majority of the marine
activities take place on board a vessel at sea with specially trained crew, and suchno negative social impacts are anticipated during any stage of the project associatedwith the deployment of the cable to the BMH.
The construction of the BMH, CLS facilities and the cable connection between thetwo facilities on land will require a local sub‐contractor. In Kosrae, a key potential
impact relates to possible minor disturbance due to micro trenching of the cablewithin the road easement and entry and exit points along this corridor. To addressthese minor impacts the reinstatement of the disturbed areas is required as specified
in the projects up dated ESMP.
The updated ESMP defines a full set of working area boundaries, work restrictions
and timing limits, which will be included in the construction contract specifications
which the contractor/s are required to comply with. The projects technical manager in
conjunction with the DOFA CIU safeguard team will monitor compliance withassistance of a local contractor in Kosrae.

East Micronesian Cable Project – ESMP Kosrae Component Addendum Update – June 202049

11.0 REVIEW OF THE ORIGINAL ESIA ANNEXES
Table 3 below provides a brief summary of the continued relevance of the annex’s
provided in the original ESIA. These annexes are not included within this report andas such the original documentation should be referred. Their continued relevance tothe project includes:
Table 3: Summary and continued relevance of the original ESIA annexes.
Annexes.
There is confusion in the original ESIA documents between the main report annexes
and its final appendices document (separate document) in terms of annex numberingand activity. For the below summary review the final appendices documented in theoriginal separate document (Final) has been reviewed and annex numbers used inthis report are reflected below.
Annex 1: Baseline Data Report.
Baseline data was relevant to the original report. Information detailed can be usedas secondary supporting information to the updated Baseline data developed within
this up dated ESMP report.
Annex 2: Land Due Diligent Report.
Much of the information detailed relating to the Kosrae component is soundbackground information and has been superseded in the updated ESMP Addendum
report based on the final cable alignment entering the Island of Kosrae. Information
detailed pertaining to the land usage, management, ownership and usage remains
relevant and should be used as background information as required. Cable alignment
specific land use information has been updated within the main body of this reportand as such no changes are required to this original annex.
Annex 3: International Conventions & Treaties.
This section remains relevant and should be referred as required. No changes aresuggested.
Annex 4: Evaluation of Compliance with WB Standard Policy & ADB Safeguard
Policy Statement (SPS) Environmental Requirements.
The compliance assessment of the WB requirements for the Kosrae component
remains relevant to the project – no changes are required. This annex should bereferred as required.
Annex 5: Chance Finds Procedure.
This remains relevant to the Kosrae component and is included in this report (Annex
3).
Annex 6: Potential Cable Alignment and BMH sites.
This information is relevant to the original report and has been superseded by new
information detailing the final cable alignment path presented within the body of the
updated ESMP Addendum report.
Annex 7: Consultation Summaries.
This information is directly relevant to the original ESIA assessment, however
provides background information on the stakeholders who where engaged during theinitial assessment and as such remain relevant to this document.
The development of the ESMP addendum update was based on the DOFA CIU
Safeguard teams marine and terrestrial assessments and has included discussions
and input from OAE staff. Stakeholder discussions were undertaken with theGovernor and Lieutenant Governor, Kosrae state ICT working group during a FSM –WB ICT mission in 2019.

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The Kosrae state, Department Fisheries and Marine Resources (DFMR) staff
participated in the project marine assessment fieldwork and as such were an integral
component of this work.
The marine assessment draft report was provided to the OAE, DTC&I, Division of
Resource Economic Administration (DREA), DFMR and Kosrae Island Resource
Management Authority (KIRMA) for review and comment. All responses were
integrated into the final report.
The project including the ESMP will be presented and discussed during the initiationof the project in Kosrae state with specific stakeholder engagement undertaken withall communities, families, individuals and business that are in close proximity to thecable alignment. This will be undertaken by OAE and DOFA CIU safeguard team in
conjunction with Kosrae state stakeholders.
Annex 8: List of Attendees.
This information is directly relevant to the original ESIA assessment, however
provides background information on whom where engaged during the initialassessment and as such remain relevant to this document.
All future stakeholder attendees will be listed during the project development
Activities.
Annex 9: Environmental Mitigation (ESMiT) and Monitoring (ESMoT) Tables:
These tables have been reviewed (CIU Safeguard team, OAE, WB) andredeveloped/updated to reflect the information pertinent for the Kosrae Component
only. The new tables include additional terrestrial impacts (BMH – CLS) andmitigation methods. Through consultation the original two tables have beencombined into one table only to reduce the size of the documents and increase thepracticability of their use.
The tables are presented in Annex 5 of this report and provided to OAE in a
separated document (word and pdf) for ease of use when attaching to contracts.
NB: This was Annex 8 in the EMC – Project – ESIA – Final document.
Separate Document: Submarine Cable Environmental Codes of Practice.
This document remains useful and applicable to the Kosrae component and as suchis retained. It has been attached separately in its original form and in the sameformat as original attached in the ESIA.

East Micronesian Cable Project – ESMP Kosrae Component Addendum Update – June 202051

11.0 APPENDICES – UPDATED ESMPANNEX 11.1 Ownership Documents of the Proposed Beach Man Hole
(BMH), Sansrit School, Kosrae.

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East Micronesian Cable Project – ESMP Kosrae Component Addendum Update – June 202053

ANNEX 11.2 Ownership Documents of the Proposed Cable Landing Site
(CLS) in Kosrae.

East Micronesian Cable Project – ESMP Kosrae Component Addendum Update – June 202054

East Micronesian Cable Project – ESMP Kosrae Component Addendum Update – June 2020

55

ANNEX 11.3 Chance Find Procedure.
When a person working on the project discovers a cultural heritage site or item, thefollowing procedures should be followed:
▪
▪
▪

▪
▪
▪
▪

Stop the activities in the area of the chance find;Delineate the discovered site or area (e.g. fencing);
Secure the site to prevent any further disturbance, damage or loss. In casesof human remains, arrange for a guard to watch the site until the police, local
government and/or National/State Cultural Commission representative or
person with delegated authority arrives and take over the responsibility of thesite;
Prohibit the collection of objective by any person;
Notify the local government and Historic Preservation Offices (whereavailable) within 24 hours (and police if it is human remains);
Any objects that are found must be handed over to the Historic Preservation
Office.
Project works can resume only after instruction is provided from the HistoricPreservation Office.

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56

ANNEX 11.4 The Kosrae Components Grievance Redress Mechanism (GRM).

FEDERATED STATES OF MICRONESIAPACIFIC REGIONAL CONNECTIVITYPROGRAM (ICT) Kosrae Component

Environmental and Social Management Plan

Grievance Redress Mechanism(Projects Complaint Process)June 2020

East Micronesian Cable Project – ESMP Kosrae Component Addendum Update – June 202057

1. Principles of the Complaints Process (GRM)➢

The Complaints process is for people seeking satisfactory resolution of theirconcerns and/or complaints on the environmental and social performance of
the East Micronesian Cable Project based at the Department of Transport,
Communications and Infrastructure (DTC&I) at the FSM national government
in the Federated States of Micronesia (FSM) in conjunction with the FSM
Telecom Cable Corporation.
➢ This Process is consistent with the Project’s Environmental and Social
Management Framework (ESMF), Environmental Management Plan (EMP)
and projects Grievance Redress Mechanism (GRM) and is directly related
Kosrae ICT State project.
➢ The mechanism will ensure the following:• Basic rights and interests of every person affected by the projects
environmental performance or social management of the project areprotected; and• Their individual concerns arising from the performance of the projects
environmental and social performance during the project phases ofdesign, construction and operation activities are effectively and timely
addressed.

2. How to get in Touch with the Project
Anyone can ask for information on the project, express a concern, make a complaint(grievance) or get in touch with the project for any reason. Complaints/concerns canbe anonymous and the various ways to get in touch with the project include:
National Contacts:
Department of Transport, Communications & Infrastructure (DTC&I)
All correspondence to: Assistant Secretary, Mr. Mark DeOrio.
1. By Phone: (691) 320- 2865
2. By email: mark.deorio@gmail.com copy to beulah.FSM@gmail.com andwkilmete@yahoo.com
3. By mail: Post Office Box PS-2, Palikir, Pohnpei, FSM 96941
4. In person: DTC&I Office National Government, Palikir, Pohnpei, Federated
States of Micronesia. Given to the Departments Office Secretary.
5. Website: www.ict.fm/contact
FSM Telecom Cable Corporation
All correspondence to: Mr Pieter Bakker, Chief Executive Officer and Mr. Gordon
Segal Manager Operations and Chairman Management Committee (EMCS).
1. By Phone: (691) 320- 2602
2. By email: pieter.bakker@fsmcable.com, gsegal@fsmcable.com or

info@fsmcable.com copy to beulah.FSM@gmail.com andwkilmete@yahoo.com
3. By mail: Post Office Box 2202, Kolonia, Pohnpei, FSM 96941
4. In person: Ocean View Plaza (East Wing) Suite 15, Kolonia, Pohnpei,
Federated States of Micronesia. Give to the Office Secretary.
5. Website: www.fsmcable.com

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Kosrae State Project Sites:
All correspondence to: Mr. Gordon Segal Manager Operations and Chairman
Management Committee (EMCS). Mr Segal will manager the project until a Kosrae
project manager is appointed. This will be undertaken before the commencement ofworks.
1. By Phone: (691) 320-2602
2. By email: gsegal@fsmcable.com and copy to beulah.FSM@gmail.com andwkilmete@yahoo.com
3. By mail: Post Office Box 2202, Kolonia, Pohnpei, FSM 96941
4. In person: C/O Ocean View Plaza (East Wing) Suite 15, Kolonia, Pohnpei,
Federated States of Micronesia. Give to the Office Secretary.
5. Website: www.fsmcable.com
This information, and a brief summary of the process for answering queries andmanaging grievances, will be published on the DCT&I, FSM cable and Department of
Finance and Administration (DoFA).

3. Roles and Responsibilities:
The following are persons involved in the complaints process and their supporting
roles and responsibilities.
➢ Focal Point for managing the FSM ICT projects Complaints Process: Mr.
Gordon Segal, Manager of Operations for the ICT cable Project(gsegal@fsmcable.com).
➢ Person who will manage the database and record keeping: Mr. Wilmer
Kilmete in coordination with Mr. Steve Lindsay and Ms. Beulah
Daunakamakama at the Central Implementation Unit (CIU) of the FSM
Government Department of Finance & Administration.
➢ Person who will answer simple queries and manage simple complaints: Mr.
Gordon Segal, Manager of Operations for the ICT cable Project(gsegal@fsmcable.com).
➢ Person who will manage difficult complaints or grievances: Mr. Gordon Segal,
and/or Mr. Pieter Bakker for the ICT cable project and Mr. Mark DeOrio,Acting Secretary DCT&I with support from CIU.
➢ Person/organization who will prepare report/s for World Bank reporting: CIU
safeguard team.
➢ Grievance Committee will be formed on an ad hoc basis for complex orsignificant grievance management. This will be made up of appropriatesenior officials (Assistant Secretary level or above) from the following:• Department of Finance & Administration (DoFA) with support from CIU
Safeguards Specialist; and• Department or Office managing the project at which the complaint isaimed (FSM Telecom Cable Corporation).

4. The Complaints Process:➢All complaints or grievances will be entered into an assigned database thattracks progress of each complaint/grievance. Complaints records (letter,email, record of conversation etc.) are stored both electronically and in hard
copy. Each record has a unique number reflecting year and sequence ofreceived complaint (i.e. 2019-01, 2019-02 etc.).
➢ Each complaint/grievance is assigned a specific person responsible for its
management and close out.
➢ Each complaint or grievance will have a plan for addressing and closing out:

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59

•

➢
➢
➢
➢

If the complaint/grievance relates to a contractor activity, the project will
ensure the Contractor remedies any damage, pays compensation fordamage or loss, etc.
• Use of community leaders and customary methods of conflict resolution
is encouraged and utilized if and when appropriate – on a case-by-casebasis.
• If an issue/complaint cannot be resolved on site, it is elevated to theProject Manager for resolution (with support from the Safeguards
Specialist in the CIU). If the Project Manager and Safeguards Specialist
cannot resolve the issue, it is referred to the ad hoc GrievanceCommittee.
• If a resolution cannot be found through the Grievance Committee, thenext course of action is the courts of FSM or an independent mediator.
All simple complaints and grievances must aim to be closed out within 1month.
Complex complaints should aim to be closed out within 3 months or deferredto the Grievance Committee.
All complainants have the right to use the courts of FSM at any time to seek
resolution, if and when required.
The ICT Project Manager will make adjustments to consultations, the GRM,
community engagement, project implementation and other aspects asnecessary to avoid future complaints and grievances if and when required.

5. Reporting and Evaluation:➢

Complaints shall be reported in the regular project reporting to the World
Bank. It should contain:• Total number of complaints/grievances received.
• Total number resolved.
• Total number under investigation/not yet resolved.
• Total number not yet resolved and also exceeds the recommended closeout time of 1 month or 3 months.
➢ Short paragraph on any significant grievances currently not yet resolved andany risks to project implementation.
• If there are more than 30 complaints/grievances recorded, the ProjectManager may decide to investigate any patterns or repetition of issues
that need addressing. The Project Manager may decide to get an
independent consultant to review and provide advice.

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ANNEX 11.5 Environmental and Social Impact Mitigation and Monitoring Table Updated for Kosrae Component Only – Marine
and Terrestrial Cable Alignment - Scope of Works.
Environmental
Parameters

Project
ImpactMitigation Measures

Location

Monitoring Action

Timing/Duration

Implementation

Supervision

1.0
PRE-CONSTRUCTION PERIOD (Planning and design actions to prevent impacts)
1.1 Physical Environment
Land Access

Air Quality –Pollution

Unable tosecure access tosites identified
for the cablealignment(marine &terrestrial).
Green House
Gas emissions
from vessels.

Substrate

Use of foreignmaterials forfilling cable
trench, causing
unknown
pollution.

UXO

Failure tocomplete an
unexploded
ordinance (UXO)
sweep of thecable route as itenters thecoastal waters(Lelu channel –harbor - BMH)
could lead to
explosion,damage to the▪ Acquire landowner ownership and approvals before
work begins.
▪ Transfer of any entitlements & keep documentation.
▪ Identify other sites on other government landparcels.

BMH &CLS sites
identified
in ESMP.

Confirm land accessownership andagreements are finalized
and meet approval
process.

Prior to startof
installation.

FSM TCC (OAE)
DTC&I.

FSM TCC(OAE) &
CIU safeguard
team.

▪ Require vessel emission certification (RE: SO2,
NO2) to be submitted in contract specifications tomeet USEPA or equivalent emissions standards.
▪ A smoke stack density test is required to ensurecompliance to USEPA or equivalent emissions
standards.
Contractor’s specification to include;➢ All backfill to be previously excavated material
where possible (marine & Terrestrial).
➢ Only inert/stable materials are to be used in
cable laying and anchoring.
➢ Be aware of unexploded WWII munitions.
Conduct a UXO survey of the cable alignment as it
passes through barrier reef, Lelu channel and Lelu
harbor through to the landing site. (Sansrit school).
IF UXO is located immediate action required includes;➢ Instigate immediate appropriate heath andsafety arrangement of all workers and generalpublic including notification of Kosrae Policeand government agencies (including Governors
office).
Secondary action to discuss requirements to finalizealignment, possible actions include;➢ Alternative route to be investigated within the
projects agreed cable alignment pathway (direct

Entirecable
route.

Confirm contract
specifications andcompliance certification.

Prior to startof
installation.

FSM TCC (OAE)
DTC&I.

FSM TCC(OAE) &
CIU safeguard
team.

InshoreCoastal &Terrestrial
areas.

Confirm contract
specifications andcompliance certification.

Prior to startof
installation.

FSM TCC (OAE)
DTC&I

FSM TCC(OAE) &
CIU safeguard
team

InshoreCoastalareas.

Conform and obtain
documentation of UXO
benthic assessment(sweep) completed.

Prior to startof any cablelayingactivity.

FSM TCC (OAE)
DTC&I.

FSM TCC(OAE) &
CIU safeguard
team.

Follow up on assessment
findings – as required.

Environmental
Parameters

Project
Impactcable
infrastructure
and loss of life.

Hydrothermal
Vents

Sea Mounts

Physicaldamage to vents
by cable orcable- laying
equipment.
Smothering bydisturbing area
sediments.
Physicaldamage tocable, given the
300 Co ventwater
temperature.
Physicaldamage tohabitat,resources andpossible impact
on demersal
fishery usage.

Mitigation Measuresand indirect area of influence);➢ Removal of UXO (explosion in situ ortranslocate); and➢ New submarine alignment outside of proposed
pathway – this may require additional marine
and foreshore benthic assessment.
In construction contract - specifications requiring
survey team to identify a cable route that maintains aminimum clearance of 2 Km from active hydrothermal
vents and specify this route in the cable-laying
specification.

Location

Monitoring Action

Timing/Duration

Implementation

Supervision

Deep seamarineareas.

Confirm adequate
specifications arepresentation in bid
documents.

Duringcontract
specification
preparations

FSM TCC (OAE)
DTC&I.

FSM TCC(OAE) &
CIU safeguard
team.

In construction contract - specifications requiring
survey team to identify a cable route that maintains aminimum clearance of 2 Km from base of seamounts
and specify this route in the cable-laying specification.

Deep seamarineareas.

Confirm adequate
specifications arepresentation in bid
documents.

Duringcontract
specification
preparations

FSM TCC (OAE )DTC&I.

FSM TCC(OAE) &
CIU safeguard
team.

▪ In bid documentation, require bidders to provide
specifications of the fuel and lubricant management
equipment and storage on vessels used during thesurvey and cable laying operations and certify thatthe installations in in compliance with national
regulations and-or MARPOL specifications for fuelmanagement.
▪ Maintain a contingency plan to address spills.
Prepare final alignment based on detailed design
demonstrating avoidance of significant marine andcoastal ecological systems. Including specifically incontract specifications;➢ Cable survey team to survey cable alignment

Offshoreandinshorecoastalareas.

Confirm adequate
specifications arepresentation in bid
documents.

Preparing
construction
bid contract
documentation.

FSM TCC (OAE)
DTC&I.

FSM TCC(OAE) &
CIU safeguard
team.

Inshoremarine,coastalareas.

Confirm adequate
specifications arepresentation in bid
documents.

Prior to startof
installation.

FSM TCC (OAE)
DTC&I.

FSM TCC(OAE) &
CIU safeguard
team.

1.2 Ecological Environment
Coastal marineand deep ocean
habitats

Accidental
discharge ofpollutants fromvessel andvesselgrounding.

Sensitive nearshore ecologicalhabitats andresources (coral
reefs, sea grass,

Failure to planroute aroundcoral
communities.

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62

Environmental
Parameters

Project
Impactmangroves)

Damageseagrass &mangrovecommunities
due to cable
placement.
Disturbance ofmarine &terrestrialorganisms andhabitats inprotected –managed areas.

Conservation
Areas (PA)Marine species
potentially atrisk (cetacean,turtles,
endangered
species etc)

Ocean sonar
survey affecting
cetaceans.

Vegetation
clearance

Disturbance &/or
removal ofvegetation within
the cablealignment (roadeasement).

Entanglement in
cable by deep
diving cetaceanssuch as thesperm whale.

Mitigation Measuresaround all coral reefs, avoiding all coraloutcrops, and following defined shipping
channels as detailed in marine benthic
assessment report, and➢ Cable`s placement must be confined to anarrow path as possible.
▪ Cable alignment to avoid all Conservation Area
(CA) – Management – Protected Areas.
▪ Define in contract specifications, via GPS andsurvey markers, a cable route that provides ≥ 75 m
distance from CA boundaries, and requires all
survey and cable laying vessels to maintain thisdistance at all times (limited by the proximity of CAs
to the shipping channel).
Contract specifications to include reference to bestpractices for operating vessels in proximity to marine
mammals as included in Environmental Code of good
Practice document, including:➢ Survey timing outside whale presence/migrationseason, namely between May and October.
➢ Post a watch for whales and suspend activities
when whales are within 1 Km of vessel.
➢ Multi-beam and/or side-scan sonar only – No
Air Guns.
Prepare final alignment based on detailed design
demonstrating avoidance where possible to reduce
and/or eliminate removal of road side vegetation (e.g.
trees). Including specifically in contract specifications;➢ Cable survey team to survey cable alignment
within the road easement to avoid vegetation
impacts and/or removal, and➢ Cable`s placement must be confined to anarrow path as possible.

Location

Monitoring Action

Offshore,Inshore,Coastal &Terrestrial
areas.

Confirm adequate
specifications arepresentation in bid
documents, as detailed in
the ESMP.

Oceanic
deep-sea
andcoastalmarineareas.

Timing/Duration

Implementation

Supervision

Prior to startof
installation.

FSM TCC (OAE)
DTC&I.

FSM TCC(OAE)
CIU safeguard
team.

Confirm adequate
specifications are included
in bid and contract
documents.

Preparing
construction
bid contract
documentation.

FSM TCC (OAE)
DTC&I.

FSM TCC(OAE) &
CIU safeguard
team.

Terrestrial
areas.

Confirm adequate
specifications arepresentation in bid
documents, as detailed in
the ESMP.

Prior to startof
installation.

FSM TCC (OAE)
DTC&I.

FSM TCC(OAE) &
CIU safeguard
team.

FSM andon siteKosrae.

Confirm safeguard staff/s
are engaged and fully
briefed at start of the
project.

At start ofdetailed
design stage
for theproject
duration.

FSM TCC (OAE)
DTC&I.

CIU safeguard
team & FSM
TCC (OAE)

1.3 Socio-Economic Environment
ESMP safeguard
implementation& monitor

Inexperienced
technician
leading todelayed or failed
implementationof ESMP items,
e.g. no clauses

Ensuring safeguards monitoring is undertaken for theduration of the project (especially construction phase)to help in implement and monitor the delivery of the
ESMP.

East Micronesian Cable Project – ESMP Kosrae Component Addendum Update – June 2020

63

Environmental
Parameters

Project
ImpactTiming/Duration

Implementation

Supervision

Confirm adequate
specifications are included
in bid and contract
documents.

Before civil
work starts.

FSM TCC (OAE)
DTC&I.

FSM TCC(OAE) &
CIU safeguard
team.

Residents
withaccess toproperty
affectedbytrenchingand cable
installation
works.

Confirm adequate
specifications are included
in bid and contract
documents.

Before civil
work starts.

FSM TCC (OAE)
DTC&I.

FSM TCC(OAE) &
CIU safeguard
team.

Kosraeandresidents
directly
impactedby theproject.

Confirm adequate
stakeholder consultations
have been undertaken andstakeholders aware.

During all
stages of the
project.

FSM TCC (OAE)
DTC&I.

FSM TCC(OAE) &
CIU safeguard
team.

Kosraeandresidents
directly
impacted

Confirm GRM
requirements are included
in bid and contract
documents.

Before civil
works begin.

FSM TCC (OAE)
DTC&I.

FSM TCC(OAE) &
CIU safeguard
team.

Mitigation Measures

Location▪ Update EMP to reflect the final scope of works anddevelop consent conditions included in bid
document.
▪ Contractor prepares and submits terrestrial CEMP
for approval before works start.
Contract specifications to include instruction RE: full
rehabilitation immediately after completion of trenchingworks. Develop notification protocol to provide noticeof access restrictions, comprising the following steps:➢ Notification of the roadside residents bycommunity workshop/s & individual verbal
information exchange providing details of the
project, potential access restrictions and likely
timing of activities;➢ Follow‐up communication to confirm awareness– understanding and offer further consultation;➢ On‐site meetings with affected residents
individually or group; and➢ “Door‐knock” notifications of residents 48 hours
prior to trenching to provide details of work
program, duration of access restriction andcontact details in case of grievance.
Conduct of series of government and non-government
community stakeholder consultations prior tocommencement of civil works, during construction andafter project completion.

N/A

Establish GRM prior to commencement of civil works
for use throughout the life of the project and ensure
project stakeholders are aware of it usage.

Monitoring Actionin the bid docs.
Update EMP, bid& contract
documentation,bid evaluationetc
Access during
terrestrial
trenching &cable installation
works

Environmental
responsible –procurement &compliance withCSS.
Failure ofcontractors todeliverytrenching works
with minimal
damage &accessrestrictions toproperty.

Community
Information
Engagement

Misconceptions
raising people’s
misunderstanding (fears)
regarding project
footprint andpotential
damages tomarine foodsupply, land
usage & land
loss.
Minor
concerns/issues
developing
community
resentments due

Community
Grievances

East Micronesian Cable Project – ESMP Kosrae Component Addendum Update – June 2020

64

Environmental
Parameters

Cultural Heritage

CoastalResource Users- subsistence
and artisanal
fisheries

Project
Impactto unaddressed
project related
concerns.
Possible
damage tocultural heritagesite/s due toplacement of thecable.
Damage toecosystem
integrity andfishery
productivity
through loss ordamage to local
fishing grounds.

Mitigation Measures

Location

Monitoring Action

Timing/Duration

Implementation

Supervision

At start ofdetailed
design stage
for theproject
duration.
At start ofdetailed
design stage
for theproject
duration.

FSM TCC (OAE)
DTC&I.

FSM TCC(OAE) &
CIU safeguard
team.

FSM TCC-OAE
DTC&I.

FSM TCC(OAE) &
CIU safeguard
team.

From thetime thevesselbegins workon thisproject.
All seafloor
trenchingoperations.

Contractor (s)FSM TCC(OAE) &
CIU safeguard
team.

Contractor (s)FSM TCC(OAE) &
CIU safeguard
team.

When work
is undertaken.

Contractor (s)FSM TCC(OAE) &
CIU safeguard
team.

by theproject.
Cable alignment (marine and terrestrial) and otherscope of works to be assessed for cultural heritage
implications in collaboration with
communities/landowners before proceeding with cable
deployment.

Coastalandterrestrial
areas.

Confirm adequate
specifications are included
in bid and contract
documents.

Using the data on design recommended in this ESMP
prepare contract specifications defining
trenching/cable laying activities to be limited to anarrow corridor and trenching to be followed by
immediate burial.

Oceanic
deep-sea,
coastaland harbormarineareas.

Confirm adequate
specifications are included
in bid and contract
documents.

2.0 CONSTRUCTION PERIOD: Impacts associated with the work
2.1 Physical Environment
2.1.1 Marine
Air Quality Pollution

Emissions fromsurvey andcable placement
vessels.

▪ Zero tolerance and immediate repair required—as
specified in Contract specifications (stack emissions& stack smoke tests).
▪ Vessel fined and shut down within 5 days of notice.

At allmarinevesselwork sites.

Contractor to provide
emissions test results.

Substrate

Introduction offoreignsubstances
reacting withenvironment or
introduced
medium for
introduced
organisms.
Physicaldamage to ventsor cable.

Contractor to insure that:➢ All backfill use only original material as percable laying specifications.
➢ Use only inert/stable materials in cable laying
and anchoring as per cable laying
specifications.

InshoreCoastalareas.

Site inspections to ensurecompliance to ESMP.

As per contract specifications, lay cable along
surveyed alignment, which has identified anyhydrothermal vents and maintains a minimum
clearance of 200 m from active hydrothermal vents toprotect the site(s).

Oceanic
deep-sea
areas.

Hydrothermal vents
detected during initial
ocean floor survey,
periodic check cablealignment to ensure it

Hydrothermal
Vents

East Micronesian Cable Project – ESMP Kosrae Component Addendum Update – June 2020

65

Environmental
Parameters
Sea Mounts

Project
ImpactMitigation Measures

Location

Monitoring Action
complies with ESMP
specifications.
Seamounts identified
during initial & detailed
design, periodic check
cable alignment to ensure
it complies with ESMP
specifications.

Timing/Duration

Implementation

Supervision

When work
is undertaken.

Contractor (s)FSM TCC(OAE) &
CIU safeguard
team.

Physicaldamage tohabitat andpossible fisheryusage.

As defined in the contract specifications, lay cablealign designated survey route, which maintains aminimum clearance of 2 km from the base of
seamounts.

Oceanic
deep-sea
areas.

Emissions fromall vehicles andmachinery used
to deploy thecable.

Ensure all vehicles and machinery used are;
➢ Maintained and operated in accordance todesign standards and specifications;➢ Turned off when not in use;
➢ Only vehicle and machinery undertaking work
are on site.
Ensure dust management measures are implemented
at all construction site including;▪ Restrict speed on roads when woks being
undertaken;➢ Cover all vehicles to prevent load spillage, dust
& sludge (e.g. waste material transportation);➢ All stockpiles to be covered to prevent dust
dispersion through wind; and➢ Schedule/staging of proposed works to ensure
no impacts from trenching and waste material.
▪ Construction vehicles and equipment to maintainedin good working order and regular equipment
maintenance will be undertaken.
▪ Construction vehicles and machineries will be fittedwith mufflers and other noise abatement equipment
as necessary.
▪ Limit noisy construction activities to be between
7am and 5pm on Monday to Saturday. No work is
to be undertaken on Sunday (Kosrae state law).
▪ Workers will be provided with noise abatement
equipment (PPE) as required.
▪ The contractor will deal with any complaints
regarding noise in the first instance through the
GRM.
▪ Preparation of sedimentation and erosion control

At allterrestrial
work sites.

Vehicle inspections toensure compliance to
CEMP mitigation
measures.

From thetimevehicles andmachinerywork on thisproject.

Contractor (s)CIU safeguard
team & FSM
TCC (OAE).

At allterrestrial
work sites.

Periodic vehicle and site
inspections to ensurecompliance to CEMP
mitigation measures.

From thetimevehicles andmachinerywork on thisproject.

Contractor (s)CIU safeguard
team & FSM
TCC (OAE).

At allterrestrial
work sites.

Periodic vehicle and site
inspections to ensurecompliance to CEMP
mitigation measures.

From thetimevehicles andmachinerywork on thisproject.

Contractor (s)CIU safeguard
team & FSM
TCC (OAE).

At allConfirm sediment andFrom theContractor (s)CIU safeguard

2.1.2 Terrestrial
Air Quality Pollution

Increase in dustlevels on site
and neigbouring
land parcels
from vehicles
and machinery
used.

Noise &
Vibration fromconstruction
equipment andmachinery

Increase noise &vibration incommunity(residential &commercial).
Impact on
construction
workers.

Sediment &Increase erosion

East Micronesian Cable Project – ESMP Kosrae Component Addendum Update – June 2020

66

Environmental
Parameters

Project
Impacterosion fromconstruction.

andsedimentation insurrounding
environment
including stream
and downside
foreshore areas.
Increased
turbidity ofwatercourses
due toconstruction.

Constructionwaste material
use andmanagement.

Introduction offoreignsubstances
reacting withenvironment or
introduced
medium for
introduced
organisms.
Waste material
reused or
disposed inapproved sites.

Use, storage &transportation ofHazardous
substances) e.g.

Pollution fromuse, storage &accidental spillsof hazardous

Mitigation Measures

Location

Monitoring Action

management plan as part of CEMP (complaint to
the ESMP specifications).
▪ All construction in areas of stream and coast to beundertaken with extreme care.
▪ Use of silt control devices and sedimenttraps/fences during all extraction activities, these to
be cleaned and dewatered as required.
▪ Avoid clearing areas during wet (rainy) season
where possible.
▪ Natural stream/river water flows in river will not beinterfered with.
▪ Use of heavy machinery in aquatic environments
minimized (used only if no other alternative).
▪ Gabion baskets, rock rip-rap or bio-engineering
measures to be used for all stream and foreshore
for stabilization if or as required.
▪ No discharge to rivers, surface water, intertidal or
coastal areas.
▪ No dumping, disposal or storage of spoils in or
close to streams and rivers.
▪ Placement of diversion ditches around stockpiles.
A Waste Management Plan (WMP) is to be developedand included in the project CEMP.
Contractor is to insure the WMP is compliant to the
ESMP including:➢ All backfill used only original material as percable laying specifications.
➢ Use only inert/stable materials in cable laying
and anchoring as per cable laying
specifications.
➢ All waste material dumped at a permitted(KIRMA) landfill site.
➢ Hazardous Waste Management plan to be
included in the CEMP and an emergency
response actin plan.
➢ Hazardous waste managed by contractor anddisposed at approved site.
▪ Contractor to prepare hazardous substancesmanagement plan (HSMP) and emergency
response plan (ERP) (as part of the CEMP).
▪ Spill kits to be provided at work sites and works

terrestrial
work sites.

erosion plan is compliant
to bid documents.
Periodic site inspections toensure compliance to
CEMP mitigation
measures.

At allterrestrial
work sites.

Confirm WMP is compliant
to bid documents.
Periodic site inspections toensure compliance to
CEMP mitigation
measures.

At allterrestrial
work sites.

East Micronesian Cable Project – ESMP Kosrae Component Addendum Update – June 2020

Confirm HSMP iscompliant to bid
documents.

Timing/Duration

Implementation

time
vehicles andmachinerywork on thisproject.

Supervisionteam & FSM
TCC (OAE).

From thetimevehicles andmachinerywork on thisproject.

Contractor (s)CIU safeguard
team & FSM
TCC (OAE).

From thetimevehicles andmachineryContractor (s)CIU safeguard
team & FSM
TCC (OAE).

67

Environmental
Parameters

Project
Impactfuel, oil etc)

substances.

Mitigation Measures▪

Accidentally
placing people
and environment
at risk.

▪

▪
▪
▪
▪
Construction
activities affectroad use and/or
access toproperty
including school(BMH).

Public accessaffected & traffic
disruption during
construction.

▪

▪

▪

▪

▪

▪

▪

yards and staff trained in their deployment.
Locate storage areas for all petrochemical products
from coastline and 100 m from stream/rivers.
Chemicals including fuel stored in secured(lockable), weather proofed area including animpervious flooring and bund/containment walls(110% of largest volume) to contain spillage.
Used oil and other hazardous materials will bedisposed of in an authorized facility off-site.
Spill waste will be disposed at disposal sites
approved by local authorities (KIRMA).
All spills cleaned as per emergency response plan.
Ensure any spills or accidents are reported andrecorded in register.
Prior to commencement of works, the contractor will
prepare and submit a Traffic Management Plan
(TMP) detailing controls, diversions andmanagement/safety measures for clearance.
The contractor and OAE will inform commuters,
providers of transport services and adjacentcommunity/business of duration and scope of works
and any alternative arrangements.
Clauses will be included in the contract specifying
that; (i) care must be taken during the construction
period to ensure that disruptions to access andtraffic are minimized and (ii) access toresidences/business along the road will always be
maintained.
Stakeholders and potentially affected people will be
consulted if access to specific areas will be
disrupted for any time and temporary accessarrangements made.
Use of signage, spotters and flaggers, safetybarriers suitable to the scale of the project to control
and regulate traffic flow and ensure safety forworkers and all users.
Ensure public safety across and around work site(s)including barriers to prevent entry to high risk areas(e.g. excavations, area with heavy machinery beingused) and ensure safe passages are provided
through work sites.
At all times, the road will be kept free of debris,

Location

At allterrestrial
work sites.

East Micronesian Cable Project – ESMP Kosrae Component Addendum Update – June 2020

Monitoring Action

Timing/Duration

Periodic site inspections toensure compliance to
CEMP mitigation
measures.

work on thisproject.

Confirm TMP is compliant
to bid documents.

From thetimevehicles andmachinerywork on thisproject.

Periodic site inspections toensure compliance to
CEMP mitigation
measures.

Implementation

Supervision

Contractor (s)CIU safeguard
team & FSM
TCC (OAE).

68

Environmental
Parameters

Construction
activities affectschooloperations andaccessSite earthworks(excavation &backfill)

Relocation of ordamage toexisting utilities& services.

Project
ImpactMitigation Measures

Schooldisruption during
BMH
construction andcable
deployment.

spoil, and any other material.
▪ All waste material to be disposed at approved
designated sites.
▪ Prior to commencement of works, the contractor will
prepare and submit a BMH Construction Plan(included in CEMP) detailing timing andmanagement/safety measures for the work. Plan to
be developed in conjunction with state Education
Department and school officials.
▪ Limit construction activities to designated school
holiday periods if possible otherwise restricted toweekend (Saturday only) or after school hours.

Vegetation
removal – minor
ecosystem
disruption during
construction –limited to roadcorridor.

Disruption of,interference with
and/or damage
to existing
infrastructure
and/or services.

Location

Monitoring Action

Work
undertakewithin near
Sansritschoolsite.

Confirm BMH construction
plan is compliant to bid
documents – specificallyoutlining schedule andtiming of work – nodisruptions to school.

▪ Vegetation clearance during construction activities,
especially of trees along the roadside corridor, will
be kept to a minimum and trees removed will be
discussed with landowners and an approved plan to
be developed.
▪ Under no circumstances is the contractor permitted
to fell or remove mangroves.
▪ Construction workers to be informed about generalenvironmental protection including and respect of
local (native and human) flora and fauna.
▪ Consult infrastructure and services providers (e.g.
FSM telecom, Kosrae Water and Power providers)before construction to identify on plans the locationof utility lines and pipes.
▪ Relocation plans, as required, to be agreed andimplemented.
▪ Any incidental damage to be immediately
notification and repaired as agreed with the utility
provider.

At allterrestrial
work sites.

According to contract specifications the contractor(s)to insure that they:➢ Lay cable along surveyed route providing for asafe distance (≥ 50m) from CA s as per cablelaying specifications.

InshoreCoastalareas.

Periodic site inspections toensure compliance to
CEMP mitigation
measures.
Confirm landowner’s
discussions undertaken
and project awareness isfully understood.
Periodic site inspections toensure compliance to
CEMP mitigation
measures.

At allterrestrial
work sites.

Confirm service providers
have been engaged andplans develop incompliance to bid
documents.

Timing/Duration

Implementation

Supervision

From thetime work at
this site isundertaken.

Contractor (s)CIU safeguard
team & FSM
TCC (OAE).

From thetimevehicles andmachinerywork on thisproject.

Contractor (s)CIU safeguard
team & FSM
TCC (OAE).

From thetimevehicles andmachinerywork on thisproject.

Contractor (s)CIU safeguard
team & FSM
TCC (OAE).

From thetime thevesselbegins workon thisContractor (s)CIU safeguard
team & FSM
TCC (OAE).

Periodic site inspections toensure compliance to
CEMP mitigation
measures.

2.2 Ecological Environment
2.2.1 Marine
Marine Coastal
Conservation
Areas

Disturbance ofmarineorganisms andhabitats in CA.

East Micronesian Cable Project – ESMP Kosrae Component Addendum Update – June 2020

Inspect cable laying
operation in coastal areas
to confirm compliance to
ESMP mitigation
measures (minimum

69Environmental
Parameters

Project
ImpactMitigation Measures

Location

Coastal andDeep Ocean
Habitats

Accidental
discharge ofpollutants fromvessel.

Sensitive nearshore ecologicalhabitats andresources (coral
reefs, sea grass,mangroves)

Destruction ofsensitive marine
ecologicalhabitats andresources (e.g.
corals, sea
grass,
mangroves).

Species of
special Interest –Cetaceans

Entanglement in
cable risk fordeep diving
cetaceans

Keep all survey and support vessels at safe
distances from CA areas.
Adhere to contract specifications and national laws thecontractor (s) to insure that they;➢ Containing all fuel, lubricants and transmission
fluids in double walled tanks on vessels and if indrums, store below deck, as specified incontract specifications.
➢ Maintain a contingency plan to address spills
and storm events.
Contractor(s) to adhere to specifications and lay cable
along proposed surveyed route, as per cable-laying
specification to ensure;➢ Avoidance of coral reefs, sea grass beds, andmangroves habitats.
➢ Contractor to adhere to designated cablealignment and map showing coral areas onroute from passage to landing.
➢ Restrict cable footprint to as narrow a path as
possible along entire length of shallow water
cable.
Control cable tension so that laid cable conforms toundulations of seabed as per cable laying specification
and-or provide anchors if needed.

Timing/Duration

Implementation

Supervision

From thetime thevesselbegins workon thisproject.

Contractor (s)CIU safeguard
team & FSM
TCC (OAE).

Inspect cable laying
operation in coastal areas
to confirm compliance to
ESMP mitigation
measures (minimum
distance from sensitive
habitats is maintained).

From thetime thevesselbegins workon thisproject.

Contractor (s)CIU safeguard
team & FSM
TCC (OAE).

Oceanic
deep-sea
areas.

Ensure cable laying
company aware ofcetacean sensitivities andconfirm compliance to
ESMP mitigation
measures.

From thetime thevesselbegins workon thisproject.

Contractor (s)CIU safeguard
team & FSM
TCC (OAE).

Coastalforeshore&terrestrial
areas.

Inspect cable laying
operation to confirm
compliance to CEMP
mitigation measures.

From thetimevehicles andmachinerywork on thisproject.

Contractor (s)CIU safeguard
team & FSM
TCC (OAE).

➢

Monitoring Action
distance from CA is
maintained).
Inspect cable survey &laying vessels to confirm
compliance to ESMP
mitigation measures.

project.

InshoreCoastalareas.

InshoreCoastalareas.

2.2.1 Terrestrial
Sensitive
terrestrial
ecologicalhabitats andresources(streams,
mangroves,birds).

Destruction ofsensitive
terrestrial
ecologicalhabitats andresources (e.g.
stream,mangroves).

Contractor(s) to adhere to cable laying specifications
along proposed surveyed route to ensure;➢ All activities within designated road easement
including approved lay down areas.
➢ Implement measures & controls to minimize
impacts on surround habitats.
➢ Avoidance of impacts to streambed, riparian
habitats and mangroves habitats.
➢ Resource extraction (flora and fauna) prohibitedby contracted.
➢ Restrict cable footprint to as narrow a path as

East Micronesian Cable Project – ESMP Kosrae Component Addendum Update – June 202070

Environmental
Parameters

Project
ImpactMitigation Measures

Location

Monitoring Action

Timing/DurationAllterrestrial
areas.

Inspect cable laying
operation and undertake
stakeholder discussions toconfirm compliance to
CEMP mitigation
measures.

InshoreCoastalareas.

Inspect cable laying
operation to confirm
compliance to ESMP
mitigation measures.

Implementation

Supervision

From thetimevehicles andmachinerywork on thisproject.

Contractor (s)CIU safeguard
team & FSM
TCC (OAE).

When work
is undertaken.

FSM TCC (OAE)
and/or Contractor(s)

CIU safeguard
team & FSM
TCC (OAE).

When work
is undertaken.

FSM TCC (OAE)
And/or Contractor(s)

FSM TCC(OAE) &
CIU safeguard
team.

possible along entire length of the cable.
Landowner’s
properties
adjacent to roadcorridor.

Destruction of
ecologicalterrestrial
systems (natural
and/or manmade) andproperty ownerresources (flora– food crops andfauna
domesticatedanimals).

Contractor (s) and workers under no circumstances
are permitted to enter and remove resources (flora &fauna) from properties adjacent to the road corridor.

2.3 Socio-Economic Environment
2.3.1 Marine
CoastalResource Users–
subsistence andartisanal
fisheries

Displacement ofactivities duringcable laying.
Entanglement offishing gear.
Damage toecosystem
integrity andfishery
productivity.

Coastal(domestic andInternational)
shipping –commercial
shipping andports

Physical injury ofcable byshipping.
Disruption toshipping duringcable laying.

As per the contract specifications:➢ Confine trenching activities to as narrow a
corridor as possible and restore site whenfinished.
➢ Confine trenching/laying activities to as short a
period as possible;➢ Request Kosrae authorities (DFMR & KIRMA)
to advise local fishers of cable laying activities,
dates, and avoidance measures.
➢ Consider placing warning markers (noanchoring) along cable line in shallow (<10 m)
waters within Lelu harbor.
➢ Consider placing warning signs on the mainlandadjacent to the cable alignment to inform
community of cable presence.
▪ Ensure a shipping notice is issued warning of cablelaying, dates, and safe clearance for other activities.
▪ Request state and national Port Authorities &Marine Authorities (NORMA) to advise shipping oflaying activities and avoidance measures.
▪ Ensure that marine navigation lights and othernational maritime measures are closely followed by
the project vessels at all times.

Interview fishers –stakeholders to determine
contractor’s compliance.
Installation of warning
signs adjacent land areas.

Offshoreandcoastalareas.

East Micronesian Cable Project – ESMP Kosrae Component Addendum Update – June 2020

Ensure shipping notice ispublished.

71

Environmental
Parameters
Coastal Accessand usage.

Project
ImpactTemporary lossof access tofishing grounds
for local
communities
during laying ofsubmarine
cable.
Straying ofagreed cablealignment into
communal
resource area.
Community
perception ofcable
encroachment to‘no-go’ marine
protected areas.

Mitigation Measures

Location

Monitoring Action▪ Confine laying activities to as short a period as
possible.
Provision of electronic (social media) and print notices
to local communities/fishers of construction scheduleand contact person in case of inquiries (GRM).

Duringcable
laying.

Ensure project
construction notifications
are published and confirm
compliance to CEMP
mitigation measures(including GRM).

Conduct a series of stakeholder consultations withgovernment, private sector, NGO and community on
progress and cable alignment.

At anylocationwhere thiserror
occurs.

Provision of electronic and print notices to local
communities of construction schedule and contact
person in case of inquiries.

Duringcable
laying.

Timing/Duration

Implementation

Supervision

When work
is undertaken.

FSM TCC (OAE)

CIU safeguard
team & FSM
TCC (OAE).

Undertake stakeholder
meetings to confirm
compliance to ESMP
mitigation measures.

When work
is undertaken.

FSM TCC (OAE)& CIU safeguard
team.

CIU safeguard
team & FSM
TCC (OAE).

Confirm construction planis compliant to bid
documents – specificallyoutlining schedule andtiming of work to inform
community.

When work
is undertaken.

FSM TCC (OAE)& CIU Safeguard
team.

CIU safeguard
team & FSM
TCC (OAE).

When work
is undertaken.

Contractor (s)CIU safeguard
team & FSM
TCC (OAE).

2.3.2 Terrestrial
AccessTemporary lossof access toproperty for local
communities
during laying ofcable.

GeneralConstruction
Activities – Risk
to workers onroad etc.

Risk of hazards
to or accidents
to workers
duringconstruction &spread ofcommunicablediseases.

▪ Contractor will provide to all workers: (i) healthfacilities, first aid kits, appropriate safety equipment
and procedures for medical treatment; (ii) adequate
training and information to workers in relation to all
health and safety issues, equipment and training
including STI and HIV/AIDS awareness andprevention program and (iv) access to safe drinking
water, mosquito management, sun/shade

Duringcable
laying.

East Micronesian Cable Project – ESMP Kosrae Component Addendum Update – June 2020

Periodic site inspections toensure compliance to
CEMP mitigation
measures.
Confirm construction planis compliant to bid
documents – specificallyoutlining management ofrisks to workers.
Periodic site inspections toensure compliance to72

Environmental
Parameters

Project
ImpactMitigation Measures

▪

▪

▪

▪

▪

▪
▪

▪
▪
▪

Locationmanagement, portable, septic latrines and garbage
receptacles at all work sites and office compoundas required.
The contractor will prepare a health and safety plan
(HSP) as part of their CEMP. The HSP is to include
key components of the World Bank Environmental,
Health and Safety Guidelines (EHSG).
The contractor will ensure they take full responsible
for the implementation of the CEMP and to liaise
with the residences/businesses in the subproject
area, as required.
The contractor will provide adequate health carefacilities including first aid facilities at the officecompound and mobile first aid kits in vehicles andat work sites.
The contractor will provide construction workers
training on health and safety matters, specifichazards of their work, basic sanitation, hygiene andhealth care issues and awareness and preventionof communicable diseases (including STIs and
HIV/AIDS).
The contractor will be responsible for providing
safety equipment and appropriate personal
protective equipment (PPE) to workers, including
instructions on how and when to use theequipment.
The contractor will ensure safe and clean facilities
include sanitation and drinking water (at least 2
liters/day) is provided to all workers.
Septic tanks and garbage receptacles will be set up
at work sites and office compound as required.
These facilities to be regularly cleaned by thecontractors to prevent outbreak of diseases.
Garbage will be dumped only at a site approved by
Kosrae State (KIRMA).
“No smoking zone” signage will be posted
throughout work sites and the office compound (e.g.
fuel storage areas).
The contractor will ensure that there is adequate
water manage at all sites to ensure that disease
vectors such as stagnant water bodies do not form.
Contractor to educate and ensure worker’s actions

East Micronesian Cable Project – ESMP Kosrae Component Addendum Update – June 2020

Monitoring Action

Timing/Duration

Implementation

Supervision

CEMP mitigation
measures.

73

Environmental
Parameters

Generalconstruction
activities Presence ofworkers in thecommunity.

Inadequate
information

Project
ImpactRisk of hazards
to or accidents
to members ofcommunity &spread ofcommunicablediseases.

Failure toincludeMitigation Measures
are controlled codes of conduct are strictly
observed (work sites and office compound) andKosrae state specific requirement (restrictions on
activities on Sunday).
▪ Before construction commences the contractor willconduct training for all workers on theirrequirements to engage the local community andensure national & State laws are respected, special
consideration and respect for women, elderly andchildren (including the school) are to be strictly
followed. Code of conduct protocols will be
discussed and worker awareness as part ofmobilization process including STI and HIV/AIDS
education.
▪ Child and/or trafficked labor will be strictly
prohibited for any activities associated with the
project and children will be prohibited from entering
the worker’s accommodation, works
area/construction zone and prohibited from playing
on any equipment or machinery associated with the
project.
▪ The contractor will implement relevant elements of
the GRM.
▪ Adequate signage and security will be provided atwork sites for prevention of unauthorized people(including children) entering any work site(s) or theoffice compound. Consideration of signs in English
and Kosraean.
▪ The public will be adequately protected near worksites, including advanced notice of commencementof works, installation of safety barriers and fences(no go areas) and signage or marking areas where
works will be carried out.
▪ Provision of safe access across the works site(s) topeople whose residential or business access is
temporarily affected during road rehabilitation
activities.
▪ The contractor will implement the Traffic
Management Plan that will include traffic control
and pedestrian safety measures.
Prior to start of work present draft cable alignment plan
to stakeholders, seek input and obtain agreed finalize

Location

Duringcable
laying.

Monitoring Action

Confirm construction planis compliant to bid
documents – specificallyoutlining management ofrisks of workers on
communities.

Timing/Duration

Implementation

Supervision

When work
is undertaken.

Contractor (s)CIU safeguard
team & FSM
TCC (OAE).

When work
is underFSM TCC (OAE)& CIU Safeguard

FSM TCC(OAE) &

Periodic site inspections toensure compliance to
CEMP mitigation
measures.

Key
project

East Micronesian Cable Project – ESMP Kosrae Component Addendum Update – June 2020

Confirm construction planis compliant to bid

74Environmental
Parameters

Project
Impactdisclosure

stakeholders &communities infinal alignment
planning &decisiondevelopment.
Contractor fails
to prepare asummary report
defining the
mitigation &monitoring
actions
completed &what needs tobe continued
during the
Operatingperiod.
Contractor withlittleunderstanding of
ESMP initiates
work & causes
significant
damage,impacts andcomplaints.
Injury or death tocontractors
duringcontracted
works.

Environmental
Mitigation
Measure/s
Completion
ReportContractor
Awareness
Raising

Contractors(workers) Healthand Safe

Timing/Duration

Implementation

Supervision

documents – specificallyoutlining schedule andtiming of work to inform
community.

taken.

team.

CIU safeguard
team.

N/A

Confirm completion report
is completed and iscompliant to bid
documents.

Complete
within thelast 4months oftheconstruction
period.

Contractor (s)FSM TCC(OAE) &
CIU safeguard
team.

Conduct a contractors CEMP implementation
workshop (briefing) reviewing mitigative, monitoring
and reporting project requirements.

Key
project
location.

Confirm completion of
implementation workshop
and it’s delivery wascompliant to bid
documents.

½ - 1 day.

FSM TCC (OAE)& CIU Safeguard
team inconjunction with
Contractor (s)FSM TCC(OAE) &
CIU safeguard
team.

Contractors to prepare (CEMP) and implement Healthand Safety Plan (HSP).

All

Confirm contractors HSP(detailed in CEMP) is
compliant to bid
documents.

Submission
prior toworks being
undertaken.

Contractor (s)FSM TCC(OAE) &
CIU safeguard
team.

Offshore
deep
water
environment.

As part of periodic
maintenance checks ofcable.

As part ofperiodicmaintenancechecks.

FSM TCC (OAE)
and/or cable
service provider.

FSM TCC(OAE).

Mitigation Measures

Location

Monitoring Actionplan.

location.

Contractor to prepare a completion report and deliverto the project Owners Engineer.

3.0 OPERATING PERIOD
3.1 Physical and Ecological Environment
Oceanic habitat– Hydrothermal
vents.

Physical impact
on cable fromhydrothermal
vents.

New vents can appear in proximity to the cable and rerouting of cable may be required to maintain safe
clearance.

East Micronesian Cable Project – ESMP Kosrae Component Addendum Update – June 202075

Environmental
Parameters

Project
ImpactPerceived
marine pollution.

Local
communities
fear of potential
damage tomarine life andother resources.

Monitoring Action

Timing/Duration

Mitigation Measures

Location

Implementation

Supervision

Establishment of a Grievance Redress Committee(GRC) to address community concerns-issues.

Kosrae

Review and record
operation of GRC andprepare inspection reports.

As concerns
arise

FSM TCC (OAE)
and/or cable
service provider.

FSM TCC(OAE).

When inuse.

Examine and record steps
taken to inform public.

At all times

FSM TCC (OAE)
and/or cable
service provider.

FSM TCC(OAE).

After cable
is in place.

FSM TCC (OAE)
and/or cable
service provider.

FSM TCC(OAE).

3.2 Socio-Economic Environment
Impactassociated withimproved
Internet—better
access toharmful sites

Marine coastal
resource users

Failure to adopt
measures andcontinue
mitigation
actions definedin theConstruction
PeriodEnvironmental
Completion
report.
Impacts on
fishing activities
and possible
fishing gear
snagging on
cable.

Make communities aware of ‘internet site blocking”
features available to every subscriber.

Measure effectiveness of
consultation.

Clearly advertise location of undersea cable and alert
local fishers and dangers of gear snagging (which will
actually be minor, as it will be buried 3 feet below theseafloor) in shallow water coastal areas (Lelu harbor).

InshoreCoastalareas.

East Micronesian Cable Project – ESMP Kosrae Component Addendum Update – June 2020

Confirm through meetings
with fishers and generalcommunity that steps
necessary to prevent
impacts have been taken.

76