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U.S. Position on AfDB’s Investment in the Regional Bagamoyo - Horo Horo / Lunga Lunga -

Malindi Road Project, Phase 1 in Tanzania and Kenya

December 12, 2019

The United States supports the project’s primary objective of improving transport infrastructure and

regional connectivity within an important multinational coastal corridor that includes two major

urban centers: Dar es Salaam and Mombasa. The United States further supports the objective of

creating new economic opportunities and facilitating market access for farmers and fisherfolk. The

United States also appreciates AfDB’s engagement on the USAID-led visit to portions of the project

site in August 2019 and looks forward to ongoing dialogue on the project during the design review

and implementation.

Any project that expands access to relatively inaccessible regions may result in significant adverse

environmental and social impacts. Given that the proposed alignment for this road project passes

through or near numerous environmentally protected areas, it is critical to proactively identify,

avoid, reduce and mitigate any adverse impacts to natural resources, including wildlife, to the

greatest extent feasible, before the project design is finalized. In our view, the proposed alignment

in Tanzania was chosen without comprehensive biodiversity baseline information to define the

natural and critical habitat and inform actions to avoid and mitigate adverse impacts.

The United States appreciates that the project has allocated funds for a consultant to conduct an

additional environmental and social baseline survey, including performing fieldwork to collect

quantitative biodiversity data. The United States stresses that, for this survey to be worthwhile, its

findings and any recommendations must be taken into account during the design review. The

United States strongly supports AfDB management’s commitment to do so. Nonetheless, the

United States notes that the baseline survey and any necessary adjustments to the project design

should have been completed prior to Board consideration.

The United States has five recommendations:

1) Given the importance of ensuring that adverse impacts to biodiversity and natural/critical habitat

will be avoided or proactively mitigated (and monitored), it is essential that AfDB staff update the

project design per the additional baseline survey described above. Specifically, staff should

carefully review the proposed alignment in light of the survey’s findings, and any recommendations

stemming from the survey, with an aim to avoid adverse impacts to sensitive sites and species

wherever possible. Where adverse impacts are unavoidable, staff should review the proposed

mitigation measures to ensure that they are proportionate to the likely impacts on both species and

habitat that are identified in the survey. If residual impacts are likely to remain even after mitigated

measures have been implemented, and an offset is needed to achieve no net loss of natural habitat

and/or net gain of critical habitat, staff should work with international experts to design and fund an

offset for the life of the project.

2) Staff should monitor and report to the Board any incidences of project-related gender impacts

and steps taken to prevent, mitigate and manage such impacts during implementation.

3) Staff should formalize partnerships with local and national NGOs in both countries to manage

the project’s resettlement and livelihood support programs.
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4) Staff should closely supervise TANROADS and KeNHA to ensure that the project’s mitigation

measures are fully implemented throughout the life of the project and that project-affected

communities are not coerced. 

5) Staff should provide detailed information about AfDB’s accountability mechanism and the

project-level grievance redress mechanism (GRM) to project-affected communities. Information

should be regularly and widely disseminated in the appropriate local language(s). Staff should also

monitor and publicly report whether the project-level GRM is functioning well, staffed sufficiently,

and easily accessed by project-affected communities.

With these comments, the United States supports the project and look forward to seeing how the

experiences from this first phase will benefit Phase 2.