IEE: Samoa: Community Sanitation Project - Asian ...

Initial Environmental Examination

November 2011

SAM: Community Sanitation Project

Prepared by Planning and Urban Management Agency (PUMA) for the Asian Development

Bank.

CURRENCY EQUIVALENTS (as of 1 November 2011)

US$1.00 = SAT 2.30 SAT 1.00 = US$0.43

ABBREVIATIONS

ACEO – Assistant Chief Executive Officer ADB – Asian Development Bank asl – above sea level EIA – environmental impact assessment EMP – environmental management plan GDP – gross domestic product HDPE – high density polyethylene IA – Implementing agency IEE – initial environmental examination IFC – International Finance Corporation JICA – Japan International Cooperation Agency JFPR – Japan Fund for Poverty Reduction MNRE – Ministry of Natural Resources and Environment MOF – Ministry of Finance MOH – Ministry of Health MOU – Memorandum of Understanding MWCSD – Ministry of Women, Community and Social Development MWTI – Ministry of Works, Transport and Infrastructure NGO – non-government organization PUMA – Planning and Urban Management Agency SSDP – Samoa Sanitation and Drainage Project STC – Sanitation Technical Subsector Committee SWA – Samoa Water Authority

WEIGHTS AND MEASURES

oC – degree Celsius ha – hectare km – kilometer m – meter m2 – square meter m3 – cubic meter mm – millimeter

NOTE

In this report, "US$" refers to US dollars, whereas SAT refers to Samoan tala.

This initial environmental examination is a document of the borrower. The views expressed herein do not necessarily represent those of ADB'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, the Asian Development Bank does not intend to make any judgments as to the legal or other status of any territory or area.

CONTENTS

EXECUTIVE SUMMARY 1

I. INTRODUCTION 1

II. PROJECT DESCRIPTION 2

A. Sanitation Improvement 2 B. Facility Design 5 C. Project Implementation 5

III. POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK 7

A. Regulations and Approvals 7 B. ADB Standards and Project Due Diligence 7

IV. PROJECT ALTERNATIVES 8

A. “Do Nothing” Option 8 B. Centralized or Decentralized Sanitation Systems 8 C. System Design 9 D. Household Selection 11

V. BASELINE ENVIRONMENT 11

A. Physical Environment 11 B. Biological Environment 12 C. Socioeconomic and Cultural Environment 12

VI. ENVIRONMENTAL IMPACTS AND MITIGATION MEASURES 14

A. Land Use Change 14 B. Construction Disturbance 15 C. Disruption to Toilet Facilities 16 D. Construction Waste 16 E. Environmental Improvement 16 F. Health Improvement 17 G. Economic Impact 18 H. Sludge Disposal 18 I. Occupational Health and Safety 18 J. Other Issues 19

VII. ENVIRONMENTAL MANAGEMENT PLAN 19

A. Management Responsibilities 19 B. Project Mitigation Measures 20 C. Environmental Monitoring 24 D. Institutional Arrangements, Environmental Reporting and Record Keeping 24

VIII. INFORMATION DISCLOSURE, CONSULTATION AND PARTICIPATION 25

IX. GRIEVANCE REDRESS MECHANISM 26

A. Grievances During Construction 26 B. Grievances During Operation 26

X. FINDINGS, RECOMMENDATIONS AND CONCLUSION 27

XI. REFERENCES 28

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EXECUTIVE SUMMARY 1. The Project, classified as ADB environment category B, will provide a model for subsidized household sanitation improvement for Samoa by directly improving the sanitation systems of 470 households and increasing awareness about the correct design and maintenance of septic systems among 15,000 households. The construction of household systems is a low impact activity on previously disturbed land, with the main adverse impacts being short term ground disturbance and a safety hazard during construction. Operation of the improved systems will create no adverse impacts over the current situation, providing functional sanitation systems for participating households and thereby reducing the current health hazard posed by poorly functioning existing septic systems in the participating villages. The main mitigation measures will be close consultation with each household regarding system siting and construction activities, minimizing ground disturbance and waste removal. Project sustainability regarding sludge build-up will be ensured by the subsidization of the initial de-sludging of each installed septic tank, providing an operational life of between 6-10 years per tank before each household meets the full cost of de-sludging. The institutional capacity and commitment of PUMA to manage the Project‟s environmental and social impacts are deemed adequate. Effective measures to avoid, minimize and mitigate adverse impacts are incorporated in the safeguard reports and plans.

I. INTRODUCTION

2. The Samoa: Community Sanitation Project (the Project) will be executed by the Ministry of Finance and implemented by the Planning and Urban Management Agency (PUMA) within the Ministry of Natural Resources and Environment (MNRE) from 2012 to 2015, using grant funding from the Japan Fund for Poverty Reduction (JFPR). 3. The overall goal of the Project is to provide vulnerable households with sustainable access to improved sanitation in targeted regions of Samoa, thereby improving public and environmental health. The Project will establish and pilot an innovative delivery method and the required institutional arrangements to provide subsidized sanitation infrastructure to vulnerable households. In doing so the Project will provide the foundation for the government to expand the sanitation scheme nationally to assist households to replace and maintain their onsite sanitation infrastructure. 4. The vast majority of Samoan households currently rely on non-functioning, leaking septic tanks for sanitation services. This poor onsite sanitation infrastructure1 pollutes groundwater and streams, damages marine ecosystems, and adversely impacts residents‟ health. Samoa has the highest reported incidence of typhoid of all Pacific developing member countries, periodically reaching epidemic levels. Typhoid is especially prevalent among poor households in low-lying settlements in urban Apia, and high incidences of diarrheal diseases have also been reported. The Project should improve the treatment of household sewage and thereby reduce the incidence of related diseases and pollution of the environment. 5. This Initial Environmental Examination (IEE) has been prepared to meet the due diligence requirements of the ADB. ADB‟s Safeguard Policy Statement (2009) requires that any project to be supported by the Bank must comply with its environmental assessment requirements, including following international good practice. International good practice for

1 Onsite sanitation refers to septic tanks, various types of latrines, and other similar sanitation technology.

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sanitation projects includes the standards contained in the International Finance Corporation (IFC) Environmental, Health and Safety Guidelines for Water and Sanitation (2007). 6. This IEE focuses on the main potentially adverse environmental issues associated with the Project, from pre-construction, through construction to operation. This IEE was been prepared based on: site visits; consultation with some potential participating households, village mayors and key government authorities; and a review of project preparatory studies and secondary sources of information relating to the Project. It identifies and assesses the Project‟s main adverse environmental impacts, and describes feasible mitigation measures for avoiding, minimizing or offsetting unavoidable adverse effects.

II. PROJECT DESCRIPTION A. Sanitation Improvement 7. The Project involves subsidized household sanitation improvement in 13 coastal villages located in three regions on Upolu island, Samoa: Apia, northeast and northwest (Figure 1). The Project has been classified by the ADB as environmental category „B‟ as the main potential adverse environmental impact is considered to be of low to moderate significance only. Figure 1: Location of Project Target Regions

8. Village sanitation is generally poor because household sanitation systems are poorly designed and rarely maintained. Nearly all households have their own toilet, with a few households sharing toilets. The most common household sanitation system in operation in the target villages appears to be flush or pour toilets connected to unsealed septic tanks (commonly having no base), allowing infiltration directly into the soil profile. Water sealed latrines are the next most common sanitation system in use. Some septic tanks are connected to soak pits or absorption trenches, but this appears to be the minority. Other septic tanks drain directly into adjacent stormwater drains, streams or the sea via a PVC pipe. Many septic tanks have a

Region 1: North West

Region 3: North East

Region 2: Apia

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sealed concrete cover at ground level, therefore the periodic pump-out of sludge is not possible. Some septic tanks in Apia are periodically de-sludged, but very few outside this urban area appear to be pumped out. 9. Site conditions within the target villages vary regarding factors relating to sanitation. These different conditions include:

Settlement density – some village areas in Apia are densely settled, while other areas in the city are relatively sparse urban settlement; settlement in the two rural regions ranges from dense to relatively sparse;

Elevation – ranging from reclaimed land immediately above the high tide line that may be susceptible to coastal erosion, to areas over 6 m above sea level;

Slope – mostly flat coastal land, but some moderately sloping areas;

Drainage – ranging from flood-prone land with a high water table (less than 1 m below the surface) to well drained areas set back from drains, streams and the coastline;

Water supply – villages are either connected to mains water supply (supplied by the Samoa water Authority (SWA)) or connected to a local village supply scheme, with some local schemes prone to running dry late in the dry season)

Land ownership – mainly shared customary land, but some areas have freehold title (owned by and/or leased to target households);

Household size – estimated to average seven people per household;

Financial means – most residents are poor, although some are identifiably better off. 10. Accordingly, the Project will vary sanitation system design for site conditions, with the siting of the septic tank and absorption trench on each property critical to optimize the system‟s performance. The Project has three components:

(i) Pilot sanitation scheme; (ii) Public awareness; and (iii) Financial and technical sustainability.

Component A: Pilot Sanitation Scheme 11. The Project aims to provide 470 households in 13 villages across three regions with subsidized sanitation systems primarily in the form of septic tanks and overflow absorption trenches, including the connection to existing flush toilets. Septic systems function on anaerobic bacteria in the septic tank decomposing or mineralizing waste discharged into the tank. Overflow effluent is then dispersed to the ground via a perforated PVC pipe laid in a gravel-filled absorption trench that promotes infiltration into the soil profile where it is naturally filtered. Periodic preventive maintenance is undertaken to remove the irreducible solids that settle and gradually fill the tank, reducing its efficiency and potentially blocking the absorption trench. 12. All households in the target villages will be given the opportunity to apply for a subsidized sanitation system. If household demand for subsidized facilities is lower than targeted then additional villages will be added to the Project. The three Project regions are on the north coast: (i) north west corridor; (ii) urban Apia; and (iii) north east corridor. The majority of target houses in the north west and north west corridors are located within 200 m of the shoreline on lower slope land/the small coastal plain, whereas target areas in Apia extend up to 1,000 m inland from Apia Bay. Household numbers in the target villages are estimated in Table 1.

http://en.wikipedia.org/wiki/Preventive_maintenance

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Table 1: Estimated Population of Project Villages

Region Village Approximate Number of Households

Region 1: North West Corridor Toamua 92

Puipaa 90

Levi 114

Total 296

Region 2: Urban Apia Leone 73

Vaisigano 40

Maluafou 10

Aai o Niue 23

Tufuiopa 37

Tauese 24

Total 207

Region 3: North East Corridor Eva 82

Salelesi 49

Fusi 63

Falefa 63

Total 257

13. Households will be selected based on income level and the current state of their sanitation infrastructure, with the principle focus being on poorer and lower income households. Subsidies for septic tank and absorption trench installation will be provided in two bands: 75% and 100% subsidy. For those households receiving a 75% subsidy, the 25% cost contribution levied on the household can be met by an in-kind and/or cash contribution. 14. By improving the sanitation systems of the most deserving 60-65% of households‟ (i.e. households with limited means to improve their poorly functioning sanitation systems) in the target villages, the Project should result in a notable improvement in the health of village residents and the receiving environment. Component B: Public Awareness 15. A public awareness program targeting approximately 15,000 households in the three regions will be undertaken to raise household awareness of septic tank construction and maintenance requirements, and the consequences of insufficient maintenance. The campaign will: advertise the pilot scheme in the target villages to encourage take-up; inform participating households about pilot scheme procedures and how septic tanks are constructed, operated, and maintained; inform the general public about the adverse effects on human health and waterways from leaking septic tanks, the consequences of not regularly emptying septic tanks, and the connection to hygiene practices; inform participating households about maintenance monitoring and enforcement procedures to encourage them to carry out regular maintenance of their sanitation infrastructure and avoid penalties; and inform participating households about potential financing sources to help cover their cash contributions. This program will utilize methods that have proved successful on previous awareness campaigns. Component C: Financial and Technical Sustainability

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16. Participating households will receive financial support to undertake initial maintenance of their new sanitation system, thereby becoming familiar with routine maintenance requirements and developing the skills to maintain the system themselves. Households in the 100% subsidy band will receive a voucher to cover 75% of the cost of the first maintenance cycle (approximately US$100). Households in the 75% subsidy band will receive a voucher for 50% of the cost of the first maintenance cycle. 17. Sanitation officials will receive training in construction supervision, septic tank inspections, asset management, and water quality testing to enable them to manage the scheme after the Project has ended. PUMA and MWTI will carry out 1,000 random inspections of septic tanks per year between 2013-15 in participating villages to monitor sanitation assets and enforce relevant acts and regulations, with fines imposed for breaches, thereby incentivizing households to replace or upgrade their onsite sanitation system themselves, and to maintain these systems over time. B. Facility Design 18. The new household sanitation systems will be designed in accordance with the National Building Code 1992 and the draft revisions to the Code (as contained in Appendix E of the National Sanitation Masterplan 2011) that are currently being considered. The main change to the Code proposed in the revisions that relates to the Project is an increase in septic tank volume to 3.64 m3 for a household of 0-5 people and 7.20 m3 for 6-15 people. As per the Code the following minimum setbacks from septic tanks will be achieved wherever possible:

15 m from a well or any water source if an absorption trench is used for final effluent treatment;

1.5 m from any building;

3 m from any window;

1.5 m from the land boundary; and

3 m from trees. 19. The minimum adsorption trench setbacks from features are: 1.5 m from the septic tank; 5 m from a building; and 15 m from a well or any water source. In addition, other siting criteria that will be taken into account will include a setback to any graves located in the house yard, locating the septic tank away and absorption tank away from accessways (parking area, foot pathway, etc), and locating the sanitation system away from land prone to coastal erosion. Other design criteria in the National Building Code will be incorporated into sanitation system design. 20. Absorption trenches will be around 650 mm deep and 900 mm wide, except where local conditions dictate that a shallower trench is required. Where there is a high water table or shallow rock then the trench may be as shallow as 400 mm and wide to provide the required gravel bed / soil surface area. 21. Septic tanks will either be constructed from concrete blocks, high density polyethylene (HDPE) or pre-cast concrete. Concrete block construction is likely to be the most common type given that materials are readily available and installation does not require a crane. Connection to the existing household toilet will be made using PVC or uPVC pipe. C. Project Implementation

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1. Implementation Schedule 22. Project implementation is due to commence in January 2012, running for four years until December 2015. Component A – Pilot Sanitation Scheme (34 months) will commence in 2012 Q1. The installation of sanitation systems is scheduled to commence in urban Apia, then progress to the northwest and northeast regions. Component B – Public Awareness (9 months) will commence in 2012 Q2. Component C – Financial and Technical Sustainability (40 months) will commence in 2012 Q1 and run until the end of 2015.

2. Pre-Construction Activities 23. Pre-construction activities for Component A: Pilot Sanitation Scheme Consultation will commence with consultation with the village mayors (“pulenuu”) to discuss Project implementation, outlining the aim, method, target areas, levels of subsidy and responsibilities of participating households. The Project will then be introduced to households through the public awareness program. The household survey will then be conducted of all households in the target villages that are interested in participating. Recipient households will be selected and the subsidized systems will be offered to these households. Those wishing to participate shall sign a memorandum of understanding (MOU) with PUMA. 24. Consultation will occur with each recipient household about the design, location and maintenance requirements for the systems. Household systems will be designed based on household size and location. Development approval for each system will then be obtained from PUMA, followed by building approval from MWTI. PUMA shall procure individual household septic tanks in three batches through national competitive bidding (NCB).

3. Construction Activities 25. Septic tank construction will involve: removing any surface features such as vegetation; excavating a pit (with an excavator or by hand); pouring a concrete base slab for a block tank; constructing the block tank including a slab top; painting a sealer on the inside of the tank; backfilling and compacting around the tank; connecting the toilet inflow and trench outflow pipes; then completing the backfilling around the crest of the tank. Where an existing tank it is decommissioned by breaking up the concrete lid, a hole will be created in the base of the tank (where there is a base) and it will be backfilling and compacted using soil excavated for the new tank. 26. Absorption trench construction will involve: excavating the trench (around 650 mm deep); filling the base of the trench with gravel or broken rock; laying a perforated 100 mm PVC pipe in the centre of the trench; overfilling the pipe with gravel or broken rock (generally to a total depth of around 450 mm); laying a separation layer of black polyurethane or similar; and compacting backfill over the top (around 200 mm depth) with a slight mound left above surrounding ground level to allow for settlement. Excess spoil is placed on site as directed by the landowner if he/she wants to use it or it is removed from site along with any other waste materials and disposed of in an appropriate manner (e.g. at the Tafaigata Landfill).

4. Operational Maintenance and Repair Activities 27. The septic tank and absorption trench sanitation system is low maintenance, but de-sludging of the tank is required every 3-5 years to remove accumulated sludge before it affects system performance, and the occasional repair may be necessary. The tank is usually de-

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sludged when it begins to smell or there is a back-up in the toilet. De-sludging will be undertaken using a vacuum tanker truck to avoid handling the material and to transport it to dewatering ponds. The initial de-sludging of each subsidized tank will be subsidized by the Project under a voucher system, then each household will be responsible for the cost of all subsequent pump-outs. The removed sludge will be released into clay lined dewatering ponds at Tafaigata Landfill, 8 km west of Apia, where it will be treated. 28. On occasions absorption trenches may have to be repaired when they are damaged by traffic or impeded by tree roots or septage overflow, but this will be the responsibility of the householder.

III. POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK 29. The Project is subject to Government of Samoa design standards, approvals and permits, as well as ADB environmental and social standards and due diligence assessment. A. Regulations and Approvals 30. Design standards. Facility design and construction has to follow the National Building Code 1992, while the Project will also follow the proposed revisions to the Code contained in the National Sanitation Master Plan 2011 (Appendix E). 31. Development consent. Under the PUMA Act 2004, PUMA (within the Ministry of Natural Resources and Environment) has operational responsibility for development planning and the regulation of development projects to ensure that environmental, social and related impacts are kept to acceptable levels, including amenity values. All new infrastructure developments, including household sanitation systems, are assessed by PUMA via the Development Approval process, where the proposed development is considered in terms of land use planning. PUMA determines if an environmental impact assessment (EIA) is required based on the significance of the likely environment impacts. An application for Development Consent is all that is required for a household sanitation system. Issues that PUMA considers for such systems are septic tank and absorption trench design and setbacks (to the house, watersources, property boundary, drains, watercourses, the shoreline, house, etc). If the development is approved, PUMA issues Development Consent to the developer. 32. Building permit. Once a proponent has obtained Development Consent they are required to obtain construction authorization in the form of a Building Permit from MWTI (Building Asset Management Division) as provided for in the Ministry of Works Act 1992. MWTI has responsibility for approving the quality of building construction, including sanitation facilities. MWTI staff inspect the development during construction and again following the completion of construction. 33. Health standard. Under the Health Ordinance 1959 and Board of Health Regulations No. 6 and No. 8, administered by Health Promotion and Preventative Services within the Ministry of Health, buildings are required to have adequate provision for wastewater management. The Ministry of Health (MOH) currently monitors receiving water quality on an ad hoc basis. B. ADB Standards and Project Due Diligence

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34. ADB‟s safeguard due diligence requirements include an environmental assessment to assess the impacts of the Project and propose mitigation measures2. The assessment normally takes the form of either a detailed Environmental Impact Assessment (EIA) or a simpler Initial Environmental Examination (IEE), partly determined by the completion of a Rapid Environmental Assessment (REA) Checklist. The Checklist is used to determine the most significant potential adverse impact of the Project, thereby providing an indication of the level environmental assessment required. 35. The Project is categorized by the ADB as environment category „B‟ as the proposed facilities will not be located on significant or sensitive ecological, heritage or social sites, and the main adverse impact of the project is not deemed to be significant. As such, an IEE is required to assess the likely Project impacts and propose management measures. This IEE has been prepared by PUMA in accordance with ADB‟s environmental and social safeguard policies and information disclosure for environmental Category B projects, including ADB‟s Safeguard Policy Statement (2009). It forms part of the Project feasibility assessment. 36. Consultation was undertaken during IEE preparation with government authorities, community representatives and potential Project-participating households, as summarized in Appendix A.

IV. PROJECT ALTERNATIVES 37. The main Project alternatives are:

“do nothing” option;

centralized or on-site household sanitation systems;

system design; and

household selection. A. “Do Nothing” Option 38. Under the “do nothing” option, existing unsanitary living conditions caused by poor sewage treatment in 13 coastal villages would continue at an accelerated rate as the population grows, becoming more extensive and severe. This would significantly exacerbate the existing levels of water-borne disease which are already high by Pacific standards and considered unacceptable. B. Centralized or Decentralized Sanitation Systems 39. The Samoa Water Authority (SWA) has the long-term goal of connecting the urban areas of Apia to a centralized sewerage system to treat and dispose of domestic wastewater, but this is cost prohibitive at present due to the relatively dispersed location of urban dwellings and the absence of sewerage trunk lines apart from the pipelines that service some industrial areas. The only existing centralized sewage treatment plant is at Sogi, on the northwestern side of Apia. This plant was commissioned by SWA in 2010 and treats wastewater from commercial properties in downtown Apia.

2 ADB, 2009. Safeguard Policy Statement.

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40. Similarly, running sewer lines from northeastern and northwestern corridor villages to central systems is not cost effective as the Project target villages are located around 18-25 km from Apia and no trunk sewerage lines exist along the coast. In addition, the concept of „user pays‟ for centralized services is not common in Samoa, with no charges currently payable by users for connection to and use of the central sewerage collection and treatment system in Apia (Government of Samoa, 2011). 41. Individual household systems are cost effective given the dispersed location of villages along the coastal corridor (neighbouring villages are commonly separated by agricultural land). They ensure that responsibility for system performance rests with the house, the sole beneficiary. Additionally, if a single household‟s system fails then this does not compromise the performance of other household systems. C. System Design 42. The design of a household sanitation system needs to achieve a balance between capital cost, effluent quality and maintenance needs. Five decentralized sanitation system design options were considered during Project planning, as summarized in Table 2. Table 2: On-Site Sanitation System Design Alternatives

System

Advantages Disadvantages

1. Septic tank with disposal trench

Simple construction

Low costs

Community awareness

Government experience

Ease of converting to STEP3 system

Problematic in low lying, flood-prone & high groundwater table areas.

Likely contamination of waterways during floods in low lying areas.

Requires de-sludging every 3-5 years.

2. Mechanical aerobic system

High quality effluent.

Reduced adverse impact on public health.

Minimizes contamination of waterways.

High capital & operating costs.

Regular & high level maintenance required

Little experience of such systems in Samoa.

Problematic in low lying & flood-prone areas.

3. Biogas toilet system

Human waste contained & degraded, reducing risks to public health.

Comprehensive system treating human, animal & agricultural wastes.

Biogas produced as an energy source, especially for cooking.

Savings on alternative fuels.

Digested slurry can be used as fertilizer.

Lack of institutional infrastructure to approve design & supervise construction.

Experienced technicians required for construction & maintenance.

Extensive capacity building exercise required before biogas program rolled out.

New community awareness campaigns & training required.

Unsuitable for flood-prone & low lying areas.

Risks of gas (methane) leaks.

Digested slurry has to be disposed of safely if not used as fertilizer.

Biogas benefit doubtful if only run on human waste.

Breakdowns expensive to repair.

4. Dry pit latrine No additional treatment systems Increased risks to waterways in low lying

3 A STEP (Septic Tank Effluent Pumping) system consists of a household septic tank and a pump, which pumps the effluent from

the septic to the sewer network and a centralised treatment plant.

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required.

Cheap construction cost.

Reduction in household water usage.

No external contamination of waterways/soils.

Dry matter can be used as compost.

areas & areas with a high groundwater table.

Perception & aesthetic issues with cleaning out pits.

Not supported by regulations/building code.

5. Ventilated pit latrine

Better ventilation & control of flies/mosquitoes than dry pits.

No additional treatment systems required.

Cheap construction cost.

Reduction in household water usage.

No external contamination of waterways/soils.

Dry matter can be used as compost

Increased risk to waterways in low lying areas & areas with a high groundwater table.

Perception & aesthetic issues with cleaning out pits.

Source: adapted from Harrison Grier/Strategy and Economics Ltd, 2011.

43. The principal design selected for Project-subsidized sanitation systems is a septic tank connected to an effluent absorption trench. The main advantages of this technology over alternative systems are that it combines simple construction with low capital cost and moderate maintenance cost. It is recognized that the performance of septic tanks and disposal trenches is reduced on sites subject to flooding, with a high water table or highly sandy soils, while mechanical aerobic systems perform much better in these locations, but the much higher capital cost of mechanical aerobic systems would mean that the Project would not trial affordable systems, while most households would be unable to afford the operating cost. 44. A septic tank is unsuitable for households that do not have a sufficient water supply, therefore sanitation system improvement for such households currently with no toilet facilities or a dry pit latrine will consist of a ventilated improved pit (VIP) latrine. 45. The design of septic tanks and absorption trenches must comply with Samoan standards for good engineering practice as set out in the National Building Code 1992, while the Project will also meet the proposed 2011 revisions to the Code, as well as PUMA planning requirements. The design must also be cost effective, sustainable and acceptable to households, therefore design options are limited. Despite this, some alternative designs are required for different locations. 46. The selected household locations are likely to include difficult sites such as: immediately next to drains, streams and the high tide line; shallow water table (within 1.2 m of the ground surface); sandy soils that freely drain to nearby drains, streams and the sea; and shallow underlying rock. Design variations that will be considered for specific site conditions include:

High water table sites and/or sandy soils close to drains, watercourses, high tide line – shallow absorption trenches (e.g. 400 mm deep).

Flood-prone areas – slightly higher septic tanks (e.g. 300-500 mm of tank above ground) with soil mounded around the sides.

47. The location of the household septic system is restricted by local norms such as: keeping the toilet relatively close to, and at the rear of, the house; siting it away from graves, etc. But placing the tank and absorption trench on the best area available on the house block will improve system performance, particularly close to the high tide line and adjacent to streams and drainage lines where the distance to each of these features needs to be maximized.

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48. Upgrading existing household sanitation systems is an alternative to installing new systems. In virtually all instances it is not advisable to upgrade septic tanks as most are not sealed (many have no base) and have insufficient capacity based on the revised Code. Improving these tanks would require temporarily taking them out of service, pumping them out, concreting in a base, most likely installing an internal baffle and sealing the internal surfaces. This process would most likely cost more than a new tank, not perform as required an present a health hazard during the works, therefore it is not proposed. 49. Most septic tanks are likely to be constructed from a concrete base slab with concrete block walls, and a concrete slab cover cast on site, then sealed with a sealant on the inside. Alternative designs that may also be used are: (i) high density polyethylene (HDPE) tanks; and (ii) pre-cast concrete tanks. The limitation of using a pre-cast concrete tank, especially for the larger capacity (i.e. 7.2 m3 capacity for a household of 6-15 people) is that a large crane is required for installation and therefore it is unsuitable where access is poor. D. Household Selection 50. The Project is targeting vulnerable, low lying coastal households that have significant sanitation issues. Many of these households are located in areas that are difficult to service with sanitation systems as they are: flood-prone; close to drains, streams and the shoreline; have a high water table; have sandy soils that freely drain to nearby waterbodies; and are densely settled. Seeking to improve the sanitation systems of these households brings with it operational difficulties, but the Project is based on improving the existing systems of those in most need, accepting that the improved systems will be subject to less than optimum performance at certain times due to the prevailing conditions. 51. The alternative to this is to leave the sanitation systems of households with difficult site conditions unimproved, instead improving the systems of households located on less constrained sites where year-round sanitation improvement is guaranteed. This would result in the poorest performing sanitation systems continuing to pollute at their current rate (and probably at a greater rate as village population increases), continuing to pose a health hazard to the whole village. It would also neglect many of the most vulnerable households that do not have the means to improve their sanitation systems.

V. BASELINE ENVIRONMENT 52. Project activities will cover three coastal regions of Samoa – urban Apia, the northeast and northwest. This section provides an overview of the environmental and socioeconomic conditions in the country, with particular reference to conditions that relate to Project activities. A. Physical Environment

1. Topography and Soils 53. Samoa has a total land mass of 2,934 km2 and is composed of two large volcanic islands (95% of the land mass), Upolu and Savaii, and eight smaller islands that include

Apolima and Manono. The country forms the western part of the 500 km long Samoan

archipelago. The landscape is dominated by volcanic mountains down the middle of Upolu and Savaii, with the landform generally rising from narrow and flat coastal plains onto undulating

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slopes then central mountains. Soils are almost exclusively volcanic, highly stoney and shallow, having a large influence on agro-ecological zones.

2. Climate 54. Samoa has a tropical equatorial climate, with little seasonal difference in temperatures. There are two distinct seasons, a relatively dry season between June and September and a rainy/wet season between October and May, with the majority of rainfall falling between December and March. Average annual rainfall varies greatly from the coast to the inland mountains, from 2,500 mm along the north-western coastline up to 7,500 mm in the mountains. Apia receives 2,960 mm annually. Cyclones occur between January and March, and Samoa is vulnerable to long dry spells that coincide with the El Nino Southern Oscillation phenomenon. 55. The average maximum temperature in Apia is uniform across the year, ranging from 29.5°C in July to 30.7°C in April, while the average minimum temperature varies between 22.6°C in July and 24.2°C in February.

3. Land Use and Water Resources 56. Samoa has limited land resources, and large areas are undeveloped due to customary ownership restrictions and access difficulties. Land use in Samoa in 1999 consisted of: forest 60.2%; agricultural land (plantations and mixed crops) 22.3%; scrubland 7.8%; settlement 2.3%; barren land 0.7%; infrastructure 0.2%; and other (grasslands, lakes, rivers, wetlands, etc) 6.5% (SamFRIS, 2004 - based on 1999 mapping). Primary agricultural products include the root crop taro and the plantation crops of coconuts, cocoa and bananas. Agricultural lands (plantations and mixed cropping) cover an estimated 34,500 ha on Upolu and 28,600 ha on Savaii. 57. Water sources consist of groundwater (mainly from coastal springs), harvested rainwater in drier areas and surface water abstracted from catchments. The Samoa Water Authority (SWA) supplies 68% of the population with water, with the remaining 32% obtaining water from independent village schemes or household sources. The main rivers on Upolu are the Fuluasou, Vaisigano, Namo, Mulivai, Salani, Tafitoala, Nuusuatia, Leafe or Lotofaga and Faleseela. B. Biological Environment

1. Biodiversity and Protected Areas 58. Samoa does not have highly diverse biodiversity due to its relatively young geological age, but its isolation contributes to a very high species endemism of over 30%. Five vegetation types occur in Samoa: littoral, wetland, rainforest, volcanic scrub and distributed vegetation. There are nearly 500 species of native flowering plants, with 25% endemic to Samoa, with around 500 species of plants having been introduced. There are 13 mammal species, 56 bird species, and 17 reptile species. Samoa has 10 declared protected areas, two of which are marine protected areas. Community-based fish reserves have been established in 72 villages. The total forest area is around 37%, consisting of natural forest and plantations. C. Socioeconomic and Cultural Environment

1. Population and Settlement

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59. Samoa has a population of 174,000 in 2001 (Population and Housing Census, 2001), which was estimated to have increased to 188,000 in 2010. The country has experienced rapid population growth over the last century, with current annual growth rate around 1%. Four of the 10 islands of Samoa are settled, with the population mainly living along the coastal fringe. The indigenous population of Samoa lives in over 330 villages that are mainly located along the coast, although recently there has been an expansion of inland settlement around roads. The broader Apia urban area contains around 35% of the national population.

2. Administration 60. Samoa has a hereditary chief of state, and is governed by the Fono (parliament). Only traditional chiefs (matai) are able to stand for election to parliament. Universal suffrage was not introduced until 1990, when women got the vote for the first time, but the restriction still remains that only matai can present as candidates. Village meetings have increasingly exercised authority under the 1990 Village Fono Act. Samoan society is based on the aiga (extended family) system. Each “aiga” is headed by a “mata” who is responsible for its welfare, especially in relation to customary family land. Samoan villages are well structured, with the village fono (village council of matai) controlling all village affairs, keeping order and providing direction for village development.

3. Economy 61. Much of Samoa‟s economy is based on primary production, with over two-thirds of the working population employed directly or indirectly in the agricultural sector. Crops, livestock, fisheries and forestry account for around 40% of gross domestic product (GDP), with much of this economic activity at subsistence level. Coconut, cocoa and banana are important cash crops and fishing provides cash income and the major source of protein. Two-thirds of agricultural exports are derived from coconuts. The manufacturing sector is centred on the processing agricultural products. 62. The average annual salary per employed person in Samoa is SAT 12,963 4, while average annual household income is SAT 27,345 5. The 2010 Poverty Report 6 indicates that the average incidence of basic needs poverty is 20.1% of households nationally.

4. Land Tenure 63. Land tenure in Samoa consists of customary land 81%, Government land 15%, and freehold land 4%. Customary land is vested in Samoans in accordance with Samoan custom and usage. It is primarily managed by the matai who is the head of an extended family. The matai is the trustee for his/her family, responsible for the management and allocation of land for various uses by family members. 64. Customary land cannot be transferred or made freehold, although lease arrangements can be made. The Taking of Lands Act 1964 allows the Government to take or exchange any type of land for public purposes. A growing trend in customary land tenure is the increased individualization of land, particularly inland agricultural areas that individuals or families have

4 2.33 SAT = 1 USD.

5 2008 Household Income and Expenditure Survey.

6 Basic Needs Poverty Lines and Incidence and Characteristics of Hardship and Poverty Report, August 2010.

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claimed. In nearly all rural villages, it is accepted practice that an area of land can be used by any person or family which first develops it from virgin forest.

5. Indigenous Peoples 65. Samoans are Polynesian, with some elite Samoans having part Chinese or European ancestry. Samoa has retained strong elements of fa'a Samoa (the Samoan traditional culture) in its constitution and political structure, and society is hierarchical. Minority groups include Niueans and Tokelauans, and a small number of Chinese, but apart from these groups there are no other distinct ethnic groups in the country. Migration from the nearby atolls of Tokelau occurred in the first half of the twentieth century, but numbers of migrants declined after the 1960s due to a lack of employment opportunities and ease of migration to New Zealand.

6. Public Health 66. Poor sanitation is a major public health issue in Samoa, brought about by poor water management, water treatment and wastewater treatment which has caused the contamination of drinking supplies. Some diseases, in particular typhoid, gastroenteritis and diarrhoea, are frequently diagnosed due to the consumption of polluted drinking water, however it is estimated that many more people suffer from the effects of waterborne diseases than the incidence recorded in the statistics. The source of outbreaks of waterborne diseases is difficult to trace due to lack of resources.

VI. ENVIRONMENTAL IMPACTS AND MITIGATION MEASURES 67. Project activities will improve sanitation in the participating villages, thereby improving public health by reducing seepage of partially treated sewage, and improving environmental health by reducing the contamination of receiving waters and land. The main potential environmental and socioeconomic impacts of the Project are: Construction

land use change;

village disturbance (noise, dust, safety);

disruption to toilet facilities;

disposal of waste and spoil. Operation

environmental improvement – surface water and groundwater, land;

public health improvement;

sludge disposal;

occupational health - from de-sludging pump-out and transportation. A. Land Use Change 68. Septic tanks are usually located within 3-6 m of a house, almost exclusively on cleared land that is part of the existing house compound. Accordingly, no natural habitat or sensitive site will be affected, with the only change in land use being a small area of yard becoming a tank and absorption trench. No or minimal vegetation removal is required, although the occasional tree may have to be removed to place the pit and trench in the optimum location, but this will

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only occur with the prior agreement of the householder. Many houses have a grave next to the dwelling but the system will be set back from this site. 69. The only above-ground features of the system will be the connection pipe between the toilet and the septic tank, and the top of the septic tank sitting about 150 mm above ground level for most tanks and possibly higher in flood-prone areas. The net change in land use will be close to nil as the existing septic tank will be decommissioned by removing the lid, making a hole for drainage in the base and filling it with soil excavated for the new tank, thus this site will be returned to earth yard. 70. All Project works will be located on either traditional land or private freehold land. The written agreement of the traditional or freehold owner will be gained prior to commencing Project works. Mitigation Measures

On-site discussions shall occur with the householder to reach agreement on the optimum siting of the sanitation system based on operational performance and householder preferences.

Vegetation removal and ground disturbance shall be restricted to the minimal area required for construction by clearly marking out the site prior to commencement.

Ground disturbance shall be avoided within 5 m of drains, stream banks and the shoreline.

The existing septic tank shall be decommissioned by removing the top and filling with soil excavated from the new tank site.

Topsoil (where available) shall be placed over backfill, returning the land level above the absorption trench to compound surface level plus a small mound of material (50-70 mm higher) to allow for settlement over time.

B. Construction Disturbance 71. A minor disturbance to households will occur during the installation of the septic tank and absorption trench, generally limited to a two day construction period per household for pre-fabricated tanks and up to 7-10 days for concrete block tanks. Disturbance will be in the form of: noise from a small excavator (when used) and motorized cement mixer, and vehicles delivering and removing materials from site; minor dust generation in dry times, creating a nuisance; and a safety hazard around the dwelling due to earthmoving and tank construction activities, including open pits. Construction activities within each village are expected to occur over 2-3 months. 72. Ground disturbance for septic tank and absorption trench installation will be around 20 m2 or less per site, insignificant in terms of creating an erosion hazard on these relatively flat areas. The ground surface around the septic tank will be reinstated using the topsoil stripped from the site (if available). Mitigation Measures

Each household and the village pulenuu shall be informed about the construction program and hazardous activities prior to commencing construction, and shall be requested to keep household members (especially children) away from working machinery and the excavated holes.

Temporary safety fencing shall be erected around earthmoving activities and the excavated holes until the sites are backfilled.

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Construction activities shall be restricted to daylight hours.

Excavation shall occur immediately prior to septic tank and absorption trench installation, leaving the voids open for the minimal period of time required (i.e. trench open for less than 24 hours, and septic tank hole open for up to 10 days).

C. Disruption to Toilet Facilities 73. Household toilets will be temporarily out of service when the toilet is disconnected from the old disposal system and reconnected to the new septic tank. This should be limited to no more than one day in most instances, during which time the household will be asked to make alternative arrangements such as using a neighbour‟s toilet. Mitigation Measures

The replaced septic tank shall be decommissioning only after: (i) the new tank and trench has been installed; and (ii) the existing connection from the toilet to the old tank has been disconnected.

D. Construction Waste 74. Waste produced during construction will include concrete, plastic and excess spoil from excavation. Volumes will be relatively small except for spoil which will be around 6-10 m3 per site, depending upon the size of the system. Where an existing septic tank is decommissioned then 1-2 m2 of spoil will be used as fill. Mitigation Measures

Excess excavation spoil shall be offered to the householder for his/her use in the house yard (e.g. for foundations, land leveling), and stockpiled in a convenient location if required. If the householder does not want the spoil it will be offered to the village for its use.

All waste shall be segregated, reused or recycled where possible to minimise the volume of waste generated.

All remaining waste shall be removed from the site following construction, and disposed of at an approved facility such as the Tafaigata Landfill, while excess spoil disposal shall avoid land degradation.

E. Environmental Improvement 75. The Project will improve receiving environment conditions, particularly during the dry season. Water quality in open village stormwater drains, nearby streams and along the coastal foreshore should improve in the dry season as currently leaking septage from the worst performing systems will be adequately treated through anaerobic action in the septic tank and ground infiltration. Partly treated and untreated septage from these households should not reach receiving waterbodies, thereby removing this source of pathogens, decreasing nutrient enrichment and in turn improving the health of animals and marine life. Other village amenity values should also improve, including a decrease in odors. 76. In villages on flood-prone land the improvement in environmental conditions during the wet season may be small as the new septic systems will be subject to inundation and the release of partly treated sewage. It is worth noting that septic tanks with sealed lids that are flooded should only release a limited amount of septage due to the small diameter inflow and

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outflow pipes. The secondary treatment of effluent by infiltration from the absorption trench in areas with a high water table or flooded is likely to be less than optimum due to inadequate soil infiltration, resulting in partly treated septage seeping onto the ground surface or reaching nearby waterbodies. 77. A broader improvement to the local environment should also result from the Project public awareness program that will be delivered to approximately 15,000 households in the three target regions. It is hoped that households replacing their sanitation systems will construct better systems and that more regular de-sludging of septic tanks will occur. Mitigation Measures

The septic tank and absorption trench shall be sited on each house block to optimize performance (e.g. installing the absorption trench on the highest site to provide the greatest clearance between the base of the trench and the top of the water table) whilst taking account of household considerations.

On flood-prone sites, raised septic tanks (e.g. 300-500 mm of tank above ground level) shall be considered to reduce the potential for flooding.

On sites with a shallow water table or overlying rock, shallow absorption trenches (e.g. 400 mm depth) shall be considered.

F. Health Improvement 78. The primary social impact of better household sanitation systems will be an improvement in village health, with the main project beneficiaries being the poor, vulnerable and lower income households. The Project, by improving the worst 60-65% of household sanitation systems in each target village, should substantially reduce partly treated and untreated septage leakage within the village, into adjacent stormwater drains and streams, and/or into the sea. This will result in an improvement in the water quality of local receiving waterbodies (freshwater and sea water) by reducing the inflow of nutrients and pathogenic bacteria, viruses and parasites. This will in turn reduce human contact with contaminated waterbodies, reducing the incidence of skin contact and ingestion when swimming, thus reducing gastro-intestinal illnesses. 79. Village sanitation improvement is also likely to reduce the contamination of some aquatic organisms that are consumed. For example, mussels and oysters accumulate pathogenic bacteria in their tissues (Prieur et al, 1990), eventually making the shellfish unsafe for human consumption. In addition, a reduction in soil contamination may reduce the contamination of food grown in the village. 80. Village areas that are not subject to flooding, have a low water table and do not receive overland runoff or seepage from upslope villages are likely to receive the greatest improvement in village sanitary conditions and health. The flooding of settlement areas may cause the partial failure of septic tanks or absorption trenches in the wet season due to flooding of the tank or trench, or saturation of the soil profile beneath the trench. This will result in the seepage of partly treated or untreated septage to the surface or into waterbodies, although the direct flow of untreated sewage is unlikely. If this residual seasonal health hazard occurs it should be lower than the current wet season health hazard in the target villages as most raw and partly treated effluent will be retained in the septic tank. 81. A broader health improvement should result from the Project public awareness program that will be delivered to 15,000 households, as described previously.

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Mitigation Measures

The optimum site on each household plot for septic tank and absorption trench performance shall be selected as described above.



G. Economic Impact

82. An improvement in village health from reduced illness or mortality due to ingestion or skin contact with contaminated water reduces health care costs and indirect opportunity costs (World Bank, 2003), although these costs cannot be accurately estimated. The effect on local livelihoods will be positive by improving health, resulting in less loss of labour due to illness and a reduction in household expenditure on medical treatment. House gardens and fruit trees will generally be left undisturbed except at a minority of sites where an alternative site for the sanitation system is unavailable. H. Sludge Disposal 83. Sludge will be pumped out of septic tanks using mobile vacuum tankers (usually 3 m3 capacity or greater) and disposed of into MNRE‟s clay lined dewatering ponds at Tafaigata (opened in January 2011), 8 km west of Apia. Once a pond is full after between 12-24 months use the sludge is left to dewater in the pond before the semi-dry sludge is deposited onto nearby drying bays for six months. Once fully dry the material is used as agricultural compost. 84. The sludge dewatering ponds have been designed with a clay lining to prevent the infiltration of sludge effluent into the soil profile and water table. The drying beds have a runoff collection system where all runoff is collected in a pond and thereby prevented from leaving the site. Mitigation Measures

De-sludging shall be undertaken using a vacuum tanker.

All sludge shall be disposed of in the Tafaigata dewatering ponds and treated according to standard MNRE practice.

I. Occupational Health and Safety 85. Occupational health and safety hazards will occur during construction activities due to earthmoving, opening and decommissioning old septic tanks and general construction activities. Septic tank de-sludging will create a health hazard for contractor staff dealing with this contaminated material. The use of proper personal protective equipment (PPE), adequate training and site supervision will reduce risks to an acceptable level. Mitigation Measures

Contractors shall issue their staff with adequate and suitable PPE and require them to use it when: (i) constructing sanitation systems; and (ii) pumping out, transporting and unloading sludge.

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Replaced septic tanks shall be filled with soil immediately after the lid/cover is removed and a hole is created in the base of the tank, ensuring that any exposure of septage occurs for a minimal period.

De-sludging contractors shall be required to empty sludge from tankers into MNRE‟s Tafaigata dewatering ponds.

J. Other Issues 86. No land acquisition is required for Project implementation as all sanitation system improvements will occur on customary land with the agreement of the traditional landholder or on private land with the agreement of the landowner. Likewise, no resettlement is required because the improved sanitation systems will be installed at least 1.5 m away from any existing dwelling within the house yard. 87. Under the ADB definition of indigenous persons (i.e., a group or cultural identity distinct from that of the dominant or mainstream society) there are no indigenous persons in the Project areas therefore the Project will have no effect on indigenous peoples. 88. The project will target women to participate in the scheme through awareness-raising activities and will provide opportunities for women to participate in project implementation and monitoring. Women‟s committee members and youth representatives will help to spread public awareness of the scheme, encourage households to apply to the scheme, monitor project implementation at the village level, and monitor septic tank maintenance and increased awareness.

VII. ENVIRONMENTAL MANAGEMENT PLAN A. Management Responsibilities 89. PUMA, as the implementing agency (IA), will undertake Project implementation (Figure 2 and Table 3), recruiting the following consultants to assist with this:

sanitation scheme coordinator, sanitation engineer, sanitation scheme administrator – to assist with procurement, construction supervision, project management, and capacity development and public awareness activities;

four consultants to design and deliver capacity development training and public awareness campaigns;

project evaluation consultant; and

external auditor. 90. The IA will ensure that mitigation measures are written into contract bidding documents, that contractor bid evaluation includes consideration of the ability to implement EMP measures, and that the supervising engineer evaluates EMP performance based on mitigation measure implementation and performance. 91. The Sanitation Technical Subsector Committee (STC)7 , chaired by PUMA, will oversee the Project and advise PUMA on project implementation, consultant recruitment, procurement,

7 Members of the STC include MOF, PUMA, MOH, SWA, MWTI, MWCSD, and Ministry of Natural Resources and

Environment (MNRE). The STC reports to the Joint Water Sector Steering Committee established by cabinet.

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and household applications. MWTI will supervise septic tank construction, and MOH will monitor receiving water quality. All three organizations will receive assistance to undertake these functions from the Project, including training. The government will evaluate the implementation of the pilot and the potential to expand the scheme nationally. Figure 2: Project Implementation Organizational Chart B. Project Mitigation Measures 92. The avoidance and mitigation of potentially adverse environmental impacts will be overseen by PUMA and undertaken by the Project team during design/pre-construction, the construction contractor/s during construction, and the maintenance (de-sludging) contractor/s during operation, as summarized in Table 4. The supervision, evaluation, and reporting of activities implemented as per the EMP will be carried out strictly and punctually to provide feedback to the Project management team.

Executing Agency Ministry of Finance

Implementing Agency Planning and Urban

Management Agency

Sanitation Technical Subsector Committee

MOF, PUMA, MNRE, MOH, SWA, MWTI, and MWCSD

Project Coordination Team Sanitation Scheme Coordinator

Sanitation Engineer Sanitation Scheme Administrator

Participating Households Approximately 470 in urban Apia, Northeast region, and

Northwest region

Civil Works Contractors One each for Urban Apia,

Northeast region, and Northwest region

Consultants Public Awareness,

Capacity Development, and Evaluation

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Table 3: Environmental Management Responsibilities

Agency Role

PUMA Implementing Agency responsible for environmental compliance with government and ADB requirements:

construction supervision, project management, and capacity development and public awareness activities;

design and delivery of capacity development training and public awareness campaigns;

project evaluation and auditing.

PUMA Implementing Agency responsible for environmental compliance with government and ADB requirements:

construction supervision, project management, and capacity development and public awareness activities;

design and delivery of capacity development training and public awareness campaigns;

project evaluation and auditing.

STC Advising PUMA on project implementation, consultant recruitment, procurement, and household applications.

MWTI EMP implementation guidance to contractors during construction, including:

reviewing the environmental mitigation and monitoring plan requirements set out in the EMP;

submitting environmental monitoring reports to ADB every six months during the Project.

Construction Contractor/s

Implementing construction phase environmental mitigation measures:

implementing all site environmental mitigation requirements identified in their contracts;

reporting regularly to MWTI on all site environmental measures and impacts.

ADB Monitoring EMP progress:

reviewing and clearing environmental monitoring reports submitted by the IA

posting reports on ADB‟s website.

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Table 4: Project Environmental Management Measures

Project Activity Potential Environmental / Social Impact

Impact Mitigation Measure Responsibility1

PRE-CONSTRUCTION

Consultation Landowner and community disagreement

Initial consultation shall be undertaken with the village pulenuu to introduce the project and seek his agreement for village participation.

Convening an open community forum to introduce and discuss the Project (purpose, design, participation, levels of subsidy, operation, benefits, etc).

Project coordination team

Site selection and system design

Loss of amenity and land use On-site discussions shall occur with the householder to reach agreement on the optimum siting of the sanitation system based on operational performance and householder preferences.

Adherence to all septic tank setbacks specified by PUMA wherever sufficient area exists on the house block. Where a sanitation system is to be improved and a PUMA-specified setback cannot be established due to a lack of space the greatest possible setback will be provided. Minimum setbacks to be achieved wherever possible.

Preference shall be given to sites free of trees (or requiring limited tree clearance), and sites with access for an excavator and vacuum truck.


Approvals and permits Development consent Application to PUMA for development consent for the sanitation system. Project coordination team

Building approval Application to MWTI for building approval to construct the sanitation system. Project coordination team

CONSTRUCTION

Land use change Loss of productive land and vegetation, land destabilization

Vegetation removal and ground disturbance shall be restricted to the minimal area required for construction by clearly marking out the site prior to commencement.

Ground disturbance shall be avoided within 5 m of drains, stream banks and the shoreline.

The existing septic tank shall be decommissioned by removing the top and filling with soil excavated from the new tank site.

Topsoil (where available) shall be placed over backfill, returning the land level above the absorption trench to compound surface level plus a small mound of material (50-70 mm higher) to allow for settlement over time.

Construction contractor

Construction disturbance Safety, disruption and nuisances

Each household and the village pulenuu shall be informed about the construction program and hazardous activities prior to commencing construction, and shall be requested to keep household members (especially children) away from working machinery and the excavated holes.

Temporary safety fencing shall be erected around earthmoving activities and the excavated holes until the sites are backfilled.

Construction activities shall be restricted to daylight hours.

Excavation shall occur immediately prior to septic tank and absorption trench installation, leaving the voids open for the minimal period of time required (i.e. trench open for less than 24 hours, and septic tank hole open for up to 10 days).


Disconnection of existing sanitation system

Disruption of toilet facilities The replaced septic tank shall be decommissioning only after: (i) the new tank and trench has been installed; and (ii) the existing connection from the toilet to the old tank has been disconnected.


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Project Activity Potential Environmental / Social Impact

Impact Mitigation Measure Responsibility1

Environmental improvement The septic tank and absorption trench shall be sited on each house block to optimize performance (e.g. installing the absorption trench on the highest site to provide the greatest clearance between the base of the trench and the top of the water table) whilst taking account of household considerations.




Health improvement On flood-prone sites, raised septic tanks (e.g. 300-500 mm of tank above ground level) shall be considered to reduce the potential for flooding.



Construction waste Excess excavation spoil shall be offered to the householder for his/her use in the house yard (e.g. for foundations, land leveling), and stockpiled in a convenient location if required. If the householder does not want the spoil it will be offered to the village for its use.

All waste shall be segregated, reused or recycled where possible to minimise the volume of waste generated.

All remaining waste shall be removed from the site following construction, and disposed of an approved facility, while excess spoil disposal shall avoid degrading land.


Occupational health and safety

Worker health and safety Contractors shall issue their staff with adequate and suitable PPE and require them to use it when constructing sanitation systems.

Replaced septic tanks shall be filled with soil immediately after the lid/cover is removed and a hole is created in the base of the tank, ensuring that the exposure of septage occurs for a minimal period.


OPERATION AND MAINTENANCE

Occupational health and safety

Worker health and safety Only experienced contractors with vacuum tankers shall be permitted to de-sludge tanks using vacuum tanks.

Contractors shall issue their staff with adequate and suitable PPE and require them to use it when pumping out, transporting and unloading sludge.

All sludge shall be disposed of in the Tafaigata dewatering ponds and treated according to standard MNRE practice.

De-sludging contractor

C. Environmental Monitoring 93. Environmental monitoring will occur during Project design, construction and operation to provide baseline data, confirm Project compliance and detect any adverse impacts/non-compliances. The focus of environmental monitoring is to ensure that construction and operational activities strictly comply with management plan provisions and avoid or minimise environmental impacts.

94. Regular internal environmental monitoring of construction works, associated activities and the implementation of environmental management measures will be undertaken during Project design and construction as summarized in Table 5. Table 5: Summary of Project Environmental Monitoring

Environmental Monitoring Task Parameters Monitored Responsibility Frequency

PRE-CONSTRUCTION

Proposed site Existing condition of proposed site

PUMA Once prior to construction

Audit of landowners‟ MOUs, development consents and building approvals

Agreements, consents and approvals

PUMA Once prior to construction

CONSTRUCTION

Construction contractor compliance with environmental management requirements

Work site pegged prior to earthworks

MWTI Once prior to construction.

Erection of safety fencing MWTI Once during construction

Site condition immediately following construction

MWTI Once immediately following construction

OPERATION AND MAINTENANCE

Performance of installed household sanitation system

Leaks, seepage, odor, etc PUMA Once every 12 months after connection, for the first two years

Receiving water quality E. coli levels MOH Twice yearly – mid wet season and mid dry season

Submission of Monitoring Report to the ADB

General environmental compliance of Project facilities, complaints and landowner disputes

PUMA Every 6 months

D. Institutional Arrangements, Environmental Reporting and Record Keeping 95. Increased awareness resulting from the awareness raising program will be monitored through existing Ministry of Women, Community and Social Development (MWCSD) monthly household surveys. PUMA and MWTI will carry out random inspections of septic tanks in participating villages to monitor sanitation assets and enforce relevant acts and regulations. All households in the pilot regions will be eligible for the random inspections. PUMA will aim to carry out 1,000 inspections per year from 2013–2015. The imposition of fines8 for failed inspections will incentivize households to replace or upgrade their onsite sanitation system

8 Under the Planning and Urban Management Act (2004, amended in 2005), fines may be imposed for carrying out

development without consent or other breaches of the act. Under the Water Resources Management Act (2008), fines may be imposed for discharging pollutants into the water resource of Samoa or other contraventions of the act. The Ministry of Health Act (2006) allows for the imposition of fines for breaches of public health standards relating to any aspect of water quality. The 2006 Wastewater and Sewerage Regulations may impose fines for discharging hazardous substances into public sewers or waterways. The 1992 National Building Code lays out septic tank construction standards to which households must adhere.

themselves (if they can afford to), and to maintain properly-constructed septic tanks overtime through minor repairs and regular emptying and disposal. MOH shall monitor the quality of receiving waters with Project assistance. 96. PUMA will maintain an environmental monitoring record system that records: (i) significant environmental matters, including monitoring data, environmental incidents, occupational accidents and other emergencies; and (ii) public complaints, concerns and accidents involving the public. This information will be part of the asset database management training and records maintained by PUMA. It will be reviewed and evaluated to improve the effectiveness of the environmental, health, and safety program. A semi-annual summary of Project environmental performance will be prepared and provided to the ADB. An example format for this report is provided in Appendix B.

VIII. INFORMATION DISCLOSURE, CONSULTATION AND PARTICIPATION

97. Design phase. Information disclosure and consultation undertaken during Project preparation involved both formal and informal consultation with government agencies, village pulenuus and potential participating households in the target villages, to introduce and develop the Project concept. Three formal meetings were organized with the STC to discuss technological and financing options, consultations, and existing infrastructure services. All members of the STC were consulted on an individual basis to discuss each agency‟s current functions and the role they expect to play in the pilot scheme. Information from these meetings was incorporated into the final design of the institutional framework. 98. A project presentation was made to about 80 pulenuus from various villages around the country. A meeting with village chiefs from Togafuafua, Tuloto, and Tangamanono and a meeting with the Secretary of the Laulii village council were held. The specifics of the pilot scheme were explained to community stakeholders, who were very supportive and expressed the need for such a scheme in their villages to improve family health and the environment. They were very supportive of the in-kind contribution provision and recommended consultation with households during implementation. 99. Representatives of the Japan International Cooperation Agency (JICA) in Samoa and the Embassy of Japan in New Zealand were consulted on the concept paper and JFPR grant proposal. JICA and the Embassy support the proposed project, stressing the importance of septic tank maintenance and sustaining the sanitation scheme financially after the end of the project. An advisor to the Ministry of Finance attended the consultation meetings with the STC, providing input regarding suitable technology and sanitation scheme scope. An advisor to SWA was consulted regarding the design and implementation of the ADB-funded Samoa Sanitation and Drainage Project that supplied and installed 101 septic tanks in Apia. 100. Informal discussions were held with Government agency staff and residents in some of the target villages during the preparation of the IEE (Appendix A). The issues raised by agency staff are summarized in Appendix A1, while the main issues raised by residents were: the hope to be included in the scheme; current sanitation problems of their household systems; and poor domestic water supply in some villages. 101. Implementation phase. Information disclosure and consultation during Project implementation will commence with a meeting with each village pulenuu to discuss Project implementation. This will be followed by the commencement of the public awareness campaign,

where information about the project, eligibility criteria, subsidy levels and section criteria will be disseminated to the target villages. Households interested in participating in the Project will be asked to complete an application and will be surveyed. Each completed application will be signed by the local village chief, village mayor, and/or the government liaison officer, as a verification check. PUMA will select households to receive subsidized sanitation systems on the basis of the household survey, and notify each applicant household of the outcome of its application. Once MOU‟s are signed with participating households community leaders/women‟s committee representatives will inform the households of the installation timetable. 102. PUMA will conduct on-going consultation during construction with participating villages and households to ensure people are fully informed, and again during Project operation to resolve issues such as under-performing sanitation systems.

IX. GRIEVANCE REDRESS MECHANISM 103. Grievances about Project performance may be raised by participating households, neighbouring households in the target villages or nearby, or by the general public. A. Grievances During Construction 104. During construction, a MWCSD staff member will be assigned the role of community liaison for each of the three regions. The name and contact details of these individuals will be presented on a noticeboard at work sites and at PUMA, with instructions on how to make a complaint. For minor complaints, such as noise or dust nuisance, or disregard of safety procedures, corrective action will be instructed by the supervising consultant, and a response provided to the complainant within 48 hours. If no action is deemed appropriate, the complainant will be of his/her rights to take the complaint to the Magistrate‟s Court. 105. For complaints over major construction issues, such as injury, damage to property, or occupation of land without due agreement, the Assistant Chief Executive Officer (ACEO) PUMA or a designated representative will respond within 24 hours and arrange a meeting with appropriate personnel including a representative of PUMA to agree resolution. If a solution, agreeable to all parties, is not reached within a period of seven days, the complainant may file the grievance with the Magistrate‟s Court. The Magistrate‟s ruling will be binding on all parties. 106. MPWU shall maintain a register of complaints in which the dates, names of complainants, action taken and personnel involved will be recorded. B. Grievances During Operation 107. PUMA has a formal grievance redress mechanism to investigate and resolve public complaints about environmental amenity relating to pollution, including complaints about poorly functioning wastewater discharge systems (e.g. setbacks, odour, seepage), that it will apply to resolve complaints about Project amenity issues arising from sanitation system operation. It undertakes to resolve each issue as soon as practical. This process consists of:

Receipt of complaint – a complainant making a verbal complaint is asked to fill out an Official Public Complaint Letter pro-forma addressed to the PUMA ACEO, detailing the complainant‟s name and address, the party responsible for the loss of amenity and the amenity issue.

PUMA public complaints register – a complaint lodged with the Agency is registered in the public complaints register. Each new case is given a code for record and file management.

PUMA file - a file is created for each complaint that includes a Public Complaint Processing Sheet used to track progress that summarizes complaint details, site visit date, reporting, correspondence, monitoring and status. The complaint is entered into a Complaints Register.

PUMA site inspection – a site investigation is conducted to confirm the issue and discuss it with the party responsible. Site investigation observations and findings are recorded on the Public Complaint Site Visit Sheet, including details about site conditions and evidence of amenity issue. The Public Complaint Monitoring Compliance Inspection Sheet is also filled in by the PUMA inspector at the time of the site inspection to record recommended mitigation actions.

The case officer prepares the inspection report with recommendations for relevant mitigation actions. This report is reviewed by the Principal Urban Management Officer before it is endorsed by the ACEO. Subsequently a letter of advice is issued to the culprit with recommendations.

Follow-up inspection – a follow-up inspection is undertaken to verify compliance with the recommended actions.

Acknowledgement letter – MNRE sends an acknowledgement letter to the responsible party after it has correctly implemented the required mitigation measures, confirming this and thanking it for doing so.

Follow-up correspondence with the complainant – an update letter is issued to the complainant about the progress of the case and actions taken by the Agency.

X. FINDINGS, RECOMMENDATIONS AND CONCLUSION 108. On-site household sanitation systems, primarily consisting of a toilet connected to a septic tank with overflow to a disposal / absorption trench, is appropriate technology to improve household sanitation in the participating villages. This facility is cost effective, simple, relatively low maintenance and requires a small land area. 109. The Project aims to establish an effective model for subsidized sanitation improvement that can be rolled out to a far greater number of households in the future under new projects. It will do this by directly improving the sanitation systems of 470 households and increasing awareness about the correct design and maintenance of septic systems among 15,000 households. 110. The construction of improved household sanitation systems, consisting of a septic tank and absorption tank for most households or a VIP latrine for a few households, is a low impact activity on previously disturbed land. Construction involves the disturbance of a small area of household yard (less than 20 m2), excavation of 6-10 m3 of soil and on-site works for a short duration. 111. Operation of the improved sanitation systems will create no adverse impacts over the current situation. Project operation will provide functional sanitation systems for participating households, greatly reducing the current health hazard produced by existing septic systems in the participating villages. This benefit may be affected during excessively wet conditions or where a high water table exists, potentially resulting in surface seepage and water resources

contamination. At these sites alternative facility designs will be considered to optimize system functioning, including raised septic tanks (e.g. 300-500 mm of tank above ground level) on flood-prone areas and shallow absorption trenches (e.g. 400 mm depth) where there is a high water table or overlying rock. But regardless of these shortcomings of the system, its installation will improve existing conditions by directing at least part of the effluent load into subsoil for at least partial filtration, which is far preferable to the “do nothing” option that would see conditions deteriorate further as the village population increases and other factors such as climate change exert an influence over system performance. 112. The sustainability of the improved household sanitation systems regarding sludge build-up will be ensured by Project subsidization of the initial de-sludging of each installed septic tank, generally providing an operation life of between 6-10 years per tank before each household has to meet the full cost of de-sludging. 113. Additional Project benefits will include training for PUMA and MWTI staff, and assistance to MOH for water quality monitoring.

XI. REFERENCES ADB, 2009. Safeguard Policy Statement. Asian Development Bank. Manila. Government of Samoa, 2011. Samoa National Infrastructure Strategic Plan. Pacific Regional Infrastructure Facility. Water for Life – Water Sector Plan and Framework for Action, 2008/9-2011/12. Coordinated by the Samoa Water Authority. Harrison Grier/Strategy and Economics Ltd, 2011. RSC-C12929(SAM) – Development of Community Sanitation Project in Samoa: Final Report 22 June 2011. IFC, 2007. Environmental, Health and Safety Guidelines for Water and Sanitation. International Finance Corporation, World Bank Group. Washington DC. Ministry for Natural Resources and Environment, 2006. State of the Environment Report 2006. Government of Samoa. Apia, Samoa. Ministry of Natural Resources and Environment, 2009. Policy Paper for Cabinet Development Committee – Consultative Draft, July 2009 (Version 3.0). Prieur, D., Mevel, G., Nicolus, J.L., Plusquellec, A. and Vigneulle, M., 1990. Interactions Between Bivalve Molluscs and Bacteria in the Marine Environment. Oceanography and Marine Biology Annual Review 28, 277 - 352. Samoa Forestry Division, 2004. Samoa Forest Resource Information System (SamFRIS) Database. Technical Advisory Note No. 4. Samoa Sanitation and Drainage Project (SSDP). 2011. National Sanitation Masterplan Final, April 2011.

Samoa – Community Sanitation Project – Non-Lending Assistance Concept Paper, April 2011. 1992. National Building Code for Samoa. World Bank, 2003. Water Quality: Assessment and Protection. (eds. Richard Davis, Rafik Hirji). The World Bank Washington, D.C.

APPENDIX A: Consultation During IEE Preparation

A1: Consultation with Government Agencies

Person

Position and Organization Date Main Comments

Jude Kohlase Assistant Director PUMA

5 October 2011 The Project will provide a significant sanitation improvement to households in villages that are suffering from poorly functioning systems.

Aleluia Taise Principal Urban Management Officer PUMA

6 October 2011 Many existing sanitation systems are not functioning correctly because many septic tanks aren‟t properly designed and maintained. For example, many septic tanks don‟t have a base. Some households are in a flood hazard zone therefore indicating potential harbor and bay pollution especially also in Apia. The scheme provides the opportunity to recommend some existing complaints cases/families with significant wastewater issues to be eligible in the scheme.

Toa‟i Bartley Urban Management Officer PUMA

6 October 2011

Noumea Simi Assistant CEO, Aid and Debt Management Ministry of Finance

5 October 2011 The success of the project will be tied to its sustainability in terms of the willingness of households to spend money on the second maintenance and their interest in maintaining the system.

Mema Motsaga Senior Community Development Officer Ministry of Women, Community and Social Development

6 October 2011 Some of the target villages such as Fusi have a severe water shortage that the Project should consider assisting. This water shortage has the knock-on effect of children having to collect water in some instances. It is important to make sure vulnerable people are considered in household selection. Some households don‟t have flush toilets. Will these households be considered? Will the Project supply these?

Vaialia Iosua Principal Community Development Officer Ministry of Women, Community and Social Development

6 October 2011

Paulo Permita Seuseu

Principal Sanitation Officer Ministry of Health

6 October 2011 Health issues are created by poorly functioning household sanitation systems.

Kenneth Faamoe Senior Building Inspector MWTI

6 October 2011 Many septic tanks do not have bases, therefore they are unsealed and not functioning correctly.

Jammie Sa‟ena Wastewater Divisional Manager Samoa Water Authority

7 October 2011 System sustainability will be reliant upon the ability to pump out the tanks – a function of household understanding, affordability and contractor availability. Need to ensure that new septic tanks are connected to the toilet, not permitting later connection by household. Measuring improvements in downstream water quality and community health attributable to the project will not be possible due to multiple other pollution sources.

Martin Odell Institutional Development Advisor Samoa Water Authority

7 October 2011

Fiatamalii Meredith Waste Division MNRE

11 October 2011 MNRE‟s new sludge dewatering ponds have been in operation since January 2011. They consist of two clay lined ponds for receiving sludge, and bays for spreading sludge to dry.

Mataia Mataia Deputy Coordinator Water Sector Coordination Unit

11 October 2011 Cost of sanitation improvements – there may be cost savings from supplier competition and the economy of scale achieved by installing multiple systems in a village at the same time.

A2: Consultation with Potential Project-Participating Households – 6 and 7 October 2011

Householder

Type of Toilet Issues Discussed Observations

APIA

Togialuga Faitoai Water closet Site in a flood zone Septic tank used for more than 20 years Septic tank not renewed due to cost

Septic tank easily filled during wet season

Ana Kalati Water sealed latrine Toilet used for more than 30 years New toilet not installed due to cost De-sludging costs SAT 300-400 which

they cannot afford

No vent pipe High water table Overflow of septic tank Poorly constructed septic tank

TUFUIOPA

So‟o Seanava Water closet House constructed on stream due to limited available land

Septic tank has never been pumped out

No vent pipe Location has a high water table

Mele Le Mamea Water closet Flood-prone location Septic tank used for three years (new tanks provided by SWA under SSDP)

LEVI-SALEIMOA

Leau Paaniani Water closet Limited available land Septic tank has never been pumped out

Septic tanks overflows directly into sea Evidence of septic tank leaking

Sefo Tausaga- fou Water Closet Toilet constructed by family in 2005 Base not cemented Water supply is an issue

Two septic tanks No soakage pit Grey water from shower and sink

discharged into sea

Faeafa Atilua Water closet Water supply is an issue

Absence of soakage pit

SALELESI

Sooialofa Water closet Septic tank has never been pumped out due to distance from town and cost

Water supply is an issue

No lid for pumping out of septic tank

Aagi Tusitafu Water closet Flood prone zone Two septic tanks for each toilets Grey water discharge d into drainage

line

Sonialofa Eliu Water closet Septic tank has never been pumped out because it has not posed a problem and unaware of the need to do so

No soakage pit

FUSI

Olaito‟a Asovale Water closet Tsunami aftershocks fractured the septic tank, producing a foul smell. The tank was covered with sand to reduce the odor (as a temporary solution)

No solid base in septic tank Septic tank has never been pumped out During king tides the smell from the

septic tank worsens Water supply is an issue

No vent pipe Septic tank poorly constructed

Tanupo Lotoā Water closet Septic tank leaks at high tide Septic tank used for more than 10 years

but has never been pumped out

No vent pipe

FALEFA

Tapeli Leafa Water sealed latrine 5 adults & 6 children use a single latrine Water supply is an issue Latrine used for more than 30 years New toilet not constructed due to cost 1-2 people work to provide the family‟s

livelihood - mainly depend on the plantation for livelihood

Poor surrounding for health A proper toilet facility is highly

recommended

Suia‟i Eti Water closet Toilet used for more than 10 years Septic tank has never been pumped out

Grey water discharged into river Septic tank poorly constructed - no

base or man-hole

APPENDIX B: Example Format for EMP Construction Progress Report

1. Summary of issues from previous report - and how they have been addressed.

2. Progress and issues during current reporting period

Grievance Redress - summary of grievances received during the reporting period and resolutions.

Mitigation measures - summary of mitigation measure effectiveness and related issues: - optimal siting and design of sanitation systems: summary of solutions for difficult

sites; - site disturbance: application of mitigation measures, effectiveness of measures,

complaints received; - disposal of excavated material: types, estimated volume, and disposal locations; - disposal of solid waste: types, estimated volume, and disposal locations; - worker and household safety: number of worker/householder accidents,

treatment provided, and remedial measures taken to reduce identified hazards; confirmation that personal protective equipment are worn by all construction workers; erection of temporary safety fencing around construction sites.

3. Conclusions and Recommendations – including outstanding actions to be taken to

improve performance during the next reporting period.

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