FULL List of Conditions in FG Provisional EIA Approval of Cross River Super Highway

There has been much rejoicing by the Cross River State Government over an "EIA approval" for its proposed superhighway. However what was obtained is a conditional approval with 23 pre-conditions. As usual people do not have the full text of the conditions and clearly the State Government is not releasing any details. Here is a list of all the pre-conditions many of which cannot be completed within a 2 week deadline or are vague at best. 

23 CONDITIONS FOR PROVISIONAL APPROVAL OF THE SUPERHIGHWAY PROJECT     

Some Highlights

        Plan to be revised and resubmitted within 2 weeks

• ·         Development and funding of biodiversity offset to be included
• ·         List of all affected 5 communities  must be made public by the Cross River State      Govt. 
• -         Communities already affected by earlier clearing before stop work order last year  must be compensated before work commences
• ·         Create and implement resettlement plan etc before starting work
• ·         CRSG to maintain corridor at 70m. Reversal of revocation of earlier hotly contested 
•           20.4km width with 10km either side offset must  be GAZETTED before work  commences. Affected land ownership revoked had included Bakassi, Akpabuyo, Calabar Municipality and Calabar South contrary to popular belief it was just a forest matter in Central and Northern LGs. 
• ·         All non-Nigerian and Cross River wild life references to be addressed.
• ·         Long-term indirect impact on CRNP due to hunting and habitat loss to be addressed
• ·         All NGOs, national and international, to be consulted throughout
• ·         CRSG to protect hydrology and wildlife corridors
• ·         Map to be made clearer, should not cut through Ekuri or CRNP
• ·         Erosion controls to be included
• ·         Safety standards      
• 
  

Approval for the project subject to the following conditions:

1. The EIA approval shall cover only the construction of a 275km long by 70m width Super Highway of 6 lanes including setbacks and other associated infrastructures such as eco-friendly bridges, culverts, drainages from Calabar to Katsina-Ala junction in Cross River State.
2. Cross River State Government (CRSG) shall ensure that the construction of the entire road project and associated infrastructures conform to standard engineering codes and International best practices.
3. CRSG shall ensure that the diverse management plans, which include Environmental Management Plan (EMP); Biodiversity Action Plan (BAP); Resettlement Action Plan (RAP); Livelihood Restoration Plan (LRP); Greenhouse Gas Management Plan (GHGMP); Public Consultation Plan (PCP); Waste Management Plan (WMP); Traffic Management Plan (TMP) as well as Labour and Human Resources Plan (LHRP) put in place for the road project are strictly adhered to as required throughout the project lifecycle.
4. CRSG shall engage a group of accredited Consultants to effectively manage the diverse management plans for the proposed road project.
5. CRSG shall ensure the realignment of the 275.344km road corridor from the boundary of the Cross River National Park is in line with the National Park Service (NPS) Act CAP LFN 2016.
6. CRSG shall ensure the re-routed road corridor is clearly depicted on a map in the updated EIA report taking cognizance of the boundary of Cross River National Park and Ekuri Community Forest as well as conform to international best practices on setbacks for highways in critical ecosystems such as the proposed corridor.
7. CRSG shall gazette the reversal of revocation order on the acquisition of 10km on either side to the 70km span of the road corridor as well as the gazetting of the boundary of Cross River National Park within two weeks (2) of receipt of this letter.
8. CRSG shall ensure that the initial land clearing of the road corridor that was carried out without due inventory of the third party properties/farmlands is revisited to adequately compensate the project affected persons (PAPS) in line with National and International standards of practice on resettlement and restoration plans. This shall be done prior to project commencement.
9. CRSG shall identify all proximate communities to the road corridor within the established area of influence as well as the project affected persons (PAPS) and ensure that every community/PAP is regularly consulted with throughout the project lifespan.
10. The environmental offsetting should be one of the guiding principles for the proposed road construction as the proposed project area of influence is noted for endemic, threatened and endangered flora and fauna. There shall be development and funding of Biodiversity offset by CRSG.
11. CRSG shall ensure that all relevant non-governmental organizations both local and international are consulted with regularly during the project lifespan to ensure among others biodiversity protection and project sustainability.
12. CSRG shall ensure that the highly technical eco-friendly bridges to be constructed at strategic points/biodiversity hotspots/critical ecosystem on the road corridor are intensively monitored by specialized accredited consultants.
13. CSRG shall ensure that the borrow pits proposed for the road project are provided with coordinates for ease of location, site identification number, reclaimed and converted to alternative environmental-friendly uses in line with regulatory standards as well as International best practices.
14. CRSG shall ensure that the proposed road setbacks from third party structures, farmlands, critical ecosystem and green areas confirm to Engineering code of practice/regulatory standards as well as International best practices.
15. CRSG shall ensure that cautionary signs are appropriately placed at strategic points along the road corridor during implementation and throughout the lifecycle especially for wildlife crossing.
16. CSRG shall ensure proper drainage termination for the flow route of run-off/storm water to protect the road corridor from erosion, ensure that the road embankment is constructed in a way that allows free-flow of surface water run-off, that any existing access road to neighbouring villages and settlements are not blocked, create appropriate buffer zones to prevent damage to unique ecosystems as well as enhance forest cover
17. CSRG shall put in place appropriate road furniture and safety standards in line with International best practices.
18. CRSG shall ensure that the proposed project protect the hydrology of wetlands, streams and channels through restoration of natural drainage pattern and reduce disruption of of ecological processes by providing wildlife corridor. 
19. CSRG shall provide adequate personal protective equipment for workers, ensure that every worker on the project is adequately trained on Health; Safety and Environment procedures for Highway and provide sanitary facilities and mobile clinic during project construction
20. CSRG shall ensure that the maintenance and management of the road corridor is in line with International best practices.    
21. There shall be Impact Mitigation Monitoring (IMM), Post Impact Assessment (PIA), Environmental Audits and Compliance Monitoring on the project by the Federal Ministry of Environment in collaboration with other relevant regulatory agencies.
22. CSRG shall put in place a robust contingency plan for the proposed road project.
23. CSRG shall update 4^th version of the EIA report to also include the following:-

a.      To exclude flora and fauna that are non-existent in the proposed project area of influence as per the attached;

b.      A comprehensive list of the actual affected communities along the proposed road corridor;

c.       List of borrow pits with coordinates and site identity for the proposed road project;

d.      Map clearly showing the preferred road corridor with coordinates as well as major crossings along the entire stretch;

e.      The EIA report should consider indirect long term impacts of hunting and habitat loss on Cross River National Park proximity to the Super Highway with improved access to the forest.     

f.        The updated 4^th version of the EIA report shall be submitted to the Ministry within two (2) weeks of the receipt of the letter.

ADD ON. In my opinion none of these requirements can be done in 2 weeks, there are still no funders and with the recent NDDC take over of the old Calabar - Oban - Ikom - Etung road the journey to Ikom will be 1hr without the super highway within the next 2 years well before the super highway 2022 proposed completion date.

Superhighway: Government seeks explanation on ‘strange’ wildlife EIA mentions - Environews

The roloway monkey is not found in Nigeria. Cross River State EIA claims it is. Photo credit: Sébastien Meys, La Palmyre Zoo

This article appears in Environews

In a move that appear to call the authenticity of the report to question, the Federal Ministry of Environment (FMEv) has categorically stated that such wildlife do not exist in Cross River State – some not even in Nigeria – and therefore wants state officials to address such queries in the updated report that is expected to be submitted in two weeks.

For instance government explained that the Bunbundi bat (Chalinolobus egeria) has not been recorded from Cross River and the pitch shrew (Crocidura picea) has only ever been recorded from Cameroon.

Additionally, noted the FMEv, while the long footed shrew (Crocidura crenata) has not been recorded from Nigeria, the Eisentraut’s mouse shrew (Myosorex eisentrauti) is only found on the island of Bioko.

Similarly, the forest chameleon (Chamaeleo camurunensis) – assumed to be Trioseros camerunensis is restricted to Cameroon, while the Cameroon worm lizard (Cynisca shaeferi) has not been recorded from Nigeria.

Furthermore, both the Schneider’s banana frog (Afrixalus Schneider) and the Dizangue reed frog (Hyperrolius bopeleti) have only ever been recorded from Cameroon.

Also mentioned were the Werner’s river frog (Phrynobatrachus werneri) which FMEv officials say has only been recorded in Nigeria from the Obudu Plateau, and the worm lizard (Cynisca gansi), which is said to have only ever been recorded from Okoloma village near PortHarcourt.

The FMEv wrote: “Many of the species listed in Table 6.1 such as the Indian Malimba, Sclater’s guenon and the Anambra waxbill are not present in Cross River State, though known from Nigeria.

“Appendix A2 is clearly not the work of PGM Nigeria Limited and has merely been copied from elsewhere. This is unacceptable. The list contains many species not known from Cross River such as the Niger Delta red colobus monkey (Procolobus epieni); others such as the roloway monkey (Cercopithecus roloway) are not found in Nigeria and some are not even known from Africa such as the American bullfrog (Lithobates catesbaeianus).

“There is no hedgehog (Erinaceus or Atelerix) (listed on Table 4.56) found in the rainforests of Cross River State; it likely confused with the brush-tailed porcupine.

“Table 4.60 lists threatened mammal species, but Cercopithecus erythrogaster is not found in Cross River and Cercopithecus roloway is not found in Nigeria.”

Designed to link Calabar, the state capital, to the neighboring Benue State, the $3.5 billion Superhighway will pass through biodiversity rich forests in the Ekuri community as well as the Cross River National Park (CRNP), a development observers feel will have far reaching implications for thousands of families and their livelihoods, as well as flora and fauna.