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GUBLES NIGERIA LIMITED

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GUBLES NIGERIA LIMITED

ENVIRONMENTAL BASELINE DATA AND MANAGEMENT PLAN FOR SAND DREDGING IN IKOT AKPAN ESHIET, ONNA L.G.A- AKWA IBOM STATE


Background 
Sand mining is an economic activity that if sustainably harness can improve the well being of the people. Sand has numerous uses ranging from house building to road construction. Therefore, the demand for sand is on the increase in Akwa Ibom State. To meet this demand, many people resort to sand mining without paying attention to the environment. The consequence of this negligence is environmental degradation which ranges from flanking of riverbanks, bio-diversity dwindling, channels destabilization, distorted topography, deforestation, erosion, loss of wetland, general degrading of the ecosystem with air, water and land pollution (Adekoya, 1995; Aigbedon, 2005; Kondolf, et al, 2001).
Considering the importance of the environment in sustainable economic activities, it becomes expedient that proper environmental management should be given high priority before the implementation of sand mining activity.

Benefits of the Project
The benefits include the following:
• Production of quality sand to meet the increasing demand in environment friendly way;
• Creation of livelihood opportunities to the teeming population in the area;
• Provision of some facilities to the communities as part of social corporate responsibilities;
• Encouraging investment in the area by encouraging investors who may use the transaction opportunity in the course of sand purchasing to explore investment opportunities in the area. 
• Generate revenue to the Federal and State Government.
• Increase the surrounding river volume for increase fish habitat
• Act as a dredging agent to maintain the surrounding water cavity and check silting from inflowing streams.

Project Sustainability
As a prerequisite for sustainable sand dredging in Ikot Akpan Ishiet, the Project shall be undertaken using the Best Available Technology (BAT) in the industry. Specific measures shall be taken to ensure technical, economic and environmental sustainability of the Project. The Project shall be environmentally sustainable as the Proponent is aware that the ecological integrity of an aquatic ecosystem is the summation of its capability of supporting balanced biological, chemical and physical variables and their inter-relationships that maintain the ecosystems and its functions.

Project Description
The technical information about sand dredging Project such as Location, Description, components, activities, associated waste management and safety issues are highlighted in this section.

Components of the Project
The Project involves the following major components: 
• Site Acquisition
• Clearing of site (swamp) 
• Excavation, cutting and filling to foundation level
• Leveling of ground using excavator
• Clearing of access road
• Coupling of dredger
• Test running of dredger and establishments of wells
• Making of bump walls
• Commencement of sand dredging operations
• Stock piling of sand 
• Transportation / haulage of sand
• Decommissioning and abandonment


Dredging Activities
The following activities take place during dredging operations;
• Anchor handling
• Removal of debris from cutter
• Lifting of materials
• Fabrication works (repair of broken parts, fabrication of temporary facilities)
• Maintenance of floating and submerged pipelines.

Objectives of the Environmental Baseline Report and Management Plan 
The objectives of the Environmental Baseline Report and Management Plan for the project are to:
• Obtain all necessary information/data to satisfy regulatory requirements of Federal, State and Local Authorities on environmental matters, and Stakeholders;
• Show that a systematic assessment of the impacts of the project has been carried out using standard procedures;
• Identify all aspects of the project that may impact the environment positively or negatively;
• Provide necessary information and evidence for developing an Environmental Management Plan (EMP) for the project in its entirety;
• Make appropriate recommendations and develop strategies that would prevent, reduce or control identified negative/adverse impacts;
• Provide the regulatory authorities with a framework to confirm compliance with environmental policies and requirements;
• Provide the community with evidence of the management of the project in an environmentally acceptable manner;
• Ensure that sand and gravel extraction is carried out in a sustainable way;
• Identify unforeseen impacts of the activity and determine if any detected alterations in the environmental components are caused by dredging operations or other factors;
• Provide early warning on environmental damage so that emergency procedure can be activated to prevent or minimize the deterioration of the environment;
• Provide literature and baseline information that can act as a beacon for reference as statusquo.

Study Area
The Project area is located in Ikot Akpan Ishiet in Onna Local Government Area, Akwa Ibom State. Onna shares boundary with Eket, Mkpat Enin and Etinan LGA. Ikot Akpan Ishiet is located along Eket-Mkpok Road. There are three clans in Onna local government area namely; Oniong, Nnung Ndem and Awa, which together form the acronym Onna.

The area has a total of forty-one villages with Awa accounting for twenty and 2006 census figures put its population at 123,000.


Technique used for the Study 
The study involves a combination of multidisciplinary standard methods from pure science, engineering and social sciences in the acquisition and evaluation of data for characterizing the project environment, impact identification and evaluation as well as establishment of mitigation and enhancement measures for adverse and beneficial impacts respectively. The procedure adopted in carrying out this study involved initial activities; field data collection, analysis and interpretation; consultation; impact identification and evaluation; development of mitigation measures; reporting and review.

Prior to fieldwork activities, an extensive literature research was carried out in order to obtain information/data on the climate, meteorology, geology, socio-economic features, vegetation, wildlife and the general physico-chemical and biological characteristics of the project environment.

Fieldwork and Data Analysis and Interpretation 
Data gathering exercise was carried to validate existing literature information. The fieldwork was limited to biophysical, socio-economic and health assessments.

The biophysical team measured air quality/ noise levels, water sampling, vegetation and wildlife assessment in the study area. The socio-economic crew carried out the socio-economic impact as well a health impact assessment of the project on the communities within the of study area. Representatives of the Federal Ministry of Environment as well as the Akwa Ibom State Ministry of Environment supervised the field activities.

Consultation with Stakeholders
Intensive consultation was carried out with the host communities/stakeholders to intimate them of the project and associated activities; solicit/articulate their views, concerns and expectations on pertinent environmental, social and health issues for integration into the impact prediction, assessment, evaluation and mitigation.

The method of consultation primarily involves information dissemination and interactions/dialogue with the various stakeholders in the project including professionals in relevant fields of agriculture, engineering, science, health, sociology, and environmental issues as well as the host communities. Those consulted within the project area include traditional rulers/heads, youth representatives as well as women folks in the area.

Impact Identification and FMENV Evaluation 
The potential and associated impacts of the project were systematically assessed using the FMEnv EIA Sectoral Guidelines for infrastructural development; International Finance Corporation Environmental, Health and Safety guidelines for hazardous materials management; Nigerian Minerals and Mining Act. 2007; Guidelines for Environmental Impact assessment; Sectorial Guidelines for Mining of Solid Minerals, Beneficiation and Metallurgical Processes; National Requirements and Guidelines on Environmental Management System in Nigeria; and World Bank Environmental Assessment Sourcebook for project development. The envisaged project activities as well as the environmental and socio-economic baseline status of the project area with other source references were used to identify and evaluate the potential and associated impacts of the project. This was followed by proffering appropriate mitigation and enhancement measures for the adverse and beneficial impacts respectively.

In addition, professional judgment, knowledge of the ecosystem in which the project is located, and consensus of opinions were important tools used in determining appropriate impact mitigation and enhancement measures.

Furthermore, post auditing or monitoring has been designed into the Environmental Management Plan (EMP) of the sand mining project to allow for further improvement of operational practices if those initially established prove inadequate.

Legal and Administrative Requirement
Guiding policies and regulations relating to environmental protection being enforced by regulatory agencies which include; 
• Regulation, standards codes, and recommended practices of the Akwa Ibom State Ministry of Environment and Mineral Resources (AKSMEMR);
• Regulations, standards codes and recommended practices of the Federal Ministry of Environment (FMENV); 
• Other applicable national statutes on environmental protection, and 
• Applicable International Agreements and Conventions to which Nigeria is signatory.

Description of Environment
The existing environmental characteristics of the project site and surrounding area are presented in this chapter. The components described include climate, geology, hydrology, soils, land use, vegetation, wildlife, and socio-economic features. The information is essential for the establishment of environmental base line status of the area and predicting probable effects of the project on the environment.

Baseline Data Acquisition 
A systematic approach was adopted to establish the environmental baseline status of the project area. This strategic approach involved obtaining the regional environmental characteristics through literature survey and project site specific characteristics through field data gathering exercise (observations, onsite measurements, insitu measurements and sample collection) and laboratory analysis of collected samples.

Literature Search
Literature survey was undertaken in order to identify gaps and also understand features peculiar to the project environment that would require detailed survey during the field data gathering exercises. This involved review of relevant literature (publications, articles, journals, textbooks, previous reports etc.) on climate, geology/hydrogeology, population status etc.

The information reviewed include Environmental Impact Assessment reports of related projects, meteorological data sourced from the Nigerian Meteorological Agency (NIMET), others were sourced from desktop, agencies/departments and university studies.

Fieldwork Execution 
The field data gathering exercises was conducted on 15th-16th October 2015, which involved the collection of physical, ecological, social and cultural information of the project area. In order to establish the environmental baseline status of the project area, a baseline data was generated. The following environmental components were considered:

Physical resources 
• Atmosphere (e.g. air quality/noise level) 
• Geology 
• Soils 
• Groundwater
• Surface water

Ecological resources
• Wildlife 
• Vegetation 
• Rare or endangered species

Social and Cultural Resources 
• Population and communities 
• Culture 
• Historical/archaeological sites 
• General health status

To establish the above information, the field data gathering exercises specifically entailed: 
• Soil sample collection (surface 0-15cm) and sub-surface (15-30cm) at 10 locations designated randomly within the project area;
• Surface water /Groundwater sampling from existing borehole close to the project area;
• Biodiversity studies across the project area and within nearby communities.

Project Consultation Process
Consultation is an important element of this socio-economic assessment and also an integral component of the data gathering process. This is because appropriate and adequate consultations will ensure smooth project implementation and guarantee economic and commercial sustainability of the project. It involves information dissemination and interaction/dialogues with the affected communities and other stakeholders of the project.

The consultation programme carried out for the environmental baseline and management plan of the project was preceded by the identification of the relevant stakeholders (directly affected groups), whom include intended beneficiaries of the project (host communities, farmers, traders, etc) as well as regulators, among others. This identification was carried out by the Environmental Consultants in collaboration with the Proponent of the Project.

Impacts Assessment and Mitigation Measures
This section comprises of findings from the overall assessment of the potential and associated impacts of the sand dredging in Akwan swamp, Ikot Akpan Ishiet, Onna L.G.A. It includes established potential impacts on the biophysical and socio-economic environment as well as human health and safety; which could arise as a result of overall project activities. Mitigation measures which would eliminate or reduce to as low as reasonably practicable the identified negative impacts are presented in this chapter.

Here, the project activities that resulted in impacts were weighed against existing legal/regulatory provisions to determine the requirement or otherwise for permits prior to the execution of such activities. Such legal/ regulatory requirements were identified from the laws/guidelines, are presented in Chapter 1 of this report.
The weighting scale used was as follows:

Condition

Rating

No legal/regulatory requirement or provision for carrying out project activity or that is related to impact of activity

Low

Legal/regulatory require or provision exist for carrying out activity or that is related to impact of activity

Medium

A permit is required prior to carrying out project activity which may result in impact on the environment

High

Importance of Environmental Component (I)

The importance of target environmental component in respect of identified potential impact was also determined and rated as “high”, “medium” or “low”. The ratings were based on consensus of opinions among consulted experts including project engineers and other stakeholders in the project. The importance criterion is summarized below.

Importance

Attribute-Environment

High

Highly undesirable outcome (e.g., impairment of endangered, protected habitat, species)

Detrimental, extended flora and fauna behavioral change (breeding, spawning, molting)

Major reduction or disruption in value, function or service of impacted resource

Impact during environmentally sensitive period

Continuous non-compliance with international best practices 

Medium

Negative Outcome

Measurable reduction or disruption in value, function or service of impacted resource

Potential for non-compliance with internal best practices

Low

Imperceptible Outcome

Insignificant alteration in value, function or service of impacted resource

Within compliance, no controls required












Importance Criterion 

Risk Posed by Impact (R): The criteria used to categorize the risk posed by the impacts of the project address both the consequence severity and probability or likelihood of occurrence. In determining the likelihood of occurrence reference was made to historical records of accidents/incidents in sand dredging 

Magnitude Criterion

Magnitude

Attribute-Environmental, Human Health and Safety 

High

Major degradation in quality in terms of scale (>1% of study area or habitat within the study area), appearance, duration (beyond duration of project)

Irreversible or only slowly recoverable (change lasting more than 1 year) degradation of environmental ecosystem level (population, abundance, diversity, productivity)

High frequency of impact (occur continuously and almost throughout the project execution period (3 months)

Geographic extent of impact (e.g. encompassing areas beyond the dredging  site)

Medium

Degradation in quality in terms of scale (>0.1% of study area, habitat), appearance, duration (a few weeks)

Effect beyond naturally occurring impacts variability

Slow reversibility (change lasting a few weeks before recovery), lasting residual impact

Potential for cumulative impact

Intermittent frequency of impact (occur in only a few occasions during the project execution period)

Limited geographic extent of impact (large area within the dredging site)

Low

Minor degradation in quality in terms of scale (<0.1% of study area, habitat, very localized), appearance, duration (a few days to a week

Effect within range of naturally occurring impacts, changes, dynamics

Rapid reversibility (change lasting only a few weeks before recovery), no lasting residual impact of significance

No potential for significant cumulative impact

Low frequency of impact (occur in just about one occasion during the project execution period)

Only very localized geographic extent of impact (e.g. not more than a few meters from impact source point)


Public Interest/Perception (P)
Here, the interest/perception of the public on the project and the identified potential/associated impacts were determined through consultation with project stakeholders. The ratings of “high”, “medium” or “low” were assigned based on consensus of opinions among consulted known stakeholders. The public perception/interest criterion is summarized below.

Public perception/interest criterion

 

Public perception

Attribute-Human and Safety

High

Elevated incremental risk to human health, acute and/or chronic

Possibility of life endangered for on-site personnel

Continuous non-compliance with international best practices

Any major public concern among population in the project region

Medium

Limited incremental risk to human health, acute and/ or chronic

Unlikely life endangered for on-site personnel

Possibility of adverse perception among population

Potential for non-compliance

Low

No risk to human health, acute and/or chronic

No possibility of life endangered for on-site personnel

 

Result of Overall Impact Assessment
The result of the impact assessment exercise is presented in Table 3.1. The Table presents the various project phases, planned project activities, the environmental aspects of the project as well as the identified potential and associated impacts. Also included in the Table are impact significance evaluation criteria: (legal/regulatory requirements (L), risk posed by impact (R), magnitude of occurrence (F), importance of affected environmental component (I), and public perception (P). In addition, the overall ratings of impact significance (High or Medium or Low) of each impact considered have been included.

Impact Discussion
This section presents detailed discussions of overall assessment of the potential and associated impacts of sand mining. The identified associated impacts of related activities on the project’s physical (soil, surface/ground water, and biological resources) and public health are taken into consideration; discussed and classified into three categories:

 Physical

The large-scale extraction of riverbed materials, mining and dredging below the existing riverbed, and the alteration of channel-bed form and shape leads to several impacts such as erosion of channel bed and banks, increase in channel slope, and change in channel morphology. These impacts may cause:
• The undercutting and collapse of river banks,
• The loss of adjacent land and/or structures,
• Upstream erosion as a result of an increase in channel slope, changes in flow velocity, and
• Downstream erosion due to increased carrying capacity of the stream, downstream changes in patterns of deposition, changes in channel bed and habitat type.

 Sand dredging in river causes the destruction of aquatic habitats by bed degradation, lower water levels and channel degradation (Lawal 2011). The processes associated with channel degradation are as follows: 

• Large-scale removal of river sediments,
• Digging below the existing riverbed and
• Changing the channel bed form and shape (ECD 2001).

 All of these cause soil erosion and sedimentation in the water bodies, which reduce water quality.

Excessive mining causes the degradation of rivers. It lowers the stream bottom, which may lead to river bank erosion. Depletion of sand in the streambed and along coastal areas causes the deepening of rivers and estuaries, and the enlargement of river mouths and coastal inlets. It may also lead to saline-water intrusion from the nearby sea.

Excessive stream sand mining is a threat to bridges, river banks and nearby structures. Sand mining also affects the adjoining groundwater system and the uses that local people make of the river.

In-stream mining can have other costly effects beyond the immediate mine sites. Many hectares of fertile streamside land are lost annually, as well as valuable timber resources and wildlife habitats in the riparian areas. Degraded stream habitats result in decline in fish productivity, biodiversity, and recreational potential.
The complete removal of vegetation and destruction of the soil profile destroys habitat above and below the ground as well as within the aquatic ecosystem, resulting in the reduction in faunal populations.

 Water Quality

Riverine sand mining activities will have an impact upon the water quality. Impacts include increased short-term turbidity at the mining site due to re-suspension of sediment, sedimentation due to stockpiling and dumping of excess mining materials and organic particulate matter, and oil spills or leakage from excavation machinery and transportation vehicles.

Increased riverbed and bank erosion increases suspended solids in the water at the excavation site and downstream. Suspended solids may adversely affect water users and aquatic ecosystems. The impact is particularly significant if water users downstream of the site are abstracting water for domestic use. Suspended solids can significantly increase water treatment costs.

Ecological

Mining which leads to the removal of channel substrate, re-suspension of streambed sediment, clearance of vegetation, and stockpiling on the streambed, will have ecological impacts.

Noise Pollution

Dredgers and other machineries used at the site can cause noise pollution to surrounding environs which may eventually pose a threat on wildlife resulting in species extinction and distress to inhabitant of the immediate environment. This may cause related health hazards and nuisance to the surrounding residents and workers around the dredging areas.

Destruction of Landscape

Landscape destruction, is one of the significant effects of mining in the area. The original landscape has been destroyed and altered as a result of excavated pits and trenches, leaving behind unpleasant sights which as well render the land unsuitable for any productive purpose. During the raining season, excavations collect and store stagnant water and as such, serve as breeding ground for pests

Impact Mitigation Measures

A comprehensive risk assessment matrix was used to determine the mitigation requirements for each of the impacts identified. The frequency, severity, sensitivity, scale, longevity, political, economic, legal, reputation/image and communication/complaints were factors taken into consideration during these assessments.

Environmental Management Plan

A suite of environmental management processes are being applied globally to promote sustainable development.
An Environmental Management Plan (EMP) is a framework that helps a company achieves its environmental management goals through consistent control of its operations. It also helps companies address its regulatory demands in a systematic and cost-effective manner. This proactive approach can help reduce the risk of non-compliance as well as improve health and safety practices for employees and the public.
The World Bank (1991) defines Environmental Monitoring Plan (EMP) as a set of mitigation, monitoring and institutionalized measures that must be ensured during the implementation and operation of a project to eliminate adverse environmental and social impacts or at least reduce them to acceptable level.
EMP provides the guidelines and procedures for managing the significant impacts of projects.
This EMP details all elements of the Environmental Management Strategy to achieve best-practice environmental management for the maintenance of sand dredging in Ikot Akpan Ishiet, Onna L. G. A of Akwa ibom State.
The EMP is a living document that will be reviewed and updated if necessary during the work periods to achieve its objective of meeting best-practice environmental management in accordance to sustainable project implementation.
The primary purpose is to ensure that appropriate environmental management practices are followed throughout the life-cycle of the project.

 EMP Objectives

The overall objective of this EMP is to demonstrate that environmental aspects, potential impacts associated with sand dredging have been identified and evaluated. This also ensures that measures are put in place for mitigating the significant adverse impact in line with Nigerian Environmental Policy, National Environmental Standards and Regulations Enforcement Agency (NESREA) and ISO 14001 (EMS) specifications as well as to demonstrate that Proponent has an effective plan for controlling the significant adverse impacts of its activities.

 Environmental Monitoring

Environmental monitoring is a tool used to identify environmental changes resulting from the implementation of a project. In the context of this report, environmental monitoring programmes are carried out to achieve the following results:
• To ensure that the dredging project meet all environmental regulatory requirements, and that commitments made in the EMP section and/or the conditions of approval are being met;
• To verify the predictions and assessment of environmental effects, thus contributing to better assessments in the future;
• To evaluate the performance effectiveness of mitigation;
• To compare actual and predicted changes to environment, so that immediate actions can be taken to mitigate unanticipated impacts;
• A control and monitoring system would be established to ensure negative impacts are reduced to the barest minimum.

 Auditing 

An audit analyses the result obtained from monitoring, assesses whether objectives and targets have been met and whether there are variances from the stipulated EMP and legal requirements. In addition, the audit assesses whether EMP implementation has been undertaken according to planned arrangements and that the EMP itself is being appropriately updated. The audit shall confirm that identified corrective actions have been undertaken and then assess the effectiveness of such actions.

 In line with the above objectives, the proponent shall develop and establish a detailed audit procedure, establish the frequency of conducting audits and ensure that auditors are competent and must be able to undertake the audit objectively and competently. Mandatory environmental Audit Report shall be produced every three years.

 Emergency Response Plan 

Emergency incidences are unforeseen situations resulting from an accident or offset in normal operating condition. The most likely incident/accident associated with the project implementation is fire.

 Consequently, in event of an emergency during the life span of the project. Emergency Response Procedure/Plan shall be activated. Its objectives are: 

• To ensure no loss of life and prevent injuries;
• To ensure that the environment is protected;
• To ensure that the manpower, equipment and funds are available to effectively contain and clean up oil/chemical spills.
• To ensure that good record keeping is maintained and accurate information concerning emergencies is disseminated to the workers, public and government.

 Closure and Post Closure Plan 

At expiration of the project’s lifespan, a detailed abandonment and decommissioning plan shall be developed by proponents with the relevant regulatory bodies. This is to enable the project fully comply with existing legislations, regulatory requirements at time of site closure. The plan shall consider all technically feasible options for restoration, decommissioning and abandonment, including alternative uses for the asset, in accordance with national and international regulations.

 EMP Implementation 

Supervision and monitoring are fundamental to the successful implementation of an EMP. Therefore, it is vital that monitoring of the extent to which the mitigation measures of this EMP is adhered to by personnel and contractors.
All of the issues described and discussed in this document required monitoring. Therefore, it is crucial for the management of the project to appoint an Environmental Control Officer (ECO) to be responsible for monitoring and ensuring the compliance of this EMP.
The responsibilities of the ECO shall include:
• To draft and implement a monitoring programme to assess compliance with the EMP. This can be achieved by the use of a checklist
• To ensure that the mitigation measures and other requirements set forth in the EMP are adhered to.
• To understand the contents of the EMP and explain it to the contractors, staff, the supervisors and visitors.
• Supervise environmental actions associated with Sand dredging activities on a daily basis.

 Follow up of Environmental Management Plan

This EMP should be implemented to address all activities that have been identified to have potentially significant environmental impacts during normal operations and upset conditions. Implementation of EMP should be based on direct or indirect indicators of emissions, effluents, and resource use applicable to different facilities. Observation and monitoring frequency should be sufficient to provide representative data for the parameter being monitored. Monitoring should be conducted by trained individuals (Accredited Environmental Consultant) following monitoring and record-keeping procedures, and using properly calibrated and maintained equipment. Monitoring data should be analyzed and reviewed at regular intervals and compared with the operating standards so that any necessary corrective actions can be taken.

 Annual Follow-Up of Rehabilitation Work

The dredging company must summit annual reports to the Ministry briefly describing each of the following tasks:
• Rehabilitation work carried out;
• Progress of rehabilitation work compared to original work schedule
• Re-vegetation progress;
• The purpose of the follow-up is to inform the ministry of the progress of rehabilitation plan;
• To minimize the negative effects of sand mining on aquatic ecosystem, the following recommendations are made;
• An integrated environmental assessment, management and monitoring programme should be a part of the sand mining plans
• The government should provide guidelines and enforce legislation aimed at minimizing environmental damage;
• Afforestation should be encouraged to replace the lost species of plants at decommissioning;
• Mining companies should present a prognosis of the possible environmental impact of their operations, as well as the technique for monitoring the impact for approval;
• The government should develop a policy that urges miners to reinvest and rehabilitate old (unused) mine sites. This can reduce the chance of landslides and collapse of structure in near dredging site;
• Mining of sand near residential or develop areas should be discontinued;
• Enlightenment should be made to improve the understanding of the miners and public about the effect of river sand mining on aquatic ecosystems;
• Periodic field checking of river sand mining sites, quantity of sand extraction, periodic environmental auditing and monitoring to estimate impact indicators;
• Workers should be encouraged on the usage of safety devices such as mining helmets, nose dust shields and first aids;
• Government should evolve necessary approach for effective conflicts management and resolution for a sustainable development of the mining industry;
• An environmental monitoring program shall be established for this dredging project. The implementation of the monitoring program will ensure that the requirements of the EMP are being met. All monitoring will be undertaken by suitably qualified persons in accordance with the monitoring requirements. The proponent shall submit a report of the monitoring outcomes at the conclusion of the dredging campaign or at the conclusion of the specified monitoring period to regulators. The following components will required monitoring:
• Sediment characteristics, water quality, flora and fauna, Air quality and Noise level, waste management, hazardous substances and community consultation;
• The height of sand dump relative to the surroundings areas will be regulated to ensure that the dumps do not cause excessive erosion of the neighboring land;
• The area shall be properly planned and developed in a way that the commercial activities associated with the sand mining do not constitute nuisance to the community.



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