Country Environmental Analysis Investing in Natural Capital for Sustainable Development UNION OF THE COMOROS Comoros Country Environmental Analysis Investing in Natural Capital for Sustainable Development March 2023 © 2023 International Bank for Reconstruction and Development / The World Bank 1818 H Street NW Washington DC 20433 Telephone: 202-473-1000 Internet: www.worldbank.org This work is a product of the staff of The World Bank with external contributions. The findings, interpretations, and conclusions expressed in this work do not necessarily reflect the views of The World Bank, its Board of Executive Directors, or the governments they represent. The World Bank does not guarantee the accuracy, completeness, or currency of the data included in this work and does not assume responsibility for any errors, omissions, or discrepancies in the information, or liability with respect to the use of or failure to use the information, methods, processes, or conclusions set forth. 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Cover Photo Credit: Ali Alwahti Contents  | iii | Contents Figures�������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������v Tables�������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������vi Boxes�������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������vii Abbreviations�����������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������viii Acknowledgments�����������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������xi 1. Executive Summary�������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������1 2. Introduction�������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������9 2.1 The Comoros at a Glance��������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������9 2.2 Importance of Natural Capital for the Comoros��������������������������������������������������������������������������������������������������������������������������������������������������10 2.3 A Country Environmental Analysis for the Comoros�������������������������������������������������������������������������������������������������������������������������������������������12 3. The Decline in Natural Capital������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������15 3.1 Natural Capital����������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������15 3.2 Main Drivers of Decline in Natural Capital���������������������������������������������������������������������������������������������������������������������������������������������������������17 3.3 Costs of Environmental Degradation�������������������������������������������������������������������������������������������������������������������������������������������������������������������23 3.4 Benefits of Environmental Restoration����������������������������������������������������������������������������������������������������������������������������������������������������������������25 4. Environmental Governance and Institutional Framework�������������������������������������������������������������������������������������������������������������������������������������������27 4.1 Environmental Legal and Policy Framework��������������������������������������������������������������������������������������������������������������������������������������������������������27 4.2 Environmental Institutional Framework��������������������������������������������������������������������������������������������������������������������������������������������������������������30 4.2.1 National Plans and Strategies for Sustainable Economic Development�������������������������������������������������������������������������������������������������32 4.3 The Way Forward������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������36 5. Key Environmental Sectors�����������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������39 5.1 Land���������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������39 5.1.1 Sector Characteristics������������������������������������������������������������������������������������������������������������������������������������������������������������������������������39 5.1.2 Land Degradation and Its Drivers������������������������������������������������������������������������������������������������������������������������������������������������������������40 5.1.3 Costs of Inaction and Opportunities for Change��������������������������������������������������������������������������������������������������������������������������������������42 5.1.4 Institutional and Legal Context����������������������������������������������������������������������������������������������������������������������������������������������������������������43 5.1.5 The Way Forward�������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������45 5.2 Forests�����������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������46 5.2.1 Sector Characteristics������������������������������������������������������������������������������������������������������������������������������������������������������������������������������47 5.2.2 Deforestation, Forest Degradation, and Their Drivers�����������������������������������������������������������������������������������������������������������������������������47 5.2.3 Costs of Inaction and Opportunities for Change��������������������������������������������������������������������������������������������������������������������������������������48 5.2.4 Institutional and Legal Context����������������������������������������������������������������������������������������������������������������������������������������������������������������50 5.2.5 The Way Forward�������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������50 5.3 Water�������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������51 5.3.1 Sector Characteristics������������������������������������������������������������������������������������������������������������������������������������������������������������������������������52 5.3.2 Water Scarcity, Degradation of Water Quality, and Their Drivers�����������������������������������������������������������������������������������������������������������53 5.3.3 Costs of Inaction and Opportunities for Change��������������������������������������������������������������������������������������������������������������������������������������58 5.3.4 Institutional and Legal Context����������������������������������������������������������������������������������������������������������������������������������������������������������������59 5.3.5 The Way Forward�������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������61 | iv |   Comoros Country Environmental Analysis 5.4 Fisheries, Coastal, and Marine Ecosystems��������������������������������������������������������������������������������������������������������������������������������������������������������63 5.4.1 Fisheries Sector���������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������63 5.4.2 Coastal and Marine Ecosystems��������������������������������������������������������������������������������������������������������������������������������������������������������������72 5.4.3 The Way Forward ������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������74 5.5 Solid Waste Management����������������������������������������������������������������������������������������������������������������������������������������������������������������������������������79 5.5.1 Sector Characteristics������������������������������������������������������������������������������������������������������������������������������������������������������������������������������79 5.5.2 Unsustainable Waste Management and Its Drivers��������������������������������������������������������������������������������������������������������������������������������81 5.5.3 Costs of Inaction and Opportunities for Change��������������������������������������������������������������������������������������������������������������������������������������82 5.5.4 Institutional and Legal Context����������������������������������������������������������������������������������������������������������������������������������������������������������������84 5.5.5 The Way Forward�������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������85 5.6 Nature-Based Tourism�����������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������86 5.6.1 Sector Characteristics������������������������������������������������������������������������������������������������������������������������������������������������������������������������������86 5.6.2 Government Vision�����������������������������������������������������������������������������������������������������������������������������������������������������������������������������������88 5.6.3 Opportunities for Change�������������������������������������������������������������������������������������������������������������������������������������������������������������������������89 5.6.4 The Way Forward�������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������93 6. Looking Ahead�������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������95  trengthen Environmental Governance and Support Recommendation 1: S Institutional Capacity���������������������������������������������������������������������������������������������������������������������������������������������������������������96  romote Sustainable Land, Forest, and Water Management��������������������������������������������������������������������������������������������������97 Recommendation 2: P  romote Sustainable Fisheries and Integrated Marine and Coastal Management�����������������������������������������������������������������98 Recommendation 3: P Recommendation 4: Invest in Integrated Solid Waste Management�����������������������������������������������������������������������������������������������������������������������99 Recommendation 5: Promote Nature-Based Tourism���������������������������������������������������������������������������������������������������������������������������������������������100 7. Conclusions���������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������103 8. References����������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������105 Annex 1: Estimated Costs and Benefits of Restoration Projects for Different Biomes�������������������������������������������������������������������������������������������������113 Annex 2: Calculations on the Costs of Environmental Degradation�����������������������������������������������������������������������������������������������������������������������������115 mpacts of Environmental Degradation on the Livelihoods Annex 3: I of the Comorian Population���������������������������������������������������������������������������������������������������������������������������������������������������������������������������117 Annex 4: Overview of Fisheries Laws and Regulations������������������������������������������������������������������������������������������������������������������������������������������������119 Annex 5: Soil Restoration Measures����������������������������������������������������������������������������������������������������������������������������������������������������������������������������121 Annex 6: Maps of Sand Extraction in Ngazidja and Ndzuwani�������������������������������������������������������������������������������������������������������������������������������������123  ey Environmental Policy, Legislation, and International Agreements Annex 7: K of the Comoros�����������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������125 Annex 8: Stakeholder Consultations�����������������������������������������������������������������������������������������������������������������������������������������������������������������������������127 Figures  | v | Figures Figure 1. Map of the Comoros Islands �����������������������������������������������������������������������������������������������������������������������������������������������������������������������������9 Figure 2. GDP (blue bars) and GDP per capita (orange line) in the Comoros from 2008 to 2020������������������������������������������������������������������������������������12 Figure 3. Structure of the Comoros CEA��������������������������������������������������������������������������������������������������������������������������������������������������������������������������13  he assets and capital that drive wealth and underpin economic and sustainable development (based on the Kenya and Malawi CEAs Figure 4. T and the World Bank’s Changing Wealth of Nations�����������������������������������������������������������������������������������������������������������������������������������������16  otal wealth and GDP of the Comoros (left) and wealth per capital by contributor (right) from 1995 to 2018������������������������������������������������16 Figure 5. T Figure 6. Distribution of per capita wealth in the Comoros��������������������������������������������������������������������������������������������������������������������������������������������17 Figure 7. Changes in wealth from renewable natural capital per capita in the Comoros from 1995 to 2018����������������������������������������������������������������17 Figure 8. Change in total wealth per capital in the lower middle-income countries, Sub-Saharan Africa, and the Comoros from 1995 to 2018���������19 Figure 9. Urban (blue bar) and rural (orange bar) population size and density in the Comoros from 1960 to 2020 �������������������������������������������������������20 Figure 10. Observed average annual mean temperature of the Comoros, 1901–2020��������������������������������������������������������������������������������������������������20 Figure 11. Observed and projected mean temperature in the Comoros from 1990 to 2100 ������������������������������������������������������������������������������������������21  istorical sea level for coastal Comoros (1993–2015) based on satellite data, observed anomalies (mm) relative to mean for Figure 12. H 1993–2012�����������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������21  verview of the most frequent natural disasters in the Comoros from 1980 through 2020 and the number of people affected�����������������22 Figure 13. O Figure 14. Modeled direct losses from earthquakes, floods, and tropical cyclones�������������������������������������������������������������������������������������������������������22  nvironmental institutional framework of the Comoros showing the subdivision of general and regional directorates into specific Figure 15. E sectors: environment and forests, fishery resources, and agriculture and livestock strategies��������������������������������������������������������������������31 Figure 16. The five strategic pillars of the PCE 2030�������������������������������������������������������������������������������������������������������������������������������������������������������34 Figure 17. Alignment of SCD and CPF with government priorities���������������������������������������������������������������������������������������������������������������������������������36 Figure 18. Overview of identified environmental challenges in the Comoros����������������������������������������������������������������������������������������������������������������40 Figure 19. Changes in land health and productive capacity over 15 years (1999–2013)������������������������������������������������������������������������������������������������41 Figure 20. A vicious cycle of poverty and deforestation�������������������������������������������������������������������������������������������������������������������������������������������������49  aps of the 44 watershed basins on Ndzuwani (left) and 25 watershed basins on Mwali as identified in the National Water Strategy Figure 21. M and Program���������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������53 Figure 22. Trend in renewable water resources per capita (cubic meters/inhabitants) in the Comoros from 1962 to 2017������������������������������������������54 Figure 23. Map showing permanent waterways in 1955 and 1973 in Ndzuwani�����������������������������������������������������������������������������������������������������������55 Figure 24. The causal chain analysis of “poor access to drinking water”����������������������������������������������������������������������������������������������������������������������56  rend in the amount of water- and sanitation-related official development assistance as part of a government-coordinated spending Figure 25. T plan from 2000 to 2020���������������������������������������������������������������������������������������������������������������������������������������������������������������������������������57 Figure 26. Water use in the Comoros (2016)�������������������������������������������������������������������������������������������������������������������������������������������������������������������60  ain pelagic and demersal species caught in domestic fisheries in Mt in 2020������������������������������������������������������������������������������������������64 Figure 27. M  istribution and density of seagrass beds around western Ndzuwani island (upper image) and the south of Ngazidja (lower image)������73 Figure 28. D Figure 29. Coral reef locations along Ndzuwani�������������������������������������������������������������������������������������������������������������������������������������������������������������74 Figure 30. Coral reef status in the Comoros by island in 2018����������������������������������������������������������������������������������������������������������������������������������������76 Figure 31. Composition of household waste in Mutsamudu Bay, Ndzuwani in 2014�����������������������������������������������������������������������������������������������������80 Figure 32. Household solid waste disposal in the Comoros by method and island in 2017�������������������������������������������������������������������������������������������81 Figure 33. Waste hierarchy as part of an integrated solid waste management strategy����������������������������������������������������������������������������������������������83 Figure 34. Trend in the number of international tourist arrivals in the Comoros from 1996 to 2020������������������������������������������������������������������������������87 Figure 35. Overview of the proposed locations for tourist infrastructure of the 2019 National Tourism Strategy��������������������������������������������������������90 Figure 36. Overview of components of the UNESCO sustainable tourism toolkit����������������������������������������������������������������������������������������������������������91 Figure 37. Estimated costs and benefits of restoration projects in different biomes���������������������������������������������������������������������������������������������������113 Figure 38. Map of sand extraction in Ngazidja�������������������������������������������������������������������������������������������������������������������������������������������������������������123 Figure 39. Map of sand extraction in Ndzuwani�����������������������������������������������������������������������������������������������������������������������������������������������������������124 | vi |   Comoros Country Environmental Analysis Tables  ey characteristics of the main islands of Comoros Table 1. K (Source: stakeholder consultations unless otherwise stated)��������������������������������������������������������������������������������������������������������������������������11 Table 2. Comparison of per capita wealth in 2018, constant 2018 US$�������������������������������������������������������������������������������������������������������������������������19 Table 3. The estimated annual costs of environmental degradation in the Comoros�����������������������������������������������������������������������������������������������������24 Table 4. The qualitative magnitude of the costs and benefits of restoration projects���������������������������������������������������������������������������������������������������25 Table 5. Mitigation actions for the Comoros�������������������������������������������������������������������������������������������������������������������������������������������������������������������29 Table 6. Adaptation measures for the most vulnerable sectors of the Comoros������������������������������������������������������������������������������������������������������������29 Table 7. Advantages and disadvantages of the three tenure regimes���������������������������������������������������������������������������������������������������������������������������33  otal overview of the topics addressed in the flagship projects and structuring Table 8. T projects of the PCE 2030, including their cost estimates in US$ millions���������������������������������������������������������������������������������������������������������35 Table 9. Economic importance of the agricultural sector������������������������������������������������������������������������������������������������������������������������������������������������41 Table 10. Volumes of renewable water resources and their exploitation rates per island��������������������������������������������������������������������������������������������53 Table 11. Progress on SDG 6 indicators��������������������������������������������������������������������������������������������������������������������������������������������������������������������������60 Table 12. Importance of the fisheries sector for the economy of the Comoros��������������������������������������������������������������������������������������������������������������63  he 2020 Environmental Performance Index (EPI) of the fisheries sector Table 13. T of the Comoros������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������65 Table 14. Overview of cover (ha) of coral reefs and mangrove ecosystems�������������������������������������������������������������������������������������������������������������������72 Table 15. Description of the flagship tourism project of the PCE 2030���������������������������������������������������������������������������������������������������������������������������89 Table 16. Soil restoration measures�����������������������������������������������������������������������������������������������������������������������������������������������������������������������������121 Table 17. List of stakeholders interviewed individually and in focus groups����������������������������������������������������������������������������������������������������������������127 Table 18. List of organizations engaged during the site visit to the Comoros��������������������������������������������������������������������������������������������������������������128 Table 19. Validation workshop participant list��������������������������������������������������������������������������������������������������������������������������������������������������������������129 Table 20. Final workshop participant list����������������������������������������������������������������������������������������������������������������������������������������������������������������������131 Boxes  | vii | Boxes Box 1. The Comoros Country Environmental Analysis (CEA)���������������������������������������������������������������������������������������������������������������������������������������������1 Box 2. The Wealth of Nations and the Wealth of the Comoros��������������������������������������������������������������������������������������������������������������������������������������16 Box 3. The Wealth of the Comoros Compared to the Wealth of Other Countries����������������������������������������������������������������������������������������������������������18 Box 4. Cyclone Kenneth and the Post-Kenneth Project���������������������������������������������������������������������������������������������������������������������������������������������������23 Box 5. Disaster Risk Management����������������������������������������������������������������������������������������������������������������������������������������������������������������������������������24 Box 6. Updated National Environmental Policy of the Comoros�������������������������������������������������������������������������������������������������������������������������������������28 Box 7. Nationally Determined Contribution (NDC)����������������������������������������������������������������������������������������������������������������������������������������������������������29 Box 8. Land Tenure in the Comoros���������������������������������������������������������������������������������������������������������������������������������������������������������������������������������33 Box 9. Family Farming Productivity and Resilience Support Project (PREFER)����������������������������������������������������������������������������������������������������������������42  nhancing Adaptive Capacity for Increased Resilience to Climate Change Box 10. E in the Agricultural Sector (CRCCA)���������������������������������������������������������������������������������������������������������������������������������������������������������������������44 Box 11. Global Climate Change Alliance (AMCC)�����������������������������������������������������������������������������������������������������������������������������������������������������������44 Box 12. Integrated Development and Competitiveness Project (PIDC)���������������������������������������������������������������������������������������������������������������������������45 Box 13. Pilot Project: Land Security��������������������������������������������������������������������������������������������������������������������������������������������������������������������������������46 Box 14. Deforestation�����������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������47 Box 15. Terrestrial National Parks�����������������������������������������������������������������������������������������������������������������������������������������������������������������������������������48 Box 16. One Comorian, One Tree�������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������51 Box 17. Access to Drinking Water as a High Priority������������������������������������������������������������������������������������������������������������������������������������������������������58 Box 18. Projects in the Comoros That Have Adopted an IWRM Approach���������������������������������������������������������������������������������������������������������������������61 Box 19. SWIOFish1����������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������66 Box 20. Projects Targeting IUU Fishing���������������������������������������������������������������������������������������������������������������������������������������������������������������������������67 Box 21. Co-Management of Marine Resources��������������������������������������������������������������������������������������������������������������������������������������������������������������68 Box 22. Marine National Parks and Protected Areas������������������������������������������������������������������������������������������������������������������������������������������������������69 Box 23. PROBLUE������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������71 Box 24. The Case of Coastal Sand Mining����������������������������������������������������������������������������������������������������������������������������������������������������������������������75 Box 25. Global Fund for Coral Reefs Investment Window����������������������������������������������������������������������������������������������������������������������������������������������78 Box 26. Overview of PCE Structuring Project 6: Integrated Waste Management����������������������������������������������������������������������������������������������������������84 Box 27. “A New Tourist Hub in the Indian Ocean”: Flagship Project of the PCE 2030����������������������������������������������������������������������������������������������������89 Box 28. EU Tourism Co-management Project for Improved Local Livelihoods����������������������������������������������������������������������������������������������������������������92 | viii |   Comoros Country Environmental Analysis Abbreviations AEPA National Drinking Water Supply and Sanitation Strategy AFD French Development Agency (Agence Française de Développement) AFDB African Development Bank AAL Average Annual Loss AMCC Global Climate Change Alliance (Alliance mondiale contre le changement climatique) ANAGID National Agency for Integrated Waste Management BER Blue Economy Roadmap BESF Strategic Framework for a National Policy on the Blue Economy CEA Country Environmental Analysis CNCSP National Center for Fisheries Control and Surveillance (Centre national de contrôle et de surveillance des pêches) CoReCSuD Co-Management of Coastal Resources for Sustainable Livelihoods CPAD Development Partners Conference CPF Country Partnership Framework CRCCA Enhancing Adaptive Capacity for Increased Resilience to Climate Change in the Agricultural Sector CSA Climate-Smart Agriculture DALY Disability-Adjusted Life Year DG General Directorate DGEME General Directorate for Energy, Mines and Water (Direction générale de l’énergie des mines et de l’eau) DGEF General Directorate of Environment and Forests (Direction générale de l’environnement et des forêts) DGRH General Directorate of Fisheries Resources (Direction générale des ressources halieutiques) DGSAE General Strategic Directorate of Agriculture and Livestock (Direction générale de la stratégie agricole et de l’élevage) DNEA National Water and Sanitation Directorate DOPA Digital Observatory for Protected Areas DREA Regional Directorate of Water and Sanitation DRM Disaster Risk Management DSCRP Strategy Document for Growth and Poverty Alleviation DTM Technical Directorate of Meteorology (Direction technique de la météorologie) DWSS Drinking Water Supply and Sanitation DWSSP Drinking Water Supply and Sanitation Project EEZ Exclusive Economic Zone EIA Environmental Impact Assessment EPI Environmental Performance Index ESV Ecosystem Service Value Acronyms are based on French titles or terms as relevant. Abbreviations  | ix | EU European Union FEC Fonds Environnemental des Comores FLE Framework Law of the Environment FNDIEA National Fund for the Development of Water and Sewage Infrastructure GDP Gross Domestic Product GEF Global Environmental Facility GHG Greenhouse Gas GIS Geographical Information Systems GoC Government of the Union of the Comoros HDI Human Development Index ICMP Integrated Coastal Management Plan ICRAF International Council for Research in Agroforestry IFAD International Fund for Agricultural Development INRAPE National Institute for Research in Agriculture, Fisheries and the Environment (Institut national de recherche pour l’agriculture, la pêche et l’environnement) IORA Indian Ocean Rim Association IOC Indian Ocean Commission IOTC Indian Ocean Tuna Commission IUU Illegal, Unreported, and Unregulated IWRM Integrated Water Resource Management LUCF Land use change and forestry MAPETA Ministry of Agriculture, Fisheries, Environment, Tourism, and Handicrafts (Ministère de l’Agriculture, de la Pêche, de l’Environnement, du Tourisme et de l’Artisanat) MCS Monitoring, Control, And Surveillance MPA Marine Protected Area MTI Marine Trophic Index NAPA National Adaptation Programme of Action NBT Nature-Based Tourism NDC Nationally Determined Contributions NFU National Fishermen’s Union NGO Non-Governmental Organization ODA Official Development Assistance OVK Karthala Volcanological Observatory (Observatoire volcanologique du Karthala) PAPDF Priority Action Plan for Forestry Development (Plan d’action prioritaire de développement forestier) PCE Comoros Emerging Plan 2030 (Plan Comores Émergent 2030) PIDC Integrated Development and Competitiveness Project | x |   Comoros Country Environmental Analysis PNDHD National Programme for Sustainable Human Development (Programme National de Développement Humain Durable) PNE National Environmental Policy (Politique Nationale de L’Environnement) PPP Public-Private Partnership PREFER Family Farming Productivity and Resilience Support Project PRSP Regional Fisheries Surveillance Program RCP Representative Concentration Pathway RENAP National Network of Protected Areas (Réseau National des Aires Protégées) RMI Regional Marine Tropic Index RP10 10-year Return Period RP100 100-year Return Period RP250 250-year Return Period SCA2D Accelerated Growth and Sustainable Development Strategy SCD Systematic Country Diagnostic SDG Sustainable Development Goal SFPA Sustainable Fisheries Partnership Agreement SIDS Small Island Developing State SONEDE Société Nationale chargée de l’Exploitation et la Distribution des Eaux aux Comores SSTL Seychelles Sustainable Tourism Label SWIOFC Southwest Indian Ocean Fisheries Commission SWIOFish1 South West Indian Ocean Fisheries Governance and Shared Growth Project UCEA Union of Water Committees of Ndzuwani UNCLOS United Nations Convention on the Law of the Sea UNDP United Nations Development Programme UNEP United Nations Environment Programme UNESCO United Nations Educational, Scientific and Cultural Organization UNICEF United Nations Children’s Fund USD U.S. Dollar WASH Water, Sanitation, And Hygiene WHO World Health Organization WUA Water User Association YLD Years of healthy life lost due to a disability YYL Years of life lost Acknowledgments  | xi | Acknowledgments The development of this report was led by the World Bank and prepared with experts from Deltares, AIDE Comoros, and the University of Seychelles in collaboration with the Government of the Union of the Comoros (GoC). The World Bank task team responsible for this report was composed of Pierre Guigon, Carolina Giovannelli, Carlo Palleschi, Julien Million, Ali Youssouf Alwahti, Erik Winter Reed, Laza Rakotondrasoa, Antoissi Said Ali Said, Sitti Fatouma Ahmed, and Andrianina Noro Rafamatanantsoa. The report preparation team included Sophie Vergouwen, Bas Bolman, Audrey Legat, Josien Grashof, Sonja Wanke, and Claudette Spiteri (Deltares); Ahamada Said and Hassanali Aboubacar-Tayffa (AIDE Comoros); and Jerome Harlay (University of Seychelles). Valuable contributions and support were provided by Urvashi Narain, Steve Loris Gui-Diby, Amy Chamberlain, Alex Pio, Mampionona Amboarasoa, Isabelle Celine Kane, Christophe Brière, Camille Lequette, Oznur Oguz Kuntasal, Peter Engel, David Casanova, Jaime Palalane, Chris Heymans, and Aline Maraci Lopes Saraiva Okelo. The team would also like to thank the Ministry of Agriculture, Fisheries and Environment for the guidance and technical input and, in particular, Elamine Youssouf M’bechezi (Director General of the Environment) for acting as National Focal Point. The report also benefited from advice and contributions from GoC officials and colleagues in the civil society and donor community who participated in interviews and consultation workshops (see Annex 8). The World Bank peer reviewers were Ana Bucher, Ruxandra Floroiu, Brenden Jongman, and Xavier Vincent. This report was developed under the guidance of Idah Z. Pswarayi-Riddihough (Country Director), Boubacar Sidiki Walbani (Resident Representative), Africa Eshogba Olojoba (Practice Manager), and Michel Matera (Sector Leader). 1. Executive Summary T he Comoros Islands are a small archipelago in determined contribution (NDC) further contributes to the Indian Ocean and harbor varied ecosystems laying out the way forward, focusing on strengthening rich in species diversity, endemism, and abun- the resilience of the country to the effects of climate dant natural resources. The Union of the Comoros has change. stagnating gross domestic product (GDP) per capita growth, is politically fragile, and has weak formal The development path envisioned by the GoC risks institutions. Limited economic growth has gone being hampered by natural capital degradation hand in hand with modest poverty reduction (World and depletion. The renewable natural capital of the Bank 2020k, 2021e). Approximately 44.8 percent of Comoros, including agricultural land, forests, and the population lived below the national poverty line in 2020, based on the national poverty line of 41,495 Comoros francs (KMF) (US$99) per capita per month Box 1. The Comoros Country Environmental (World Bank 2021f). Natural capital is at the basis of the country’s key economic sectors and livelihoods: Analysis (CEA) about 38 percent of its GDP is generated in activities • The CEA 2023 aims to identify the main op- for which land, sea, and nature are essential inputs, portunities for the Comoros to better manage and approximately 50 percent of the rural population its natural capital, achieve its potential sus- is dependent on agriculture and fisheries for their live- tainably, capitalize on climate co-benefits lihoods (World Bank 2020j). Agriculture is the largest stemming from the process, and advance the economic sector in the Comoros in terms of GDP con- development agenda. tribution (30.5 percent) and source of employment (34 percent). Domestic fisheries make up 2.87 percent of • This is the first CEA for Comoros and, as such, GDP and operate at the subsistence level. it constitutes an unprecedented opportunity to open avenues for effective natural resource Growth and poverty reduction in the Comoros are management, poverty reduction, and the po- strictly linked to the well-being of its natural resources. tential to boost socioeconomic development. If sustainably managed, its natural resources have the • The development of the CEA was based on a potential to trigger significant co-benefits in terms combination of literature review, secondary of poverty reduction, livelihoods contribution, eco- data analysis, stakeholder interviews, and nomic growth, and development, while supporting focus groups conducted in early 2022. The environmental conservation and climate resilience. outcomes of the CEA have been validated The Government of the Union of the Comoros (GoC) through a verification workshop with the recognized the need for such a major shift toward sus- country’s key stakeholders. tainable development and structural transformation of the economy. This translated into the adoption in 2019 • Given the lack of data on the natural capital of the Comoros Emerging Plan (PCE) 2030, a national of the Comoros, this CEA seeks to identify strategy for long-term action which describes the opportunities to strengthen the methodological focus areas and large-scale projects that will drive the soundness of natural resource management structural transformation of the emerging Comorian in the Comoros to enable evidence-based economy. The PCE 2030 also acts as a reference for decision-making and prioritization of the implementation of the Sustainable Development interventions. Goals (SDGs). The revision in 2021 of the nationally 1 | 2 |   Comoros Country Environmental Analysis fisheries, showed a per capita decline. The country’s increasing resources for environmental management, natural assets are, in fact, increasingly vulnerable and strengthening the decentralization agenda. To be and exposed to a series of stresses, causing effective, the above-presented approach would need their progressive decline and putting a strain on to be paralleled by strengthened data availability and sustainable economic development and poverty gap analyses. This is because, as indicated in this reduction. Population growth has translated into a CEA, the lack of adequate data is a key constraint for greater number of Comorians seeking livelihood the development of effective evidence-based deci- opportunities, increasing the risk for forests, sion-making and prioritization of interventions. wetlands, and wildlife habitats to be converted into agricultural lands.  Since 1960, the Comoros has experienced rapid population growth, especially concentrated in rural areas and along the coast, and Key Environmental Issues  the population was estimated to be approximately 870,000 in 2020 against 542,358 in 2000. Land degradation in Comoros is widespread The depletion of the natural capital of the Comoros and severe is also driven by the rural poor’s high dependence It is estimated that 57 percent of the arable land is in a on natural resource-based incomes. Poverty in the state of degradation, which has resulted in significant Comoros is overwhelmingly concentrated in rural socioeconomic impacts and loss of biodiversity zones, as 70 percent of the poor live in these areas and ecosystem services, such as water purification (World Bank 2017a). Rural households tend to overuse and flood control. The costs associated with land natural resources to carry out their economic activities degradation correspond to a loss of US$274 million and meet their food and energy needs. per year and a reduction of about 18 percent in the Climate change accelerates the depletion of the value of ecosystem services (Annex 2). country’s natural capital and ecosystem services, as Severe land degradation is occurring in the Comoros it alters precipitation patterns, average surface and because of overexploitation of natural resources, ocean temperatures, oxygen content, and acidity of coupled with unsustainable traditional farming seawater. The costs of climate-related impacts are esti- techniques and lack of mechanization and proper mated to reach US$836 million by 2050 (United Nations training. Land degradation is exacerbated by the Development Programme [UNDP] 2014). Because of its impacts of climate change, high density and growing geographical position, the Comoros archipelago is also population, and inadequate land governance and exposed to many natural hazards, including droughts, management. The socioeconomic complexity of the storms/cyclones, floods, earthquakes, and volcanic land tenure regime poses a significant challenge to activity. The total average annual direct losses from sustainable land management.  tropical cyclones, floods, and earthquakes are esti- mated at US$5.7 million (World Bank 2020k). Decreased land productivity caused by land degradation significantly affects agriculture, the Against this backdrop, this country environmental sector with the highest contribution to GDP and analysis (CEA) for the Comoros calls for transform- provision of jobs, and aggravates poverty and food ative change toward sustainable management of insecurity in rural areas. Land degradation also affects natural resources to achieve long-term poverty alle- the surrounding environment by increasing the viation and resilience. An integrated approach to nat- intensity of soil erosion and the consequent disruption ural resource management would play a central role of waterways. Rural populations’ subsistence in enabling maximization of the synergies between dependence on this sector for their livelihoods makes the core elements of natural capital and to gen- sustainable management simultaneously challenging erate opportunities for climate co-benefits to arise. and urgent. Whenever possible, co-management approaches would need to be adopted to increase local inclu- siveness in decision-making processes, promote The Comoros has experienced dire benefit-sharing and women’s empowerment, raise awareness, and contribute to behavioral change deforestation and forest degradation among local populations about environmental chal- Forests represent an essential source of livelihood and lenges and opportunities. In addition, this CEA food security for rural communities, offer important recommends improving the legal and institutional habitats for the country’s rich flora and fauna, and framework, enhancing institutional capacities, provide CO2 storage. Natural and planted forests Executive Summary   | 3 | currently account for 17.7 percent of the country’s total 75 percent, but the country is still far from achieving land (World Bank 2020a). Mwali National Park has safely managed standards,2 as only 65 percent of the proven to be a successful conservation tool and an population has access to drinking water supply on important income source for local populations. their premises (63 percent in rural areas, 71 percent in urban areas). While access to basic drinking water is The Comoros has experienced a decline in forest area of relatively high, access to basic sanitation services lags approximately 13,000 hectares from 1990 through 2020 behind and appears to be a neglected area for invest- because of extensive and uncontrolled deforestation, ments. Indeed, current access to sanitation services which has, in turn, contributed to land degradation equals 36 percent, which is above the Sub-Saharan (World Bank 2020b, 2021f). Deforestation and forest African average of 28 percent but far behind the world degradation are primarily caused by clearance for average of 78 percent.3 agricultural expansion, followed by wood harvesting for timber (construction), firewood for household cooking, and the operation of ylang-ylang distilleries. Vulnerable The coastal and marine ecosystems of the groups, especially women, are highly dependent on Comoros are rich but degraded, and fisheries forest resources for their livelihoods. The annual loss due to deforestation in the Comoros is estimated at are under pressure US$1.953 million (Annex 2).  The country’s coastal ecosystems harbor rich biodiversity and natural assets, including coral reefs, mangroves, and seagrass beds. These ecosystems are Despite its potential, the Comoros faces grave being degraded because of coastal erosion, pollution, water scarcity and degradation extraction of natural resources, natural disasters, and climate change. The management of coastal and Although, in theory, water is an abundant resource marine ecosystems and biodiversity is hindered by in the Comoros (World Bank 2021c), the water supply institutional limitations and a chronic lack of funding. is insufficient to meet the needs of the growing Comorian population. Water availability varies among Subsistence fishing, unsustainable fishing methods, the islands. Unlike Ngazidja, which has no surface and limited enforcement of policy are placing water bodies, Ndzuwani and Mwali can rely on the significant pressure on fisheries. Furthermore, efforts availability of seasonally variable rivers and streams to combat illegal, unreported, and unregulated for water supply, the availability of which is, however, (IUU) fishing by industrial and particularly artisanal challenged by climate-induced and anthropogenic fisheries have not been effective so far. Fisheries laws factors. Ngazidja has huge potential in groundwater and decrees are in place, but implementation and resources, which account for 90 percent of the enforcement remain key challenges. renewable water resources available on the island, but high operational costs hamper the exploitation of these resources. Rainfall varies considerably across Managing solid waste is one of the greatest and within islands because of differences in altitude ecological and social challenges for the and winds (World Bank 2021b). Water scarcity results from a combination of factors, including human Comoros activities, rising demand driven by population growth, Poor solid waste management practices in the inadequate management, climate change, and high Comoros result in the pollution of soil, water, and operational costs. Water scarcity goes hand in hand marine and coastal ecosystems, while posing high with increasing water degradation, which is mainly risks for public health and resulting in economic loss. linked with polluting human activities and poor Widespread open dumping, open burning practices, infrastructure. and waste disposal along the coasts and rivers are common in the Comoros. Urban growth increases Access to basic drinking water supply services1 in the waste production and compounds poor waste man- Comoros was at the relatively high rate of 80 percent agement characterized by insufficient waste services in 2019 and above the Sub-Saharan African average of and no safe disposal methods. Because of the growing Basic drinking water refers to drinking water from an im- 1  2 Safely managed drinking water is drinking water from an im- proved source, provided that collection time, including proved water source that is accessible on the premises, avail- queuing, is not more than 30 minutes for a roundtrip (World able when needed, and free from fecal and priority chemical Health Organization [WHO] and United Nations Children’s contamination (WHO and UNICEF , 2021). Fund [UNICEF], 2021). 3 Ibidem. | 4 |   Comoros Country Environmental Analysis population and new consumption and production pat- for environmental management. This update process terns, the current efforts of the GoC are insufficient has become necessary as the two instruments become to properly manage the increasing amount of solid outdated and prove inadequate to fully uphold the waste generated, including hazardous and hospital country’s environmental ambitions. In particular, the waste, the majority of which ends up polluting the update process has the potential to fill the legal and environment. policy gaps the country has faced over the last 30 years by including climate change, strengthening The current fragmented and decentralized institutional the environmental impact assessment system, and setting represents a major constraint for sustainable providing support for effective decentralization. waste management in the Comoros. While the institutional outline is set by the Framework Law of Despite the potential positive effects of the update the Environment, no specific legislation is in place process, the complex institutional framework of the except for that addressing plastic waste. With limited Comoros is frequently a limitation for effective envi- funding, the National Agency for Integrated Waste ronmental management and enforcement. While a Management (ANAGID) is not yet fully operational decentralization framework is in place as per the 2018 and lacks structural funding.  constitution, devolution of competencies remains incomplete, further exacerbating the disconnect between the central state and the islands and making Despites its potential, the nature-based environmental governance burdensome. Lack of ade- tourism (NBT) sector of the Comoros remains quate financial and human resources further aggra- largely untapped vates the country’s institutional fragility.  Although NBT contributes only 3.4 percent of the GDP Against this backdrop, the PCE 2030 is a cornerstone of the Comoros, the potential for development of the document for the Comoros, as it sets forth the sector is high because the country is rich in natural country’s strategic framework for the next few years. resources, such as forests and coastal and marine It lays the foundation for structural change in the ecosystems. However, development of the tourism economy through the implementation of flagship sector comes at the risk of increasing the pressures projects and structuring projects in the five pillars on freshwater resources, with infrastructural for economic growth. The plan is supported by the development and increased pollution damaging and Accelerated Growth and Sustainable Development fragmenting ecosystems (Commission Économique Strategy 2018–2021, as well as by the Blue Economy pour l’Afrique 2017). Strategic Framework.  Development of the sector is challenged by the limited competitive offer of high-quality hotels and tourism amenities, the lack of waste services and Opportunities for Change  sanitation, and inadequate and unsafe transportation infrastructure. The difficulties the Comoros is facing are The GoC is committed to addressing environmental compounded by high competition in an unfavorable challenges, including through important institutional business climate, given that neighboring countries frameworks such as the soon-to-be-updated PNE and such as Madagascar, Mauritius, and Seychelles have the FLE, which are already in place. This is reflected a stronger, more developed tourism offer. As such, it through PCE 2030, which aims to achieve strong, would be fundamental for the Comoros to carry out inclusive, and equitable growth of the emerging an ex ante analysis to assess the effective potential of economy without compromising natural resources developing an NBT sector in the country. and the environment. The World Bank’s FY20-FY24 Country Partnership Framework for the Union of Comoros is aligned with these strategic efforts and seeks to aid in their implementation by mobilizing Environmental Governance and resources, carrying out policy reforms, and enhancing Institutional Framework  institutional capacity building.  The Comoros recently stepped up its commitment to When implementing the recommendations spelled upscale its environmental policies and laws, launching out in this CEA, it is pivotal to acknowledge the the update process of the National Environmental interactions between the core elements of natural Policy (PNE) and the Framework Law of the capital and avoid considering environmental sectors Environment (FLE), the country’s two key instruments in isolation from one another. A landscape approach Executive Summary   | 5 | for the integrated management of land, forestry, pollution, water supply, and IUU fishing. Couple and water resources is needed, while also moving enforcement with a co-management approach that toward sustainable and integrated management of involves and empowers local communities in the fisheries and marine and coastal resources, as well management of natural resources and livelihoods. as an integrated waste management framework. • Ensure that the environmental implications of Furthermore, the country would benefit from projects and actions are taken into account by preliminary opportunity assessments of NBT to the GoC before decisions are made. Enhance evaluate if the sector has the potential for being a the technical capacity of institutions to evaluate growth driver and pro-poor tool. In addition, the the socioenvironmental impacts of a proposed development and implementation of successful project or development plans, taking into account sustainable natural resource management in the beneficial and adverse socioeconomic and country will hinge on improving institutional and human-health impacts. In particular, updating coordination capacities, ensuring that institutions are the environmental impact assessment (EIA) sufficiently resourced. regulatory framework and management system While the set of recommendations put forth is recommended. Develop and strengthen the may require medium- to long-term structural institutional capacity for implementation of the transformations, concrete actions following a phased Strategic Environmental and Social Assessment approach can be undertaken in the short term as (SESA) to ensure that environmental and social a foundation for this medium-long-term vision. In implications are adequately taken into account in particular, the waste management and water sectors the process of elaborating plans and strategies in would need to be prioritized in the shortest term, support of sustainable development.  as they represent the two most pressing issues for the Comoros, while also being apt at delivering immediate benefits for livelihoods, the economy, Recommendation 2: Promote sustainable land, and the country’s natural resource base.4 In addition, forest, and water management the Comoros could leverage lessons learned from • Adopt an integrated landscape approach to successful programs and pilots being implemented optimize synergies and promote sustainable use or recently concluded in the country by replicating and conservation in an equitable manner. The and scaling them up while paving the way for lasting approach would enable the country to maximize changes in natural asset management. productivity, improve livelihoods, and reduce negative environmental impacts, while providing Recommendation 1: Strengthen environmental an opportunity to generate significant climate co-benefits and and foster synergies between governance and support institutional capacity mitigation and adaptation in the country. • Strengthen the capacity of general and regional directorates to fulfill their mandate by mobilizing • Develop and implement land-use plans for Ngazidja human, technical, and financial resources. Develop and Ndzuwani to protect the natural forest targeted continuous professional development resources and promote climate-smart agriculture programs for technical staff at different levels, as well (CSA) such as agroforestry and reforestation. as capacity building for other stakeholders. Carry out Apply a zoning approach to identify the usage for a human resource needs assessment to ascertain different zones, including agriculture, agroforestry, the specific level of support needed at the national protected dry forests, and natural forests in and regional levels for the directorates to carry out National Parks. Combine this strategy with an their functions and increase service delivery. integrated landscape approach to ensure that all activities in the area work in complementarity and • Boost law enforcement capacity coupled with that each specific zone is used for its intended targeted livelihood support and community purpose.  empowerment programs. Specifically strengthen enforcement capacity concerning key environmental • Promote reforestation and soil fertility and challenges such as overexploitation, deforestation, strengthen climate-resilient integrated water resource management. Conduct reforestation by planting native trees that offer economic benefits 4 I n line with this prioritization approach, two policy notes ad- dressing the water and waste sectors have been developed and opportunities to diversify incomes for local as part of the CEA. communities.  | 6 |   Comoros Country Environmental Analysis • Protect terrestrial, coastal, and marine ecosystems and financial assistance from Indian Ocean and biodiversity by officially operationalizing the Commission (IOC)-United Nations Educational, two additional terrestrial national parks.  Scientific and Cultural Organization (UNESCO) beginning in November 2021. • Upscale the simplification and decentralization of the land tenure regime to enhance legal certainty • Promote the protection and restoration of and strengthen social cohesion while ensuring mangroves, seagrass, and coral reefs. Assess transparency. their potential to function as a nature-based flood defense. Base projects on co-management • Strengthen the sustainable and climate-resilient principles; as part of this approach, include capacity agriculture capabilities of the rural population. building on sustainable fishing practices to reduce Establish a climate-resilient agriculture plan and pressures on coastal and marine ecosystems. develop a sustainable irrigation strategy. Integrate Strengthen financial support for the creation of the climate-smart training for farmers to increase the three marine national parks. sector’s resilience against the effects of climate change and improve yields and soil fertility. • Support watershed protection and restauration. Recommendation 4: Invest in Integrated Solid Watershed protection and restauration have the Waste Management (ISWM) potential to be among the more effective solutions to increase climate resilience and improve the • Develop a comprehensive strategy for ISWM, well-being of ecosystems, while also facilitating considering interventions in waste prevention, efforts to meet the increasing demand for water collection, disposal, and waste recycling. An for drinking and environmental and agricultural implementation roadmap should be prepared uses. for infrastructural development, taking into ac- count the implementation capacities of national, • Improve drinking water quality and higher sani- regional, and local governments and societal tation standards. scale-up Water, Sanitation, and parties. Hygiene (WASH) programs and increase invest- ments in sanitation infrastructure in both rural and • Invest in services and infrastructure capable of en- urban areas. suring adequate waste collection, recycling, and disposal. Expand and enhance waste collection services to households that are not yet covered, Recommendation 3: Promote sustainable fisheries minimize collection losses, and increase volun- and integrated marine and coastal management tary, community-based collection points, including those for recyclable materials. Provide the country • Support the development of a sustainable fish- with final waste storage sites meeting environ- eries strategy. Ensure consistency among fish- mental norms and standards. eries decrees and address key challenges such as IUU fishing, international/regional cooperation, • Improve the institutional and legislative and co-management of coastal and marine re- framework. Update the sector legislation, provide sources. Include a fisheries management plan in ANAGID with the required funding, strengthen the strategy, where science and research on the the technical and institutional capacities of all status of fish stocks feed into an informed deci- stakeholders at each tier of government, and sion-making process. include adequate provision and mechanisms to enable them to develop. • Sustainably protect and manage coastal zones and reduce the impacts of climate change. Develop • Reduce the generation of solid waste, incen- an integrated coastal management plan and blue tivize design for reuse, use alternative materials, economy roadmap and support the Marine Spatial and increase opportunities to establish a circular Plan in one integrated process. The Post-Kenneth economy approach. Carry out a life-cycle assess- Project (see Box 4) could form the foundation ment of the most problematic waste products, par- for the next interventions. Identify management ticularly those with higher potential for reuse and objectives, measures, actions, and opportunities recycling, followed by a feasibility study for policy for coastal risk management. Support and and regulatory options to increase circularity (for integrate the Marine Spatial Plan initiated by the example, market-based instruments to restrict, sub- General Commission for Planning with technical stitute, or incentivize reuse of plastic items).  Executive Summary   | 7 | • Improve data collection and analysis. To develop to expand the country’s protected areas and en- effective and sustainable ISWM policies, it is cru- sure their sustainable management and financial cial for the GoC to conduct in-depth, sound studies sustainability.  on cost recovery and sustainability aspects, as well as to quantify the environmental and public health • Ensure participatory approaches in decision- footprint of waste in both rural and urban areas. making processes, scale co-management op- Assessment of the potential impact of tourism- portunities, and ensure the establishment of sector development on waste management in benefit-sharing mechanisms with local com- the country is also essential. Implementing such munities. For the benefits deriving from the de- studies would be instrumental for the Comoros to velopment of the NBT sector to trickle down to close the gap and inform decision-making across local populations, participatory approaches and all aspects of ISWM. co-management mechanisms will be essential; in turn, these might support behavioral change rec- • Raise awareness about waste-related risks and ognizing the value of environmental conserva- opportunities, in particular the prevention of solid tion. Successful co-management pilots in Mwali waste generation and sorting at source. Adequate National Park could be replicated. Awareness communication campaigns, awareness-raising raising and capacity building are equally impor- events, and capacity building should be planned tant to ensure proper understanding and incen- to promote behavioral change by all stakeholders tivize participation. involved. • Monitor biodiversity and ecosystems in protected areas, and plan NBT development according to the carrying capacity of each Recommendation 5: Promote nature-based island. Evidence-based information on tourism, tourism the status of biodiversity and ecosystems, and • Develop upstream opportunity assessments and island-specific carrying capacity will inform demand analyses to close the data gap and clarify policy development, improve tourist services, a realistic market space for NBT in the Comoros. assist local communities effectively, and ensure Filling this data gap would be a prerequisite to the proper conservation of the natural capital of the development of strategies and plans. This should Comoros. include updating the 2013 Comoros Tourism Sector • Finalize and adopt the draft Sustainable Tourism Review to provide evidence-based understanding Master Plan, the National Tourism Strategy of the Comoros NBT sector’s effective potential as a report, and the Strategic Plan 2019–2025 and growth driver for the country. ensure alignment with the PCE 2030. This • Value protected areas not only as a conservation exercise will ensure a solid basis for the achieve- tool but also as a livelihood support asset and po- ment of any NBT sector targets in a sustainable tential engine of growth through NBT opportun- fashion. ities. To achieve this goal, it would be fundamental 2. Introduction volcanic soil and the altitudinal gradient create favor- 2.1. The Comoros at a Glance able microclimates for agriculture. The Union of the Comoros (henceforth “the The Comoros is characterized by dense vegeta- Comoros”) is a small island developing state con- tion with varied ecosystems rich in species diver- sisting of an archipelago located at the northern sity, endemism, and abundant natural resources. entrance of the Mozambique Channel in the Indian Ecosystems include mangroves, seagrass beds, Ocean. The Comoros Islands are made up of Ngazidja, coral reefs along the coast, savanna shrubs and for- Mwali, and Ndzuwani (see Table 1 for key character- ests on land, and wetland ecosystems. The Comoros istics), as well as Maore, which currently falls under harbors many emblematic, threatened, or migratory French administration and is not covered in this study, species, such as sea turtles, whales, dolphins, lemur, and many smaller islands. The total land surface is dugong, and sea cucumbers. 1,860 square kilometers, surrounded by an exclusive economic zone (EEZ) of 160,000 square kilometers, The country has a tropical marine climate with two which is approximately 86 times the size of the land seasons. The rainy season extends from November to area (Figure 1). The islands have volcanic origins with April and is characterized by hot and humid weather. high topographic relief characterized by drastic alti- The dry season lasts from June to October and brings tudinal changes ranging from low-lying coastal areas lower humidity and relatively lower temperatures. to elevations higher than 2,000 meters. The fertile The Comoros experiences a hydro-climatic seesaw Figure 1.   Map of the Comoros Islands. Ndzodali 0 10 20 km Mwali Ngazidja 0 5 10 km 0 5 10 15 km 0 50 100 km Source:  World Bank 2021c. 9 | 10 |   Comoros Country Environmental Analysis effect that oscillates between recurrent water scar- 2021e). Approximately 44.8 percent of the population city in the dry season and heavy rainfall and floods lived below the national poverty line in 2020, using in the humid season. It is highly vulnerable to climate the national poverty line of KMF 41,495 (US$99) per change and natural hazards, such as droughts, trop- capita per month (World Bank 2021f). With a Human ical cyclones, earthquakes, floods, landslides, and Development Index (HDI) score of 0.555, the Comoros tidal waves. ranked 156 out of 189 countries (United Nations Development Programme [UNDP]  2020). Since its independence, the Comoros has experi- enced recurring political instability, underpinned by Economic inequality is relatively low in the Comoros the weakness of formal institutions and the lack of a (World Bank 2021f). The richest 10 percent account strong sense of national unity. The decentralization for 26.1 percent of the total consumption expenditure process rolled out as envisioned under the 2018 con- of the population, more than the bottom 40 percent stitution is still incomplete, further exacerbating the who account for 20.4 percent of the total consump- disconnect between the central state and the islands. tion expenditure. This inequality is driven mostly by The Comoros is currently classified by the World inequalities within urban and rural areas, as well as Bank as a state with high institutional and social within each of the islands, rather than between geo- fragility. graphical locations. Although the population of the Comoros has increased steadily since 1960, reaching approximately 870,000 in 2020 (World Bank 2020c), with growth seen 2.2. Importance of Natural Capital for especially in rural areas, the country has yet to reap the Comoros the demographic dividend. The Comoros is still in the early stages of urbanization, with only 30 percent of Natural capital is at the center of livelihoods and is the population living in urban areas. A growing pop- the basis for key Comoros economic sectors, such ulation and the high population density contribute to as agriculture, fisheries, and nature-based tourism the pressure on the environment and wealth of the (NBT). Approximately 38 percent of the GDP of Comoros. the Comoros is generated in activities for which land, sea, and nature are important inputs, and Although Comorian society is matrilineal, with women approximately 50 percent of the rural population playing an important role in terms of asset ownership, is dependent on agriculture and fisheries for gender inequality in the Comoros is entrenched. This their livelihood (World Bank 2020j). In particular, results in low education outcomes for women and agriculture and fisheries account respectively for 30.5 underrepresentation of females in all spheres of polit- percent and 2.87 percent of GDP (World Bank 2020k). ical and socioeconomic activity, among other effects. With the majority of the population living along the coast, the Comoros is highly dependent on small- The country’s Gross Domestic Product (GDP) has scale fisheries for food security and nutrition. While been growing at approximately 2.8 percent annually relatively small in terms of economic contribution for the last 10 years (World Bank 2020c), although (3.4 percent of GDP), NBT has great potential but is GDP per capita has been stalling due to population largely untapped (World Bank 2020I). The Comoros growth (Figure 2) (World Bank 2017a). GDP declined is also rich in natural and planted forests, which in 2020, affected by the COVID-19 pandemic as well currently account for 17.7 percent of the total land as cyclone Kenneth in 2019. Unemployment levels (World Bank 2020a) and are important habitats for are relatively high at approximately 9.4 percent biodiversity and for CO2 storage for the Comoros. (World Bank 2021a5). This is specifically the case They represent an essential source of livelihood and with the younger population: in 2014, one in two food security for rural communities and have the young Comorians of working age were unemployed, potential to contribute more significantly to GDP if and only 3 percent were employed in the formal sustainably managed. Although, in theory, water is sector (World Bank Country Partnership Framework an abundant resource in the Comoros, current levels [CPF] 2020). of water supply are insufficient to meet the needs of the growing Comorian population because of low Weak economic growth has gone hand in hand watershed storage capacity, land degradation, and with modest poverty reduction (World Bank 2020k, limited investments in green infrastructure. 5 World Bank, 2021. Comoros Unemployment, total (% of total labor force). Available at: https://data.worldbank.org/ The natural assets of the Comoros are increasingly indicator/SL.UEM.TOTL.ZS?locations=KM vulnerable and exposed to multiple stressors, such Introduction  | 11 | Table 1.  Key characteristics of the main islands of Comoros (Source: stakeholder consultations unless otherwise stated) Ngazidja Mwali Ndzuwani Population density 330.46 inhabitants/km2 (projection) (INSEED 192.45 inhabitants/ km2 (projection) (INSEED 835.77 inhabitants/km2 (projection) 2021) 2021) (INSEED 2021) Significant emigration to France  The least densely populated island One of the highest density popula- High immigration of citizens from the other tions in the world islands (mainly from Ndzuwani) Significant emigration to other islands including Mayotte Physical and natural Geologically youngest island Geologically oldest island Most mountainous island characteristics Active volcano (high risk of disaster in case of an Clayey and very fertile soils Very limited agricultural land eruption, geothermal potential, etc.) The most natural island (whole island is a Presence of permanent rivers Very porous basalt soils United Nations Educational, Scientific and 80 percent of coastline covered by Home to largest natural forest in the country Cultural Organization [UNESCO] biosphere coral reefs reserve) Absence of surface water Presence of permanent rivers Availability of crushing materials Quite rare crushing materials 60 percent of coastline covered by coral reefs 100 percent of coastline covered by coral reefs Key economic sectors Agriculture/vanilla production/vegetables Subsistence agriculture/clove production/ Agriculture: ylang-ylang and clove Fisheries, including tuna fishing strong increase of ylang-ylang cultivation production/milk production Trade Reef fish fishing Tuna fishing Active business initiatives Key environmental Pollution/solid waste management Deforestation Deforestation challenges Deforestation Mining of coastal materials Land erosion Extraction of gravel for construction Land erosion Drying up of rivers Coastal and marine ecosystem degradation Solid waste management (coral reef, seagrass, mangrove forests) Very strong pressure on the land Drying up of rivers Social organization Significant power of notables Local associations very proactive Local associations very proactive Strong participation of diaspora in the realization Participation of diaspora in the realization of Participation of diaspora in the real- of community projects community projects ization of community projects Local associations very proactive as population growth and density, high dependency climate change. The contribution of NBT to growth of the rural poor on the country’s natural resources, and development is also limited due to the lack of climate change, and natural disasters. The combined adequate infrastructure, including waste management, impact of these factors drives the Comoros’ declining sanitation, and freshwater supply systems. These natural capital and triggers major environmental limitations of the Comoros are visible, for instance, challenges that need to be addressed to invert the along the coastlines, where large amounts of debris trend and release its considerable socioeconomic collect on beaches and in the reefs. During the past potential. decades, the Comoros also experienced severe deforestation and forest degradation, as evident in the Despite traditionally being one of the main drivers 20 percent decline in forest natural capital per capita of growth in the Comoros, agriculture and fisheries between 1990 and 2020. suffer low productivity. Agricultural productivity is hampered by unsustainable land uses, outdated If sustainably managed, the natural resource base farming practices, natural disasters, climate change, of the Comoros could become an engine for growth and hydro-climatic risks. The socioeconomic potential and poverty reduction. Improving the management of fisheries has yet to be realized sustainably, given the and utilization of the country’s rich natural capital many challenges including unsustainable practices; will underpin environmental conservation while illegal, unreported, and unregulated (IUU) fishing; the supporting poverty reduction, the livelihoods of rural lack of governance and enforcement of policies; and communities depending on natural assets, and growth | 12 |   Comoros Country Environmental Analysis Figure 2.   GDP (blue bars) and GDP per capita (orange line) in the Comoros from 2008 to 2020. GDP 1400 1600 1200 1400 GDP per capita (USD) 1200 GDP (million USD) 1000 1000 800 800 600 600 400 400 200 200 0 0 Sources:  World Bank 2020d, 2020c. and development in key sectors of the economy. It The objective of the Comoros CEA is to provide a also opens opportunities for generating significant critical review of the country’s natural resources and climate co-benefits and enhanced climate resilience, associated challenges, as well as their potential role ultimately contributing to structural transformation for poverty alleviation and sustainable development and sustainable development. Healthy ecosystems if properly managed. The CEA identifies and could become a source of socioeconomic well- describes the status of the key natural assets and being and a way out of poverty and unemployment, their contribution to the country’s wealth, economic especially for young Comorians, as they create a growth, and livelihoods. It explores the costs of potential asset for the enhancement of economic environmental degradation, providing the basis for growth if combined with education and employment policy dialogue on the economic and social costs of diversification opportunities (World Bank 2020j). nonaction. In addition, it assesses and identifies the gaps in institutional capacity for environmental and natural resource management. It also analyzes the specific challenges for each key environmental sector. 2.3. A Country Environmental Analysis Finally, the CEA makes recommendations on critical for the Comoros interventions required to protect the country’s natural assets and open the pathway toward sustainable, Against this backdrop of cumulative pressures resilient development, by helping define and prioritize on  the country’s natural capital, the Government donor support that can strengthen natural resource of the Union of the Comoros (GoC) has recognized management in the country. Given that this is the first the need for a major shift toward sustainable CEA for the Comoros, it constitutes an unprecedented development and structural transformation of the opportunity to open avenues for effective natural economy, as stated in the Comoros Emerging Plan resource management, simultaneously boosting the (PCE) 2030. The World Bank aims to support the GoC potential for socioeconomic development. along this path, in line with the 2020–2024 Country Partnership Framework (CPF) and the Systematic Country Diagnostic (SCD). Methodology The Comoros CEA is situated within the context of The Comoros CEA was developed based on a that framework. The CEA is a World Bank country-level literature review, secondary data analysis, stakeholder diagnostic tool designed to close the gap between interviews, and focus groups conducted in early 2022. environmental sustainability and socioeconomic The outcomes of the CEA were validated through development. a verification workshop with the country’s key Introduction  | 13 | stakeholders (see stakeholder list, Annex 8). Given challenges of the Comoros, and the key strategic the lack of available and updated data on the natural documents for sustainable development adopted capital of the Comoros, this CEA seeks to identify to date. opportunities to strengthen the methodological soundness of natural resource management in Chapter 5: Key Environmental Sectors. This chapter the Comoros, to inform effective, evidence-based provides a comprehensive analysis of the most decision-making and prioritization of interventions. important environmental sectors of the Comoros, from land, forests, and water to the coastal and marine sectors, including NBT and waste Structure of the CEA management. It also assesses the key challenges and This CEA is structured into four chapters (chapters makes associated recommendations for sustainable, 3–6), followed by a final chapter with conclusions resilient development. (chapter 7) (Figure 3): Chapter 6: Looking Ahead. This chapter puts forward Chapter 3: The Decline in Natural Capital. This chapter the cross-sectoral opportunities for change that describes the natural capital of the country and the enhance sustainable, resilient development in the main drivers of degradation and decline in natural Comoros. It also describes the enabling conditions to capital. It provides the rationale for the need to achieve this path. protect natural capital and, consequently, to boost the Chapter 7: Conclusions. This chapter summarizes the country’s prospects for sustainable development. main results and recommendations of the Comoros Chapter 4: Environmental Governance and CEA. It identifies concrete opportunities that could be Institutional Framework. This chapter describes leveraged in the short term to help steer the Comoros the key environmental policies and environmental toward a  sustainable, inclusive, and climate-resilient legislation, the institutional setting and governance development path.  Figure 3.   Structure of the Comoros CEA. KEY DRIVERS OF CHANGE eNVIRONMENTAL SECTORS KEY CHALLENGES Chapter 5 Chapter 3 Chapter 5 LAND Natural ST FORE WATER Capital NA TU RE-BA S T is in decline GEM EN Chapter 4 Chapter 3 ANA ED CO I N E ST TO EM RIS AST A N D M A R WA U M Chapter 6 OPPORTUNITIES FOR CHANGE INTEGRATED WASTE MANAGEMENT SUSTAINABLE LAND & NATURE-BASED WATER MANAGEMENT TOURISM ENVIRONMENTAL GOVERNANCE & INSTITUTIONAL CAPACITY ENABLING CONDITIONS 3. The Decline in Natural Capital T he main challenge for the Comoros is to achieve strong, inclusive, and equitable growth without 3.1. Natural Capital compromising natural resources and the envi- As for many other lower- and middle-income countries, ronment. To lay out the way forward, which is the the Comoros is dependent on natural capital for its main objective of this CEA, it is critical to look at the wealth, meaning that the economy is still largely wealth of the Comoros and fully assess the main chal- based on the primary sector. Natural capital accounts lenges and opportunities along the pathway toward for approximately 8 percent of the country’s total sustainable development (Box 2). However, the gross wealth (World Bank 2021d) (Figure 6). This percentage domestic product (GDP) of the Comoros can provide is relatively low compared to its peer countries; for only a partial picture of the health of the country’s example, the share of renewable natural resources of economy over the long term and is unable to capture Madagascar, Mozambique, Tanzania, and Kenya are the sustainability aspects of growth. A closer look at 30 percent, 42 percent, 20 percent, and 16 percent, the country’s natural capital, in contrast, highlights a respectively (Box 3). The main share of the country’s more concerning picture of a decline in natural cap- renewable natural capital comes from agricultural ital per capita. An in-depth analysis of the drivers of land. Therefore, an increase in the productivity of this decline can ensure that economic and political the Comoros agriculture sector could enable the decision-making adequately incorporate an assess- population to diversify away from subsistence ment of how growth and development trajectories are agriculture, alleviating rural poverty and creating affecting and being affected by natural capital, both opportunities for the development of other economic currently and in the future. sectors such as tourism. Other natural assets such as forests, fisheries, biodiversity, and mangroves all have This chapter presents the natural capital of the the potential to contribute to the livelihoods and well- Comoros, describes the trend of decline in natural being of the population, particularly the rural poor (see capital, and identifies the main drivers of the decline, chapter 5). This is both through the economic potential namely a growing population and density, high they offer (for example, potential contribution to dependency of the rural poor on natural assets, and nature-based tourism in the Comoros), as well as climate change and natural disasters. Finally, it makes through the ecosystem services they provide that the case for sustainable development by addressing contribute to well-being (for example, stabilization of the costs of environmental degradation and the the shoreline and uptake of CO2). This highlights the benefits of environmental restoration. importance of sustainable management of the natural KEY DRIVERS OF CHANGE eNVIRONMENTAL SECTORS capital of the Comoros to ensure long-term economic growth. LAND The renewable natural capital of the Comoros, including agricultural land, forests, and fisheries, has shown a Natural ST FORE decline per capita. These renewable assets are directly WATER Capital N ATU RE-BAS linked to the country’s most important economic sec- EMENT is in decline tors. Growth in GDP , coupled with demographic expan- Chapter 3 NAG sion and decline in natural capital per capita, seem to ED MA CO INE S TO RIS AST A indicate that in the long run, the natural capital stock N D M A R WA TE U M may not keep up with the rate of use. In addition, urban 15 | 16 |   Comoros Country Environmental Analysis Box 2. The Wealth of Nations and the Wealth of capture the value of natural assets in generating the Comoros income and supporting human well-being. Why look at wealth? Wealth in the Comoros To assess and design sustainable development paths, it is essential to go beyond the traditional Total wealth of the Comoros has shown an increase focus on GDP and analyze wealth, namely the over time, whereas total wealth per capita has been stock of natural and human capital and net for- declining. The increase in total wealth was mainly eign assets (Figure 4). Although GDP provides an driven by an increase in human capital. Human capital important measure of economic progress, it meas- is considered to be the most important component of ures only income and production and does not global wealth, as it indicates estimated earnings in a reflect changes in the underlying asset base. GDP lifetime (World Bank 2021d). This increase in human says nothing about a country’s natural capital. For capital indicates a shift toward the services sector, instance, GDP could show double-digit growth where earnings are higher.The decrease in wealth per without indicating whether natural assets have capita, a leading measure of long-term sustainability, been depleting, whether investment and accumu- is most clearly illustrated by a reduction in produced lation of wealth are keeping pace with population capital because of population growth (Figure 5) or growth, or whether the mix of assets is consistent deterioration of materials. The decline in produced with a country’s development goals. For this reason, capital per capita indicates that machinery, equipment, this CEA has opted to look at the Comoros’ devel- and structures require additional investments to keep opment path through the lens of wealth, to fully up with the growing population. The assets and capital that drive wealth and underpin economic and sustainable development (based on the   Figure 4. Kenya and Malawi CEAs and the World Bank’s Changing Wealth of Nations. Sustainable Development GDP Total Wealth Non- Produced Capital renewable natural Renewable Natural Capital Human Capital Net Foreign Assets capital Knowledge Machinery Skills & Equipment Urban Land Fossil fuels, minerals Mangroves Agriculture Forests Protected Fisheries Experience in Assets - Liabilities Structures land Areas Workforce. Gender Source:  World Bank 2021d. Figure 5.  Total wealth and GDP of the Comoros (left) and wealth per capital by contributor (right) from 1995 to 2018. 20 1.5 25 20 15 GDP 1 15 10 10 5 Nonrenewable 5 5 Renewable Human capital Produced capital 0 0 0 Net foreign assets 1995 2000 2005 2010 2015 2018 1995 2000 2005 2010 2015 2018 Note: This figure uses CWON 2021 estimates which are based on readily available global datasets and may deviate Total wealth GDP (right y-axis) from actual country data. Please visit www.worldbank.org/cwon for methodology and background materials. Source:  World Bank 2021d. The Decline in Natural Capital   | 17 | Figure 6.  Distribution of per capita wealth in the Comoros. Wealth per Capita DistribuƟon in Comoros Forests Fisheries 1.8% 1.3% Produced capital 38.8% Protected areas Renewable 0.5% natural capital; Mangroves 8.3% 0.4% Human capital 52.9% Agricultural land 4.4% Source:  World Bank 2021f. land is becoming more densely populated, giving rise are degraded to production forests with implications to environmental pollution because of the limited for species diversity as well as ecosystem functioning. wastewater and solid waste infrastructure. A more detailed evaluation of changes in the renew- able natural capital of the Comoros shows that the 3.2. Main Drivers of Decline in Natural general decrease is mainly caused by a significant Capital drop in the value of cropland per capita(Figure 7) (see section 5.1 for a detailed analysis of land degradation Growing Population and Density, and its drivers). This decline in the value of cropland per capita is due to an increase in population size and and Urbanization land degradation since the natural capital total value Population growth, concentrated in rural areas and of cropland itself remained stable and the decrease underpinned by lack of governance and investments, is is only visible in wealth per capita. Nontimber forest, one of the main drivers of the decline in the Comoros’ which offers ecosystem services such as minor forest natural capital. About 88 percent of Comorians live products, hunting, recreation, and watershed protec- along the coastline (World Bank 2021c) and about 70 tion, is decreasing at the expense of forest land used percent in rural areas. Since 1960, the Comoros has for timber. This indicates that rather than increasing experienced rapid growth, especially concentrated in productivity in existing timber forests, natural forests rural areas and along the coast, and the population Figure 7.  Changes in wealth from renewable natural capital per capita in the Comoros from 1995 to 2018. Value of Renewable Natural Capital per Capita 1200 Wealth per capita (2018 USD) 1000 800 600 400 200 0 Forest Protected areas Cropland Pastureland 1995 2018 Source:  World Bank 2021d. | 18 |   Comoros Country Environmental Analysis estimated at approximately 870,000 in 2020 compared networks are often lacking (World Bank 2021c). As to 542,358 in 2000 (Figure 9). Population growth a result, pressures on the environment continue has translated into a greater number of Comorians to surge, and a parallel increase is occurring in the seeking livelihood opportunities, increasing the likelihood of disease spread across the population. risk for forests, wetlands, and wildlife habitats to be converted into agricultural lands. The impact of these demographic trends on the Comoros’ natural capital High Dependency of Rural Poor on Natural has been further exacerbated by the lack of adequate governance, management, and enforcement of the Assets implementation of environmental legislation (see The depletion of the Comoros’ natural capital is chapter 4). also driven by the rural poor’s high dependence on natural-resource-based incomes. In fact, poverty in Although the country is in the early stages of the Comoros is overwhelmingly concentrated in rural urbanization, cities have a pivotal role to play in areas (70 percent of the poor) (World Bank 2017a), addressing the main ecological and development where households tend to overuse natural resources challenges. This is especially true given that most to carry out their economic activities and meet their of the population lives within 20 kilometers of a city food and energy needs. Indeed, the average person because of the small size of the islands (World Bank living in poverty in the Comoros lives off subsistence 2021c). The Comoros Emerging Plan (PCE) 2030 aligns agriculture and artisanal fishing rather than commerce to this vision, acknowledging the potential of cities and services, putting additional pressure on the in driving economic growth without compromising natural assets on which they depend. natural resources and the environment. Despite representing an opportunity, the urbanization process Rural poverty affects but is also affected by the decline has been taking place in an unmanaged way because of the Comoros’ natural capital. The unsustainable of a lack of urban planning, inadequate funds, and use of natural resources risks triggering a vicious low institutional capacity. As such, cities are not cycle of declining livelihoods, increased ecological equipped with the necessary waste management, degradation, and loss of natural resources, further water, and health facilities to meet the needs of the exacerbating poverty in the country. Rural households growing population. Given the limited availability are generally worse off because of bigger family sizes, and higher costs of residential land in the capital, 56 fewer assets, limited access to employment, and percent of migrants have set up in vulnerable urban lower access to infrastructure and basic services— settlements, where land is leased to them informally compounding pressures on natural assets and, in turn, and connections to electricity, water, or sanitation on their own livelihoods. The depletion of ecosystem Box 3. The Wealth of the Comoros Compared to proximity: Seychelles (high income), Madagascar the Wealth of Other Countries (low income), Mozambique (low income), Tanzania (low income), and Kenya (lower-middle income). The wealth gap between low-income and high- Except in Kenya, the total wealth per capita is higher income countries is increasing. Although national in the Comoros than in the other countries, attrib- total wealth increased in all 146 countries assessed uted to higher produced capital and human cap- in Changing Wealth of Nations, 22 countries ital. However, with the exception of Seychelles, the saw a decline or stagnation in per capita wealth Comoros scored lower on natural capital, mainly (World Bank 2021d). Even compared to countries due to lower scores of forests, cropland, and pas- in the same income group and other countries in tureland, and higher per capita wealth with regard sub-Saharan Africa, the Comoros scored low in total to mangroves and fisheries. Sustainably increasing wealth per capita (Figure 8). This can be explained the productivity of the sectors depending on nat- by the small size of the Comoros, combined with ural capital could help the Comoros increase its a high population density that is dependent on wealth. Furthermore, preservation of the existing current capital. natural capital is required to benefit both the devel- oping economic sectors, such as tourism, as well Table 2 compares the Comoros (lower-middle as current livelihoods. This will ultimately lead to income) to several peer countries based on increasing total wealth. The Decline in Natural Capital   | 19 | Change in total wealth per capital in the lower middle-income countries, Sub-Saharan Africa, and the Comoros   Figure 8. from 1995 to 2018. 30 Constant thousand 2018 US$ Lower middle income 25 Sub-Saharan Africa 20 Comoros 15 1995 2000 2005 2010 2015 2018 Source:  World Bank 2021d. Table 2.  Comparison of per capita wealth in 2018, constant 2018 US$. Comoros Seychelles Madagascar Mozambique Tanzania Kenya Total wealth 18,698 - 8,375 6,505 15,378 22,055 Produced capital 7,276 9,307 1,461 1,354 3,314 3,566 Human capital 9,932 - 4,647 3,551 9,365 15,260 Natural capital 1,567 873 2,538 3,388 3,238 3,618 Renewable natural resources 1,567 873 2,522 2,700 3,118 3,617 Forests, timber 213 39 855 1,046 782 808 Forests, nontimber 117 5 356 447 471 91 Mangroves 78 549 16 15 5 10 Fisheries 243 184 16 15 6 6 Protected areas 95 71 52 57 492 464 Cropland 603 23 632 972 1,010 833 Pastureland 219 2 595 147 352 1,406 Source:  World Bank 2021d. services coupled with worsening living conditions (Bourgoin et al., 2016). The costs of climate-related in rural areas also contributes to the intensification impacts were estimated to reach US$836 million of the rural-urban migration, further increasing the by 2050 (UNDP 2014), equivalent to an average cost pressure on the environment. Moroni receives most of US$23 million per year for the same period and of the influx, and an estimated 78 percent of the city’s representing 1.9 percent of the GDP in 2019 (Ministère population growth stems from internal migration de l’Agriculture, de la Pêche, de l’Environnement, du (World Bank 2021c). Tourisme et de l’Artisanat [MAPETA] 2021a). While this is described in more detail throughout the report in the relevant subsections, an overview of key impacts Climate Change and Natural Disasters is provided here. Climate change accelerates the depletion of the Droughts pose a significant threat to the Comorian Comoros’ natural capital and ecosystem services, population and natural resources, in light of changes as it alters precipitation patterns, average surface in precipitation patterns and warming. Indeed, the and ocean temperatures, oxygen content, and the rainy season has become more irregular and has acidity of seawater. These trends jeopardize the shortened in duration from six months to approx- country’s economy, livelihoods, and natural resource- imately three months per year, while the average based sectors, while hampering poverty alleviation annual temperature has increased by 0.9°C (Figure 10) | 20 |   Comoros Country Environmental Analysis Figure 9.  Urban (blue bar) and rural (orange bar) population size and density in the Comoros from 1960 to 2020. PopulaƟon density (people per km2) 1000000 500 900000 450 800000 400 700000 350 PopulaƟon size 600000 300 500000 250 400000 200 300000 150 200000 100 100000 50 0 0 1960 1964 1968 1972 1976 1980 1984 1988 1992 1996 2000 2004 2008 2012 2016 2020 Sources:  World Bank 2020h, 2020m, 2020g. and is projected to increase by an additional 0.8 °C to the Comorian population. Indeed, floods account (Representative Concentration Pathway [RCP] 2.6) to for direct annual losses of approximately US$2.0 2.1 °C (RCP 8.5) by 2060 (MAPETA 2021a) (Figure 11). million and indirect emergency costs of US$460,000. Prolonged drought observed in the late 1990s and early Ndzuwani experiences the greatest risk for flood loss 2000s (World Bank 2021c) led to water shortages and and has an average annual loss of US$1.3 million affected the hydrographic network. For instance, sev- (World Bank 2016a). eral rivers on Ndzuwani, the primary water supply for the island, dried up (Bourgoin et al., 2016). Droughts Since 1993, sea level has risen between 1 millimeter continue to represent a threat for agriculture and food and 6 millimeters per year and is expected to further production (World Bank 2021b), although costs are increase by 4 millimeters annually (World Bank 2020k), probably underreported, as drought monitoring and resulting in growing coastal erosion (Figure 12). In impact assessments are not well developed. particular, this phenomenon threatens the coasts of Mwali and Ndzuwani and is already causing the Floods, the occurrence of which is expected to increase disappearance of coastal areas, beaches, agricultural because of more frequent heavy rainfall events and land, and forests. For instance, in Mutsamudu, the cyclones (UNDP 2017), put additional pressure on the capital of Ndzuwani, massive erosion has caused Comoros’ natural capital and pose a significant threat a significant part of the coastline to disappear and Figure 10.  Observed average annual mean temperature of the Comoros, 1901–2020. 25.5°C 25°C Temperature (°C) 24.5°C 24°C 23.5°C 1901 1911 1921 1931 1941 1951 1961 1971 1981 1991 2001 2011 2020 Annual Mean 5-yr smooth Source:  World Bank 2021b. The Decline in Natural Capital   | 21 | Figure 11.  Observed and projected mean temperature in the Comoros from 1990 to 2100. 31 30 29 28 27 26 25 24 2000 2020 2040 2060 2080 2100 Historical RCP 2.6 RCP 4.5 RCP 6.0 RCP 8.5 Source:  World Bank 2021b. Historical sea level for coastal Comoros (1993–2015) based on satellite data, observed anomalies (mm) relative to mean   Figure 12. for 1993–2012. 300 Average Historical Sea Level Anomaly 200 100 0 -100 -200 1994 1996 1998 2000 2002 2004 2006 2008 2010 2012 2014 2016 Average Monthly Anomaly Average Annual Anomaly January Source:  World Bank 2021b. also threatens the airport. The impact of coastal in Africa (World Bank 2019c), the ecological risk score erosion is estimated at damage to 29 percent of (species-specific estimates of exposure and ecological roads and strategic infrastructure and displacement and biological traits) for the Comoros is 69.996, which of at least 10 percent of the population (Ministry is classified as high (63–75). of Rural Development, Fisheries, Handicrafts and Environment 2006). Floods are extremely impactful for The Comoros archipelago is exposed to many natural Comorians settled in degraded urban areas and living hazards, including storms/cyclones, droughts in vulnerable housing made of sheets and other easily and floods, earthquakes, and volcanic activity destroyed materials (World Bank 2020j). Agriculture is (Figures 13–14). Natural disasters, combined with also affected by floods via the salinization of coastal the overexploitation of natural resources, have a aquifers and reduction of soil quality, which has dramatic impact on the Comoros’ natural capital, negative consequences for food production and thus as well as on people and physical infrastructure food security (Bourgoin et al., 2016). and buildings. Because of their reliance on natural- resource-based livelihoods and limited availability Ocean acidification, increasing seawater of alternative options, impoverished Comorians are temperatures, deoxygenation, and changes in ocean the most vulnerable to such events. Furthermore, currents are likely to have an impact on fisheries, natural disasters cause displacement of farmers, who although the severity of this phenomenon is not tend to migrate to urban areas where they end up yet well documented. According to the vulnerability living in precarious conditions and joining the ranks assessment of climate change and marine fisheries of the urban poor (World Bank 2021c). The impacts | 22 |   Comoros Country Environmental Analysis Overview of the most frequent natural disasters in the Comoros from 1980 through 2020 and the number of people affected. Figure 13.  Key Natural Hazard Statistics for 1980-2020 Number of People A ected 1M 100k Number of people 10k 1k 100 10 1980 1985 1990 1995 2000 2005 2010 2015 Drought Storm Epidemic Volcanic activity Flood Earthquake Source:  World Bank 2021b. of natural disasters are compounded by inadequate thousands of ”seemingly tectonic” earthquakes, cul- and inefficient disaster risk management and disaster minating in a magnitude 5.9 earthquake in May 2018. response (Box 5). This spike in activity is attributed to an underwater volcano just off the coast of the Comoros. Since then, The total average annual direct losses from tropical submarine seismicity has been registered an addi- cyclones, floods, and earthquakes are estimated at tional 16 times. A recent powerful tremor was regis- US$5.7 million, or 0.92 percent of the GDP in 2014 tered on all islands in March 2020, with the epicenter (World Bank 2020k). Tropical cyclones are the most located between Ndzuwani and Maore (World Bank significant disaster risk in the Comoros, causing 2021c). Although earthquakes account only for 2 per- approximately 64 percent of the estimated US$5.7 cent of the Comoros’ total annual direct losses from million combined direct losses. Losses from these natural disasters, recent ongoing seismic activity sug- natural disasters are not evenly spatially distributed. gests that they may become a serious high risk in the For example, because of its geographical location, (near) future (World Bank 2021c). Ndzuwani has the greatest risk of direct loss from tropical cyclones (Figure 14). Volcanic eruptions could represent a significant threat to the majority of the Comorian population The Comoros has experienced ongoing seismic and  ecosystems. The Karthala volcano, which activity in the past 20 years. It began with a series of forms the southern two-thirds of Ngazidja, is the Figure 14.  Modeled direct losses from earthquakes, floods, and tropical cyclones. Average Annual Loss (%) Direct Losses by Hazard 0 0.06 0.12 0.18 0.24% Earthquake Flood Tropical cyclone $160 M $80 M $40 M $20 M AAL RP10 RP100 RP250 RP10 RP10 RP100 RP250 AAL RP10 RP100 RP250 Source:  World Bank 2016a. Note: AAL: Average annual loss; RP10: 10-year return period; RP100: 100-year return period; RP250: 250-year return period. The Decline in Natural Capital   | 23 | only active  volcano in the archipelago, although Box 4. Cyclone Kenneth and the Post-Kenneth no eruptions have occurred since 2007. Since 1808, Project Karthala has erupted approximately 25 to 38 times, at an average eruption recurrence interval ranging In April 2019, the Comoros was hit hard byTropical from 5.3 to 8.0 years. This recurrence was exceeded Cyclone Kenneth, one of the most devastating with a succession of four eruptions occurring at tropical cyclones in the country’s history. Cyclone half-year intervals in 2005, 2006, and 2007 (Morin Kenneth affected more than 345,000 people and et al., 2009). During the 2005 eruption, approximately caused damage to approximately 14 percent 40,000 inhabitants were evacuated. of the national GDP (World Bank 2021). Impacts included economic growth falling from 3.6 per- cent in 2018 to 1.9 percent in 2019. A fast-track post-disaster evaluation and damage assessment 3.3. Costs of Environmental Degradation estimated the recovery and reconstruction need at US$277.5 million over five years. Environmental degradation and loss of natural capital will come at a price if not brought to a halt (Table 3). The country suffered from damage to the housing (See Annex 2 for cost calculations of environmental sector (67.5 percent of the estimated damage and degradation and Annex 3 for an overview of the losses), the agricultural sector (53 percent), infra- impacts of degradation on livelihoods of Comorians). structure and transport (21.1 percent), energy The pressures exerted on natural resources and (12.6 percent), and health and nutrition (12.3 ecosystems, underpinned by persisting poverty, the percent). Other damage included education and high vulnerability of rural populations, climate change, social protection,  water and sanitation, environ- and natural disasters, are contributing significantly to ment, and the public sector (World Bank 2021c). squandering the Comoros’ precious natural capital (Bourgoin et al., 2016). Unsustainable management Almost 80 percent of farms were destroyed, and use of agricultural land, climate change, and including 63 percent of crop plants and 35 percent natural disasters are estimated to result in yearly losses of cash crops. This resulted in significant losses for of US$274 million resulting from land degradation rural communities, given that agriculture consti- (see section 5.1; see also Annex 2 for the calculations tutes their main economic sector (UNICEF 2019). on losses resulting from land degradation). Severe The economic impacts of these damages were and persisting deforestation and overexploitation of partially offset by increased public and private forests are depleting the asset, threatening the island’s spending, consisting mainly of external aid biodiversity and the livelihoods of people depending and private remittances for reconstruction and on the forestry sector (see section 5.2). The costs of social transfers (World Bank 2020e). deforestation based on the deforestation rate, the ecosystem service value of forests, and the ecosystem In the aftermath of this catastrophe, the Ministry value of the new land use are estimated at US$1.953 of Land Use Planning and Urban Development million per year (Annex 2). Although coastal and marine in charge of Land Affairs and Land Transport has degradation are particularly severe due to inadequate been carrying out the Post-Kenneth Recovery and management of resources and climate change, as well Resilience Project financed by the World Bank. As as the associated risks of natural disasters, it was not part of this project, a study is being conducted to possible to undertake specific calculations because of develop an action plan for coastal risk manage- the lack of reliable and comparable data. In particular, ment which will consist of a framework docu- although there is evidence showing that fish stocks ment for investments to be implemented over the are being overexploited, coral reefs are bleaching, and next 10 years on the coastlines of the Comoros. mangrove forests and seagrass beds are declining It will also provide technical and scientific knowl- (Freed et al., 2018; IOTC 2021), additional studies edge and tools to inform activities to reduce risks are required to fully assess the magnitude of these related to coastal erosion and coastal flooding trends (see section 5.3.). An upcoming PROBLUE- for the three islands of Mwali, Ndzuwani, and financed activity by the World Bank will be carried out Ngazidja. The study will also inform the design to fill some of these gaps and support the sustainable of preliminary infrastructure aimed at reinfor- and integrated development of marine and coastal cing Comorian coastlines, prioritizing those areas resources (see Box 23). Quantification of the loss of most affected by Cyclone Kenneth. biodiversity also suffers from a lack of data, hampering the ability to provide reliable and comprehensive | 24 |   Comoros Country Environmental Analysis Box 5. Disaster Risk Management national disaster risk management tools (Union des Comores 2019b). For example, during the Disaster risk management (DRM) analyzes the 2006 eruption of the Karthala volcano, it became underlying causes of vulnerability to improve clear that the Comoros remained unprepared and strengthen the resilience of vulnerable to face a minor eruptive event, resulting in communities and ecosystems. The institu- a failure of the crisis management system tional DRM framework of the Comoros includes (Morin et al., 2009) The eruption forced people the General Directorate of Civil Security and living in the shadow of the mountain to flee, its branches at the island level: the Karthala and many people were unaware of the health Volcanological Observatory (OVK), the Technical hazards. Further analysis of the environmental Directorate of Meteorology (DTM), the epidemi- institutional framework and main policies is ological watch center, the national platform for provided in chapter 4. disaster risk reduction, and civil society organ- izations in the field. In addition, the Comoros has developed the following tools for emer- gency preparedness and response: characterization of the decline in natural capital in the Comoros. The impacts of environmental degradation 1. National Strategy for Disaster Risk Reduction on health also generate serious economic losses for the Comoros. The costs to advert disability-adjusted life National Emergency 2.  Preparedness and years (DALYs)6 attributable to unsafe water, sanitation, Response Plan and hygiene are estimated at US$40.7 million per year 3. National Contingency Plan and the costs to advert DALYs attributable to outdoor and indoor air pollution are estimated at US$51 million 4. Rescue organization plans at the island level per year and US$142 million per year, respectively. Specific plans for the primary hazards (for 5.  example, cyclone, tsunami, Karthala volcano,  The estimated annual costs of environmental Table 3. cholera, and marine pollution) (Union des degradation in the Comoros Comores 2019b) Economic Degradation Costs (US$, Specification of Calculation For Cyclone Kenneth, the General Directorate of of Asset millions/year) Civil Security, supported by the United Nations Terrestrial Terrestrial ecosystem services are System (UNS), United Nations Development ecosystem 274 lost as a consequence of degrada- Programme (UNDP), the World Bank, and the services tion (based on Sutton et al., 2016). International Federation of Red Cross and Red Forest ecosystem The loss of ecosystem services Crescent Societies (IFRC), conducted a fast-track services7 is associated with deforestation, postdisaster evaluation and damage assess- taking into account the new land ment. This resulted in the swift restoration of 2 use (agriculture) (based on De Groot main accesses to essential infrastructure fol- et al., 2012; FAO 2008; World Bank lowing emergency funding (World Bank 2021c). 2020b). Coastal and No data for estimation The main challenges of the Comoros related marine ecosystem No data to disaster risk management and response services revolve around the limited institutional and Biodiversity No data No data for estimation systemic capacities of stakeholders. These result from inadequate legislative and regulatory framework as well as a lack of operational and 6 Disability-adjusted life years. One DALY represents the loss transparent funding mechanisms for disaster of the equivalent of one year of full health. DALYs for a dis- risk management. Additional challenges ease or health condition are the sum of the years of life lost include operationalization hampered by very to due to premature mortality (YLL) and the years of healthy limited qualified human resources, appropriate life lost due to a disability (YLD) due to prevalent cases of the disease or health condition in a population (World Health Or- equipment, basic infrastructure, and scientific ganization [WHO] definition). knowledge of hazards, and a lack of ownership of This value does not include forest degradation, only de- 7  forestation; the actual number is therefore expected to be higher. The Decline in Natural Capital   | 25 | (Continued) Table 3.   not available for the Comoros, as these are highly dependent on local conditions and context. Table 4 Economic gives a qualitative overview of the magnitude of the Degradation Costs (US$, Specification of Calculation costs and the benefits of restoration actions (based on of Asset millions/year) figures in Annex 2). These do not include the benefits Health Cost to avert DALYs attribut- of the restoration of agricultural land or the restora- able to water, sanitation, and 41 tion of biodiversity. To be beneficial, restoration pro- hygiene (based on World Health Organization 2013) jects should prioritize ecosystems that have relatively low restoration costs and relatively high benefits, Cost to avert DALYs attributable 51 to indoor air pollution (based on such as tropical forests, wetlands, and coastal ecosys- World Health Organization 2018b) tems. More detailed suggestions for potential restora- tion projects are provided for the key environmental Cost to avert DALYs attributable to ambient air pollution DALYs in sectors in chapter. 142 Comoros (based on World Health Organization 2018a) Since the Comoros is a small island state, all ecosys- tems are connected and affected by each other. To Total 234 take effective restoration actions, it is therefore vital to always consider the source of the degradation  The qualitative magnitude of the costs and and to adopt an integrated landscape management Table 4. benefits of restoration projects approach. Rather than a single sector or ecosystem restoration action, an integrated landscape man- Typical Cost of Benefits agement approach would have the advantage of Ecosystem Restoration (over 40 Years) taking into account the health of the ecosystems Temperate forest + ++ that support livelihoods and contribute to communi- Tropical forest + +++ ties. Integrated activities have been shown to help Wetlands + +++ coordinate the multitude of actions of multiple land Rivers/lakes + ++ users and other stakeholders, reduce conflicts, and Coastal ecosystems ++ ++++ improve overall governance of water, land, and other Mangroves + ++ resources (Gray et al., 2016) reduced conflicts, and Coral reef +++ ++++ improved overall governance of water, land, and other resources. Integrated landscape management Source :  Adapted from Pravettoni, UNEP, and GRID-Arendal 2012. is thus a useful approach to enhance the intensifica- tion of dryland cropping systems and will, in many locations (but not always. This integrated approach 3.4. Benefits of Environmental Restoration to natural resource management should range from the land ecosystems, including forests, to coasts and The benefits of ecosystem restoration generally marine environment. This recommendation is fur- outweigh the costs (TEEB 2010). Precise values of ther elaborated as part of chapter 6: Opportunities the benefits of restoration and reforestation are for Change.  nvironmental Governance 4. E and Institutional Framework T he Comoros has a Both the FLE and PNE are being updated. The revision broad range of laws process aims to incorporate lessons learned in three and policies to guide decades of environmental management practice as environmental and natural well as key emerging issues such as decentralization resource management. This support, climate change, and strengthening the EIA chapter provides an overview of the country’s envi- system. For the FLE, which had already been updated ronmental laws and policies (4.1), as well as the insti- once in 1995, the law approval process is complex tutions in place to support them (4.2) and the national and involves technical committee reviews, public plans and strategies that have been adopted to steer participation, and dialogue in Parliament. On the the country toward a sustainable economic develop- contrary, the PNE is in the late stages of the process ment path (4.3). A way forward with key recommenda- (see Box 6). The FLE and PNE updating process is an tions for improvement is proposed in section 4.4. opportunity to incorporate emerging environmental issues, overhaul priorities, and facilitate the implementation of environmental management objectives. 4.1. Environmental Legal and Policy Framework After the adoption of the PNE and FLE, the Comoros took significant steps to improve its environmental The first instruments for environmental management legal and policy framework. The Government of the adopted by the Comoros are the 1993 National Union of the Comoros (GoC) enacted numerous Environmental Policy (PNE) and the 1994 Framework sector laws, adopted several national sector policies, Law of the Environment (FLE). The FLE provides and entered into international agreements related the legislative foundation for all environmental to environment and natural resources management sectors, defines the general principles for the (for details, see Annex 7). In 2018, the right to a healthy protection of the environment, and establishes an environment was enshrined in the Constitution: environmental impact assessment (EIA) process. “All  citizens have the right to a healthy and The PNE was established to integrate environmental ecologically stable environment, as  well as having dimensions into social and economic development a duty to protect and conserve it. ” In 2020, the GoC policies, covering resource management and updated the Fishing and Aquaculture Code to include strengthening sector policies. Both the FLE and the specific provisions regarding illegal, unregulated, PNE address similar emerging issues, including the and unreported (IUU) fishing, and the Water Code recommendations to: to further enable participative and decentralized use and protection of water management on each of the • Mainstream climate change into sectors three Comorian islands. • Increase responsibilities of municipalities in envi- Currently, there is no dedicated climate change policy, ronmental management though climate change is being incorporated in the updated FLE and PNE. The Comoros has ratified the • Strengthen the EIA system UN Framework Convention on Climate Change and the • Increase focus on enforcement, for example, by Kyoto Protocol and must integrate these into sectoral establishing a forest monitoring and protection unit policies, strategies, and development programs. In 27 | 28 |   Comoros Country Environmental Analysis Box 6. Updated National Environmental Policy Integrate natural capital and ecosystem 10.  of the Comoros services into national accounts and eco- nomic performance systems. The PNE is currently in the process of being updated (MAPETA 2021). The updated PNE aims The implementation of these strategies will to provide a relevant response framework to the involve the following: current environmental and climatic challenges, as well as to include the legal and regulatory • The principle of co-management and the de- advances made at the national and international velopment of income-generating activities levels. • Establishment of an environmental police The PNE includes an action plan which mobil- corps as well as enforcement tools ized actors in a transversal, collaborative, and integrated way. The action plan is structured into • Updating the legal framework and its ap- 10 main actions: plication and the framework law on the environment Reconcile the sustainable management and 1.  • Environmental awareness and education protection of natural resources with the practice of subsistence activities of the most • Reinforcement of knowledge in environ- vulnerable populations. mental matters 2.  Monitor and control practices that risk envi- • Strengthening the consideration of environ- ronmental degradation. mental requirements in economic and social investments Clarify the roles and responsibilities of 3.  actors and the different levels of public Through the updated PNE, the Comoros administration in environmental matters. aims to “ensure a healthy and sustainable 4.  Ensure the protection and enhancement of environment for the Comorian population and terrestrial and marine biodiversity. its descendants and to preserve and enhance the natural resources and environmental heritage of 5.  Improve the living environment of the Comoros” (MAPETA 2021). population and responsiveness to environ- mental risks. 2006, the Ministry of Rural Development, Fisheries, Ensure sustainable economic development 6.  Handicrafts, and Environment adopted the National of the Comoros through decision-making Adaptation Programme of Action (NAPA). The NAPA that includes climate change and the describes the main pressures on the environment and preservation of natural capital. economy of the Comoros and the vulnerability of the 7.  Strengthen knowledge in the fields of bio- country to climate change. It further elaborates on diversity, environment, and climate change, links with development programs and reviews actions and make this knowledge accessible to taken in the past to face climate change. Despite its everyone. low contribution to greenhouse gas (GHG) emissions, the Comoros adopted its nationally determined Ensure the development of a blue economy 8.  contribution (NDC) in 2021 aimed at placing the that respects biodiversity and marine and Comoros as a carbon sink (see Box 7). The NDC coastal resources. pledges to reduce net GHG emissions of the Comoros in 2030 by approximately 23 percent -excluding land Develop financing for the preservation 9.  use change and forestry (LUCF)- compared to the of natural resources and the environ- emissions projected for the same year according to a ment based on the “polluter pays” prin- reference scenario. ciple and the sustainability of funding sources. A transparent and robust EIA system is crucial for a country such as the Comoros, which relies heavily Environmental Governance and Institutional Framework   | 29 | on natural resources for economic development and livelihoods. A functioning EIA system is critical Adaptation measures for the most vulnerable   for identifying and managing potential impacts of Table 6. sectors of the Comoros development such as agriculture-induced deforestation or fisheries management, as well as for striking the right Sector Adaptation measure balance between economic growth and environmental Agriculture 1. Development of a resilient and climate-smart protection. In addition, a functioning EIA system is key to agricultural policy set an adequate enabling environment to attract private 2. Development of agro-pastoral irrigation 3. Establishment of an early warning system for the emergence of new bovine or caprine Box 7. Nationally Determined diseases Forests and 4. Extension of protected areas and reforested Contribution (NDC) biodiversity areas GHG emissions from the Comoros represent Fisheries and 5. Restoration and monitoring of marine and approximately 0.001 percent of the global emis- coastal/marine coastal ecosystems sions. Its net balance of emissions is negative, ecosystems 6. Raising awareness and increasing security of meaning that the country absorbs more than fishers in the face of climatic hazards it emits. Yet, the Comoros still has benefits and Water 7. Increase access to water and improve water potential for reducing its GHG emissions fur- management quality ther. The Comoros declares to contribute to the 8. Adopt integrated water resources manage- international effort to combat global warming ment by pursuing its objective of being a carbon sink. Disaster risk 9. Identification and mapping of areas vulner- The Comoros plans to reduce its net CO2 emis- management able to natural disasters sions by 23 percent and increase its net CO2 (DRM) 10. Adopt building standards based on disaster absorption by 47 percent by 2030 compared to risks the baseline scenario (MAPETA 2021). To achieve Source:  MAPETA 2021. these goals, the government is focusing on the mitigation actions outlined in Table 5. In its revised NDC, the government recognizes the importance of the role of women in many To strengthen the resilience of the country to the sectors strongly affected by climate change. effects of climate change, the revised NDC iden- The success of these mitigation and adaptation tified several adaptation targets for the most vul- efforts depends on the integration of women nerable sectors of the Comoros (Table 6). into various sectoral policies, capacity building, and mobilizing sufficient financial resources. Table 5.  Mitigation actions for the Comoros According to the estimates presented in the revised NDC, the Comoros will need an overall Medium- to Long-term envelope of about US$1,450 million to success- Short-term Priorities Priorities fully implement its NDC, comprising US$1.005 Consolidation of the electrical Continuation of development million for mitigation measures and US$445 network projects for photovoltaic million for adaptation measures. power plants Improvements in waste collection Launch of a first geothermal sector Reduction of firewood and Afforestation, reforestation, investments. The EIA legal and regulatory framework industrial wood by promoting agroforestry, and arboriculture should factor in considerations related to social risks alternative energy sources and and impacts to identify and assess social risks at the protecting forests planning stage of project cycles and ensure that such Reduction of residential firewood Increase in effective manage- risks can be managed as an integral part of project usage through the use of efficient ment of protected areas design and implementation. Finally, the development wood burners and strengthening of institutional capacity for SESA Promotion of organic waste implementation is also key to ensure that environmental compost and social implications are adequately taken into Source:  MAPETA 2021. account in the process of formulating plans, strategies, and projects in support of sustainable development. | 30 |   Comoros Country Environmental Analysis The legal, regulatory, and institutional framework for Moreover, gender and social inclusion are not men- EIA provides the foundation for a sound EIA process. tioned in the EIA regulation, making the case for The FLE enacted the first elements of the EIA system increasing the institutional capacity Environmental by establishing the minimum EIA content, as well and Social Impact Assessment (ESIA) implementa- as penalties for infringement of EIA requirements. tion. Although recourse to justice is possible in case The FLE also mandated the Council of Ministers to of infringement of EIA laws, the process involves prepare regulations establishing the EIA rules and a complex and time-consuming legal process that procedures, including information to the public, might delay or deter access to justice. Finally, limited and the list of projects subject to EIA. A 2001 decree capacity and insufficient resources are causing a sig- complied with that mandate and established the nificant gap in EIA monitoring, inspection, and com- EIA process in more detail and regulated projects pliance in ongoing and new development across all subject to EIA. A 2012 Ministerial Order established sectors. To address these challenges and support the and set the terms of reference for an EIA Evaluation ongoing effort to develop the EIA process, it is crucial Committee tasked with the review and approval of to do the following: all EIAs. Despite being operational,8 the committee requires further key expertise, for example, on • Strengthen the capacity of the EIA committee with social impact. Projects expected to have limited additional key expertise and capacity building. environmental and social impacts do not require a full EIA but rather an environmental notice with the • Strengthen the capacity of EIA units at the national associated environmental management plan. These and regional directorate levels to both process en- environmental notices can be approved at the level vironmental notices and monitor the implementa- of the regional directorate. tion of management plans. • Review and approve the existing draft sectoral Despite the significant progress in the EIA legal guidelines for EIA (that is, for the fisheries, agri- framework, several challenges remain ahead. culture, energy, and mining sectors) and develop While general guidelines for the preparation of and approve additional sectoral and cross-cutting environmental and social impact assessments have guidelines (for example, for tourism, infrastruc- been developed and approved, sectoral guidelines ture, oil and gas, and social assessments to incor- for key sectors such as fisheries, agriculture, energy, porate social inclusion considerations). and mining have been developed but not approved yet, and guidelines for tourism, infrastructure, and • Establish a transparent environmental manage- oil and gas still need to be developed. At this time, no ment information system to track EIA preparation, formal requirements exist for EIA consultants to be review, disclosure, and monitoring status. certified and registered in the Comoros, allowing any company or consultant to provide EIA services in the • Operationalize a dedicated financial system to col- country. In addition, although the FLE mandated the lect the fees associated with EIA management. Ministry of Environment and Public Health to develop • Provide EIA institutions at the national, island, and environmental quality standards, national standards local levels with technical and financial support to on water and air quality are yet to be approved and deliver their mandate appropriately. World Bank/International Financial Corporation (IFC) and World Health Organization (WHO) Standards are • Undertake an in-depth gap analysis to inform key applied instead. options for program strengthening in the medium term. In addition, no reference is made to the application of strategic environmental assessment for policies, plans, and programs in any of the environmental laws 4.2. Environmental Institutional Framework and decrees. Despite the general legal requirement included in the FLE, there are no regulations or guide- The Comoros environmental institutional framework lines for public participation and disclosure and there is organized on three levels: central (national), regional is a lack of clarity on which ministry/department is (island), and local (community). This framework is the responsible for social issues. result of a decentralization process envisioned under the 2018 constitution that started in 2011 when the 2001 constitutional agreement was enacted; however, the process remains incomplete and only partially effec- 8 The committee met approximately eight times in 2021 and tive. The environmental institutional setting is also char- twice in 2022. acterized by the coexistence of formal and informal Environmental Governance and Institutional Framework   | 31 | institutions, reflecting the difficulty for formal institu- status (United Nations Environment Programme tions to establish their legitimacy, while local commu- [UNEP] 2016). The governorate, selected by uni- nities continue to rely heavily on local traditional and versal suffrage, is accompanied by a consulta- informal governance systems. The three-level envi- tive council whose members are appointed by ronmental institutional framework, mixing formal and the community councils. In particular, the gover- informal actors, is structured as follows (Figure 15): norate is responsible for the design and imple- mentation of the Comoros Emerging Plan (PCE) • Central level (national): The Comoros institutional for each island and has the following mandates framework places the Ministry of Agriculture, related to natural resource management: (1) the Fisheries, Environment, Tourism, and Handicrafts economic and social development plan; (2) land- (MAPETA) at the core of environmental use planning; (3) the promotion of tourism, the management. Under MAPETA, the General environment, and the historical heritage of the Directorate of Environment and Forest, Fisheries island; (4) artisanal fishing; and (5) agriculture Resources, and Agriculture and Livestock and livestock, excluding strategies and research. Strategies was established to develop and monitor Despite enjoying an independent administration the implementation of environmental policies and management autonomy, governorates are and promote and coordinate governmental largely financially dependent on central institu- and nongovernmental activities related to the tions, limiting their capacity to fulfill their man- environment (Figure 15) (MAPETA 2021a). The dates effectively. The islands are divided into 16 General Directorate has a regional office on each of prefectures, each with a head appointed by the the three main islands of the country. central government. The prefect, who is respon- • Regional level (island): The main body responsible sible for the enforcement of laws and regula- of ensuring the implementation of environmental tions, is the interface between municipalities and policies and strategies at the island level is the the governorate, on the one hand, and the cen- regional directorate, which acts on behalf of the tral government on the other. The authority of the DG. Environmental management at the regional prefecture is contested by some municipalities, level is also ensured by governorates. Each island and prefectures generally do not have sufficient constitutes a governorate and has autonomous human or financial resources. Environmental institutional framework of the Comoros showing the subdivision of general and regional directorates into   Figure 15. specific sectors: environment and forests, fishery resources, and agriculture and livestock strategies.9 Central Ministry of Agriculture, Fisheries, National General Directorate (DG) Environment, Tourism and Handicrafts Programs - Define policy, programs and projects - Develop and participate in - Develop environmental legislation the implementation - Environment and Forests - Monitor and evaluate implementation of government policy - Fisheries Resources - Honor obligations to international - Promote and coordinate - Agriculture and livestock co nventions activities related to strategies environment Regional Governate Regional Directorate (DR) (island - Exclusive competence over - Ensuring implementation promotion of environment level) of policies and implementation - Participate in natural Plan Comoros Emergent resources management and environmental Prefectures protection Grande Comore Anjouan Mohéli - Monitor application of regulation 8 5 3 Decentralized Municipality strucures Grande Comore Anjouan Mohéli (Communities 28 20 6 & Villages) NGOs Informal Villages Informal Professional organizations Informal Sources:  Adapted from MAPETA 2021; Suez et al., 2021. 9 The Comorian names for the islands are Ngazidja (Grande Comore), Ndzuwani (Anjouan), and Mwali (Moheli). | 32 |   Comoros Country Environmental Analysis • Local level (community): Municipalities are the devolution of competencies is not complete and basic formal territorial authority in the Comoros. functions among institutions have not been clearly They group together several villages, are headed defined. Competing governance structures at the by a mayor, and are in charge of environmental national and regional levels often do not provide management, water supply, sanitation, housing the right incentives for collaboration and further and habitat, and communal equipment. While they fragment the delivery of state services. The are a formal institution, they do not have the ade- incomplete decentralization process has deepened quate administrative services and financial means the sense of disconnect between the central state to accomplish their missions. Together with mu- and local centers, increasing the importance of local nicipalities, informal institutions such as nongov- informal institutions in providing environmental ernmental organizations (NGOs), villages, and management services. professional organizations play key roles in local • Limited technical capacity. The environmental communities, as they are rooted in traditional local institutions of the Comoros generally lack power and benefit from greater credibility and le- the required technical capacity to fulfill their gitimacy among the population. Villages, the core mandate, comprehensive capacity-building and unit of identification and societal organization at professional-development programs, and human the local level, host several associations, including resource allocation at national, island, and local environmental-protection associations, which levels. carry out activities in the field of environmental and sustainable development. These associations • Financial constraints. Insufficient financial are typically able to mobilize funds to carry out resources risk jeopardizing the capacities of local projects aimed at providing environmental the general and regional directorates, and management services. As soon as the scale of the environmental expenditures are often not aligned village or neighborhood is reduced, the social co- with the environmental priorities, hampering hesion to mobilize actors or funding for projects effective and efficient management of public becomes quite challenging (Suez et al., 2021). In resources. Indeed, a detailed look at expenditures addition to villages, NGOs and professional or- and budget executions in 2013 pointed out a ganizations form two other types of informal in- general prioritization of remuneration-related stitutions relevant to environmental management. spending, underspending on public services, Both national and international NGOs play a role and expenditure bias toward the administrative in the implementation of donor-financed environ- institutions at the expense of economic and mental and natural resource management pro- social sectors and investment programs. The jects, often together with village communities. 2013  budget designation to the Ministry of Professional organizations in the field of agricul- Production, Environment, Energy, Industry, and ture and fisheries often operate as cooperatives, Handicrafts—the predecessor to the current positioning themselves as the beneficiaries of ag- MAPETA—accounted for 88 million KMF or 1.5 ricultural and fishery development projects. The percent of the national budget, 32 percent of best-known professional organizations are the which was executed (World Bank, n.d.). Union of Chambers of Agriculture and Fisheries, National Union of Comorian Farmers, and the 4.2.1. National Plans and Strategies for National Union Comorian Fishers. Through the projects of professional organizations, farmers Sustainable Economic Development and fishers can directly receive technical or finan- The GoC has recently invested in a concerted effort cial support. to develop ambitious plans and strategies to fur- ther define a path for sustainable development. With this purpose in mind and in line with the Agenda for Challenges Sustainable Development 2030, the GoC developed The effectiveness of the current environmental institu- the following main strategic planning documents: tional framework of the Comoros is challenged prima- rily by the following: • Comoros Emerging Plan (PCE) 2030 • Accelerated Growth and Sustainable Development • Fragmentation, unclear distribution of roles, Strategy and limited inter-level collaboration. While a decentralization framework is in place, the • Blue Economy Strategic Framework Environmental Governance and Institutional Framework   | 33 | Box 8. Land Tenure in the Comoros Advantages and disadvantages of the three  Table 7.  tenure regimes In the Comoros, three land tenure systems coexist— customary law, Islamic law, and civil law inspired Customary Law Muslim Law Civil Law by modern French law. This original, but highly Land Land inherited Land belongs Private and complex and incoherent, situation is the result of a ownership through matri- to whomever domanial land history of multiple foreign nations importing their lineal lines puts it to pro- ownership legal system to the Comoros. ductive use The coexistence of these tenure regimes creates con- Advantages Efficient, strong Anchored in High land fusion and low-level territorial disputes over land social basis, Comorians security through firmly rooted who practice land official titles ownership (World Bank 2020d). Land ownership can in Comorian Sunni Islam be at the state, community, religious, family, and indi- customs vidual levels with these modes of ownership often Disadvantages Weak legal Weak legal Double overlapping. The transfer of land is also governed by aspects aspects allocations of both religious and customary laws, practices, and land, absence codes. Land ownership has an important gender of a modern component in the Comoros with approximately 59 cadaster, com- percent of women owning land versus 42 percent of plex procedures men (2012 Demographic and Health Survey). Source:  Sow 2021. Although women generally inherit land according to custom, usufruct rights tend to go to their male for municipal cooperation tasked with clarifying relatives.  The land tenure system is challenging property rights and reforming land governance. economic development as the complexity of land ownership does not create a favorable climate for The main challenge consists in integrating the private investors. This is in part reflected by the low three systems into a single legal regime that takes rank (160 out of 190 countries in 2020) of the Doing into account the cultures of the other regimes. To Business Index of the Comoros, which analyzes the address this issue, the Provisional Report of the regulation that encourages efficiency and supports Diagnostic Study on Land Tenure in the Comoros freedom of doing business (World Bank 2020g). proposes an integrated tenure regime that focuses on simplified and clear procedures, reduction of Under short-term informal contracts, farmers use land disputes, and increased efficiency and effec- the lands for production. Since these farmers do not tiveness (Sow 2021). The objective of this new own the land, there are no incentives to make any regime is to provide legal certainty and strengthen long-term investments in production techniques or social cohesion while ensuring transparency. The land conservation. As a result, agricultural yields new regime would operate at the municipality remain low and the land degrades, leading to land level, but the established village land committees abandonment when the land becomes less pro- and the cadi would remain in charge of customary ductive (stakeholder consultations). The increasing and religious rights. Findings by these author- demand for arable land results in further clearing ities have to be validated by the land counter. The for agricultural expansion, involving deforestation decentralization of tenure securitization could be and burning (UNEP 2016). Besides the complexity envisaged in the short term but requires capacity of the tenure system, a key problem lies in the lack building of technical staff and funding (World Bank of authorities empowered to settle disputes over 2021c). A key component of this new land regime access to land or land use. As a result, disputes should be to reduce the costs of land registration become conflicts. A recent urbanization review and tax landowners, creating incentives to use carried out by the World Bank specifically recom- their land productively and invest in long-term land mends setting up a dispute resolution mechanism conservation. Smallholders Low Complexity No long-term Land cannot own agricultural tenure regime investments degradation land production | 34 |   Comoros Country Environmental Analysis This strategic effort is in line with the World Bank After the adoption of the PCE in 2019, the GoC Country Partnership Framework (CPF), which is aimed initiated a process for resource mobilization as well at supporting the Comoros in finding a sustainable as the  necessary reforms for implementation. The growth path and building the resilience of its Development Partners Conference (CPAD) was held in population against multidimensional shocks. Paris in 2019, resulting in a pledge of approximately €4 billion toward the implementation of the Comoros PCE. The implementation of the PCE will take place through flagship projects, structuring projects, and priority Comoros Emerging Plan 2030 sectoral projects (see the overview of the topics and In 2019, the GoC adopted a national strategic plan for their cost estimate in Table 8). The structuring projects long-term action: the Comoros PCE 2030. The PCE include six proposed projects, two of which are aimed describes the focus areas and large-scale projects at environmental and natural resource challenges: the that will drive the structural transformation of the promotion and development of the agricultural sector, emerging Comorian economy. The plan is a reference and integrated waste management in the Comoros. document for the implementation of the Sustainable The costs of the development components proposed Development Goals (SDGs), to which the Comoros has for the agricultural sector are estimated at €12.8 million been committed since 2015. In addition, it advocates (US$14 million) and the costs of integrated waste joint implementation of the SDG 2030 agenda as well management development are set at €35.575 million as the African Union’s Agenda 2063. The PCE is based (US$39.32 million). Implementation mechanisms of the on five strategic pillars (Figure 16): (1) tourism and PCE aim to involve Comorians at all institutional levels, entrepreneurship, (2) an established blue economy ranging from national, island, municipality, and village of the Comoros, (3) a hub for financial services governments and NGOs (Union des Comores 2019b). and logistics in the Indian Ocean, (4) modernized agriculture for food security, and (5) industrial niches to diversify economy. Accelerated Growth and Sustainable Five essential catalysts have been identified for Development Strategy (SCA2D), 2018–2021 achieving these pillars: (1) a reformed and stable polit- The SCA2D 2018–2021 is a national benchmark ical and institutional framework, (2) up-to-date infra- document that lays the foundation for the structural structure for an efficient economy, (3) human capital transformation of the national economy and fed into that is ready for the future, (4) structural reforms for the preparation of the principal development plan for a competitive environment, and (5) digital revolution. the country, the PCE 2030. It was initially developed in Figure 16.  The five strategic pillars of the PCE 2030. Tourism and entepreneurship Industrial An established niches to diversify Blue Economy of the economy Comoros the Comoros Emerging Plan A hub for Modernized nancial services agriculture for and logistics in the food security Indian Ocean Source:  Adapted from UNDP 2019b. Environmental Governance and Institutional Framework   | 35 |  Total overview of the topics addressed in the disrupted by Cyclone Kenneth in 2019 and the COVID- flagship projects and structuring projects of the 19 pandemic in 2020. These events highly affected Table 8. PCE 2030, including their cost estimates in US$ agriculture, fisheries, natural resources more broadly, millions and infrastructure. The outcomes of the SCA2D were incorporated into the PCE 2030, currently the main Total development plan for the country. Flagship Projects (US$ Millions) (US$ Millions) Maritime development 68.2 1,534.1 Tourism sector 747.7 Blue Economy Strategic Framework Hospital 129.7 In 2018, the GoC adopted the Strategic Framework for Energy sector 378.3 a National Policy on the Blue Economy (BESF)  (Union Airport development 114.5 des Comores 2018). The main objective of the BESF is to Administrative district and smart city 95.6 define a strategic framework to integrate the Comorian maritime space and its resources into the country’s long- Structuring Projects term sustainable socioeconomic development policy. Port infrastructure 249.6 1,482.6 Exploitation activities include the sustainable develop- Moroni smart city 1,036.6 ment of aquaculture, coastal tourism, marine biotechnolo- Urbanization 4.1 gies, and marine energy. The BESF is in line with the PCE Roads 139.3 2030, which recognizes the blue economy as a key pillar for the country. Agricultural development 13.9 Waste management 39.0 The strategic framework is structured into five specific TOTAL AMOUNT PLEDGED AT THE 2019 PCE 2030 4,360 objectives: (1) strengthen national safety and security; CONFERENCE (2) enhance key sectors of the blue economy, including training and job creation for young people; (3) protect Sources:  Union des Comores 2019; Union des Comores et al., 2019. coastal, aquatic, and marine ecosystems and waste management; (4) adapt the institutional framework; partnership with United Nations System (UNS) in 2015 and (5) reorient the areas of regional cooperation. and was revised in 2018 to be aligned with the PCE 2030. The SCA2D has been the second development The BESF comes along with an action plan, which is document, following the Strategy Document for meant to support the implementation of the Strategic Growth and Poverty Alleviation (DSCRP), and aims for Framework (Union des Comores 2018). Following the accelerated, strong economic growth that generates adoption of the BESF , a national committee co-chaired by decent jobs, while promoting the sustainable the Ministry of Foreign Affairs and the General Planning development of the Comoros. The SCA2D is the first Commission was established to step up this implemen- milestone on a path toward prosperity and emergence, tation process. Nevertheless, as of August 2022, this in line with the vision of the PCE 2030, the 2030 Agenda committee exists only on paper and is not operational. for Sustainable Development, and the African Union’s The main constraints for the operationalization of the Vision 2063 (General Secretary of the Presidency and action plan are (1) inadequate structural and long-term General Planning Commission 2017). funding, (2) the absence of a clear mandate establishing the roles and responsibilities of the committee, and The overall objectives of the SCA2D areto (1) strengthen (3) lack of an investment plan with clearly identified the foundations of a structural transformation of the financing mechanisms for the proposed action plan. economy, to achieve strong, viable, sustainable, equi- table, and inclusive growth; (2) improve the quality of life of the population and guarantee equitable access to Comoros Country Partnership Framework basic social services; (3) ensure the rational exploitation FY20–FY24 of natural resources following the principles of sustain- able development, while taking into account climate The CPF’s overall goal is to accompany the Comoros change; (4) strengthen good governance and resilience in launching a path for higher economic growth, in the face of political and institutional fragility; and (5) investing in human capacity and building resilience promote the rule of law and social cohesion. (World Bank 2020k). The CPF builds on the Systematic Country Diagnostic (SCD), which takes stock of Good progress was made in the implementation of development progress in the Comoros and reflects the SCA2D through 2018, after which progress was on constraints and opportunities for growth (World | 36 |   Comoros Country Environmental Analysis Bank 2020j). The CPF concentrates on two focus areas: complete and strengthen the selected value chains (1) crisis response and building resilience through of selected sectors (for example, tourism, fisher- investing in human capital, disaster recovery, and ies, and agriculture), connecting to the PCE strate- resilience; and (2) economic recovery and inclusive gic pillars. growth through improving the governance and business environment, fostering private sector growth, T he CPF will study options and pathways for and improving connectivity. The CPF seeks to mobilize developing a blue economy framework and resources and carry out political reforms to help the undertake preliminary steps where possible, country advance toward achieving its ambitious goals which directly contributes to the PCE pillar of “an of economic development. The CPF is aligned with the established blue economy of the Comoros. ” PCE 2030 (Figure 17).  Under focus area 1, the World Bank will support national and local institutional capacity building 4.3. The Way Forward to prepare for natural events, which will increase • Approve the updated PNE and FLE. The approval in incidence because of climate change. It will of these two fundamental elements of the envi- support the government in adopting a proactive ronmental framework can help upgrade environ- approach to disaster risk management. These ac- mental priorities, incorporate emerging issues tivities will support the PCE essential catalyst of and lessons learned, and facilitate the implemen- ” “human capital that is ready for the future. tation of ambitious environmental management  Under focus area 2, the World Bank will help the objectives. In addition, the updates of the PNE government accelerate the sustainable transfor- and FLE should be accompanied by a monitoring mation of the agriculture and fisheries sectors system to track implementation and draw lessons (connecting to the PCE 2030 objectives). It will learned. Figure 17.  Alignment of SCD and CPF with government priorities. SCD CPF COMOROS EMERGING PRIORITIES OBJECTIVES PLAN 2030 Pathway 1: Overcoming the COVID-19 investment gap Axis 1: Necessary Conditions Macroeconomic management to PANDEMIC A Sound macroeconomic framework build trust with investors Resilience ot climate change and Expand domestic revenue disasters mobilization Renewed framework for policy Improve financial sector dialogue mobilization Fnabling business environment Focus Area I: Crisis Response & Axis 2: Essential Catalysts Pathway 2: Raising Human Capital Building Resilience Stable political and institutional Reduce infant and child mortality Building Human framework and associated reforms Reduce stunting Capital Sound infrastructure Improve quality of education Disaster Recovery Human Capital Close education gender gap and Resilience Structural Reforms for a competitive environment Pathway 3: Protecting and Focus Area II: Comoros as an actor in the digital leveraging Comoro’s natural Economic Recovery revolution resource base & Inclusive Improve water management Growth Axis 3: Strategic Pillars Reform agriculture Improving Business Tourism and crafts Develop sustainable management Environment & Blue Economy approach to fisheries Governance A financial hub for Indian Ocean Strengthen DRM Improving Modern agriculture for food security Reform Land Tenure Connectivity Industrial niches for diversification Source:  World Bank 2020k. Environmental Governance and Institutional Framework   | 37 | • Strengthen the capacity of general and regional social assessment incorporating social inclusion directorates to fulfill their mandate by mobilizing considerations,), (4) establish a transparent en- the human, technical, and financial resources nec- vironmental management information system to essary. Develop targeted continuous professional track the status of EIA preparation, review, dis- development programs for technical staff at dif- closure, and monitoring, and (5) operationalize a ferent levels as well as capacity building for other dedicated financial system to collect the fees as- stakeholders. Carry out a human resource needs sociated with EIA management. An in-depth gap assessment to ascertain the specific level of sup- analysis can further inform key program strength- port needed at the national and regional levels for ening options in the medium term. Within this the directorates. Align environmental expenditure context, institutional capacity for developing the with priorities and use results-based agreements SESA will need to be developed and strength- to improve effectiveness and efficiency in the use ened, to ensure that development plans and strat- of public resources. The Comoros might benefit egies adequately take into account the social and from a dedicated environmental expenditure re- environmental implications of sustainable devel- view to provide more clarity on the specific chal- opment plans and strategies. lenges and needs in the sector. • Boost enforcement capacity coupled with tar- • Strengthen vertical (between the national, island, geted livelihoods support and community em- and local levels) and horizontal (between sectors) powerment programs. Dedicate targeted efforts inter-institutional coordination by setting coordi- to enhance enforcement capacity by providing nation incentives and quantifiable goals that are human, technical, and financial resources to the regularly monitored. The process of updating both implementation of environmental and natural re- the PNE and the FLE represents an opportunity to source regulations and policies; the establishment bring government officials and other key stake- of the specialized forest monitoring and protection holders together to generate a policy dialogue fo- unit included in the draft PNE is a step in the right cused on cross-cutting coordination. Continuation direction. Enforcement needs to be coupled with a of the decentralization process can emphasize the co-management approach that involves and em- role of national and regional directorates in sup- powers local communities in the management of porting governorates and local institutions to fulfill resources and livelihoods and creates a framework their environmental management mandates. for dialogue and consultation between the various stakeholders concerned by the exploitation of nat- • Update the EIA regulatory framework and man- ural resources. Co-management approaches are agement system, also factoring in social impacts bringing positive results in the areas where they and risks by developing and strengthening the have been piloted (for example, the South West institutional capacity for implementing ESIA. Indian Ocean Fisheries Governance and Shared Key immediate improvements include to (1) Growth Project [SWIOFish1], see section 5.4.3). strengthen the capacity of the EIA committee with additional key expertise and capacity building, • Increase public participation and socially inclu- (2) strengthen the capacity of the EIA unit at the sive service delivery participation by establishing national and regional directorate level to both and strengthening environmental monitoring sys- process environmental notices and monitor the tems, public disclosure, and feedback mechan- implementation of management plans, (3) review isms. Public awareness, coupled with important and approve existing draft sectoral guidelines for feedback mechanisms on the design, implementa- EIA (that is, for the fisheries, agriculture, energy, tion, overall performance, and grievances related and mining sectors) and develop and approve to environmental programs, can help build trust additional sectoral and cross-cutting guidelines between the government and the communities it (for example, tourism, infrastructure, oil and gas, serves. 5. Key Environmental Sectors T his chapter assesses the environmental chal- lenges of the Comoros in six key environmental • Agriculture, the largest economic sector in the sectors: land (5.1), forest (5.2), water (5.3), fish- Comoros in terms of gross domestic product eries, coast, and marine (5.4), solid waste manage- (GDP), constitutes 70.4 percent of land use. ment (5.5), and nature-based tourism (5.6). For each Together with forestry and fishing, agriculture sector, analysis of the state of environmental degra- represents 36.7 percent of the GDP and 34 dation, its cost, and its impact on livelihoods is pre- percent of employment. sented. Recommendations to overcome degradation are then proposed to inform the opportunities for • The agricultural sector is predominantly change described in chapter 6. subsistence-based. Productivity is low relative to peer countries, implying opportunities for eNVIRONMENTAL SECTORS KEY CHALLENGES change. • The socioeconomic complexity of the land LAND tenure regime poses a significant challenge to Natural sustainable land management. ST FORE WATER Capital N ATU RE-BAS EMEN T is in decline Chapter 3 NAG ED MA CO INE S TO RIS AST A 5.1.1. Sector Characteristics TE N D M A R WA U M Given the volcanic soil, the Comoros is endowed with abundant fertile land, which creates favorable 5.1. Land conditions for agriculture. Agriculture accounts for 70.4 percent of land use, with 0.08 ha of arable land estimated per person. Agriculture is the largest eco- Key Features nomic sector in the Comoros in terms of GDP contri- bution and source of employment, estimated at 30.5 • It is estimated that 57 percent of the arable land percent and 34 percent, respectively (Table 9). Land of the Comoros is in a state of degradation. is largely used for subsistence agriculture, while the main cash crops are ylang-ylang, cloves, and vanilla. • Land degradation in the Comoros is mainly These cash crop cultures are mainly produced in driven by unsustainable management of the coastal lowlands of the Comoros and are cen- agriculture. tral to the economy, accounting for 90 percent of all export income (Breuil and Grima 2014; World Bank • Climate change and natural hazards accelerate 2019). However, these crops are cultivated in mono- the country’s land degradation. cultures, and are therefore quite destructive to the • Land degradation in the Comoros results in a environment and result in land degradation. To find reduction of ecosystem service value of about new fertile land to cultivate the cash crops, these 18 percent, corresponding to a loss of US$274 plantations are being moved up to higher altitudes, million per year. resulting in additional deforestation. Furthermore, in recent years, the production of cash crops has 39 | 40 |   Comoros Country Environmental Analysis Figure 18.  Overview of identified environmental challenges in the Comoros. NATURE-BASED TOURISM FORESTS WATER LAND SOLID WASTE COAST MANAGEMENT & MARINE Source: Deltares. declined, primarily because of natural disasters and price variations in international markets (Union des Comores 2019b). 5.1.2. Land Degradation and Its Drivers Land degradation,10 underpinned by high population density and inadequate governance and manage- ment, is a major challenge for the Comoros. It is esti- mated that 57 percent of the arable land is in a state of degradation (Bourgoin et al., 2016). According to the Digital Observatory for Protected Areas (DOPA) developed by the European Union, coastal areas saw the most significant declines in the productive capacity of land between 1999 and 2013 (Figure 19). Land degradation in the Comoros has gone hand in and hand with a progressive expansion of land used for agricultural purposes. In fact, to cope with agricul- tural plot degradation, smallholder farmers are com- pelled to use additional plots to maintain usual levels Comorian banana farmer of crop planting and harvesting. Nevertheless, this Photo Credit: Deltares cropland expansion has not kept up with the country’s population growth, resulting in an estimated decline in cropland wealth per capita of approximately 43 water purification and flood control. The risk of percent between 1995 and 2018. soil erosion is higher in the Northeast and South of Ngazidja and the West, East, and South of Ndzuwani Land degradation in the Comoros increases the than in other locations (Bourgoin et al., 2016). This intensity of soil erosion and causes significant loss risk differs between Ngazidja and Ndzuwani because of biodiversity and ecosystem services, such as of differences in slope relief and soil quality. With the erosion of young fragile soils, waterways get dis- 10  Land degradation is defined here as “the deterioration or rupted and increased sediment loads are released loss of the productive capacity of the soils for present and into rivers, further contributing to water scarcity and future” (Global Environmental Facility [GEF], n.d.). Land deg- poor water quality (see section 5.3). Additionally, radation is one of the world’s most pressing environmental land degradation and soil erosion expose Comorian problems and is essentially caused by land clearance, poor agricultural practices, inappropriate irrigation, deforestation, communities to hydro-climatic risks such as floods and climate change. and droughts. Key Environmental Sectors   | 41 | Table 9. Economic importance of the agricultural sector and soil water infiltration and diminish the amount of groundwater available for crop growth. Indicator Value Share of GDP (value-added) 30.5% In the Comoros, land degradation is closely related to Share of employment 34% inequality and rural poverty. The rural poor cultivate Share of total land area 70% cassava, banana, yam, and maize, are generally not engaged in the farming of cash crops, but are involved Arable land per person 0.08 ha in harvesting ylang-ylang. Since poor rural Comorians Added value per worker US$4,304 are primarily located in the most unfavorable lands and Cereal yield 1,370 (kg/ha) engaged in land-related activities for their livelihoods, as land degrades, they face a higher risk of losing their Sources:  World Bank 2018, 2019b, 2019a, 2020a. main source of income. This mechanism also tends to widen the income gap between rural-based poor and Land degradation results in a loss of land productivity Comorians who rely on other types of assets to gen- and thus in the reduction of agricultural output, aggra- erate income, thereby exacerbating social inequalities vating poverty, food insecurity, and unemployment within islands. levels in rural areas. Smallholder farms, which dom- inate farming in the Comoros, are particularly vulner- able to the effects of land degradation, as they generally Unsustainable Farming Techniques, Climate produce lower and more volatile yields than large-scale commercial farms (World Bank 2020j). Another lia- Change, and Natural Hazards bility factor is the fact that agriculture in the Comoros One of the main drivers of land degradation in the is mainly rainfed, and less than 1 percent of the arable Comoros is the unsustainable management of agri- land is currently actively irrigated.This makes the degra- culture, which is still dominated by slash-and-burn dation process, which is compounded by droughts and farming and monoculture cropping (ylang-ylang, changes in precipitation patterns (Bourgoin et al., 2016), vanilla, cloves). Most farming is done without any fer- even more impactful for the Comoros, as degraded tilizer, and water management is still largely under- lands reduce the water-holding capacity of the soil developed; for example, small-scale water control Figure 19.  Changes in land health and productive capacity over 15 years (1999–2013). Persistnet Persistnet Persistnet strong Persistent severe moderate Stable No biomass inter-annual increase in decline in decline in productivity (km2) productivity productivity productivity productivity (km2) variations (km2) (km2) (km2) (km2) Hahaya Lilolo 311 114 66 280 911 315 MORONI Mutsamudu COMOROS Domoni Fomboni Adda Douéni Source:  European Commission 2021. | 42 |   Comoros Country Environmental Analysis for improving production during dry spells is almost nonexistent (UNEP 2016). Most farmers lack technical Box 9. Family Farming Productivity and knowledge on sustainable irrigation practices and rely Resilience Support Project (PREFER) on labor-intensive agricultural production techniques that offer few diversification options. These unsustain- The PREFER project launched by the International able farming techniques, compounded by the lack of Fund for Agricultural Development (IFAD) aims adequate agricultural infrastructure, contribute to land to improve the country’s food and nutritional degradation through declining soil fertility, increasing security by sustainably increasing food avail- pressure on the steep slopes, higher degree of soil ero- ability while strengthening the livelihoods of sion, deforestation, watershed degradation, and high poor rural populations by increasing agricultural sediment loads to the marine environment (Bourgoin incomes at the household level (IFAD 2021). The et al., 2016). project runs from December 2017 to December 2022. During the mid-term review in 2020, it was Climate change and natural hazards exacerbate the found that more than 3,000 households had effects of unsustainable farming practices, further benefited from the project (40 percent of women increasing and accelerating the ongoing land deg- and 27 percent of young people). The direct radation processes. Increased frequency and inten- effects of the PREFER project were: sity of heavy precipitation, coastal erosion affected by a rise in sea level, floods, droughts, and cyclones • Adoption and replication of improved produc- put addition pressure on soil losses in the Comoros tion techniques at the farmer field school level while contributing to changing vegetation cover and in individual plots (for example, hedging, cul- composition. The combined impact of these phe- tivation techniques, and organic fertilization) nomena contributes to reducing the productivity of • Improvement of productive capacity by the agriculture sector, especially considering that the increasing cultivable areas through restora- Comoros suffers from the lack of appropriate irriga- tion of land fertility on previously uncultivated tion systems. At the same time, degraded lands are steep slopes more vulnerable to the impact of climate change and natural hazards, triggering a downward spiral of • Yield improvements, particularly by providing land degradation, climate vulnerability, and produc- access to cassava cuttings and banana shoots tivity losses. Although the mitigation agenda is not • Establishment of good farming techniques and the most urgent concern for the Comoros, it cannot practices be overlooked that land degradation, if unchecked, • Hedging of plots, creating multiple benefits reduces the valuable function of lands as carbon including improved soil fertility and protection sinks, thus likely resulting in an increase in the against erosion country’s GHG emissions. In light of the decline in the value of cropland as described in Chapter 3, soil Despite these achievements, PREFER has not been degradation can indeed hamper carbon sequestra- able to improve market access, which remains tion potential and thus jeopardize the achievement weak. Therefore, this CEA recommends mobilizing of the ambitious nationally determined contribution technical assistance to support the development of (NDC) goal of increasing net CO2 absorption by 47 a value chain for livestock products. percent by 2030 compared to the baseline scenario (see Box 7). 5.1.3. Costs of Inaction and Opportunities The impacts of climate change on land are not equally for Change distributed among the different cultivation systems Land degradation11 has significant cost implications of the Comoros. Cultivated crops in open fields are for the economy of the Comoros. Although there is the most vulnerable to climate change, given the lack of protection by forest cover. Cultivation sys- tems near natural forests and agroforestry systems In this current CEA, land degradation is measured as the 11  ratio between the total ecosystem service value before land are most resilient to the effects of climate change. degradation (ESV Terrestrial) and the total ecosystem service Lowland monocultures, such as ylang-ylang, vanilla, value after land degradation (ESV degraded). Their approach and cloves, which are essential to the country’s of using simple benefit transfer methods to estimate the im- economy, are affected not only by droughts but also pacts on the value of ecosystem services allows the definition of the “land efficiency ratio” but has certain shortcomings like by increased saltwater intrusion via surface and sub- the use of an oversimplification of the ecological reality. Nev- surface water connections between land and coastal ertheless, their findings are relevant to understanding the water systems. economic consequences of land degradation. Key Environmental Sectors   | 43 | no comprehensive recent study on land degrada- as for water storage should be considered in cash tion in the country, it has been estimated that land crop areas. Additionally, to improve the agricultural degradation in the Comoros results in a reduction of sector, attention needs to be paid to the age distri- ecosystem service value of about 18 percent (Sutton bution in the farming community. Agricultural inno- et al., 2016), which corresponds to a loss of US$274 vation projects can benefit from actively involving million per year, accounting for 22.5 percent of the the young and unemployed population group on the country’s GDP (Annex 2). Lower land productivity islands, which is currently not included in the agri- caused by land degradation significantly affects cultural sector. By providing education to the cur- agriculture, which is indeed the largest sector of the rent farmers, and the inclusion of this additional country’s economy in terms of contribution to GDP group of young potential workers, the prospect of a and the provision of jobs. more flourishing and sustainable agriculture sector is feasible. The Comoros Emerging Plan (PCE) 2030 aims to address these losses by intensifying the fight against Transformations to reach more sustainable farming land degradation through the establishment of a practices and the promotion of CSA systems rep- program aimed at restoring degraded soils and pro- resent major opportunities for the economy of moting the sustainable maintenance of soil fertility. the Comoros. Capitalizing on these measures and Addressing land degradation is generally econom- opportunities for change would not only enhance ically beneficial in both the short and long terms. soil and land management while contributing to cli- Although no studies on the economics of land deg- mate change mitigation but would also maximize radation in the Comoros have been conducted, a local co-benefits. Indeed, land-based approaches 30-year study on the economics of land degradation for carbon sequestration and CSA and programs in nearby Kenya determined that the costs of action for land management would offer new jobs and against land degradation are about four times lower income opportunities, while reducing widespread than the costs of inaction (Mulinge et al., 2016), poverty and fostering synergies between mitigation implying that every dollar spent on combating land and adaptation in the country. From this perspec- degradation likely generates about four dollars in tive, carbon sequestration needs to be considered return. Even over a short-term period of six years, not only as a tool for mitigating climate change but the costs of action are about three times lower than also as a contributor to soil health, increased food the costs of inaction, representing a very strong eco- security, and thus a sustainable development pro- nomic justification for taking action to address land peller. By sustainably increasing agricultural produc- degradation. tivity, the Comoros can strengthen food and nutrition security and support income generation. To reduce land degradation while increasing the sector’s resilience against the effects of climate change, farmers should receive training and incen- tives to help transition to climate-smart agriculture 5.1.4. Institutional and Legal Context (CSA) practices.12 Various aspects of CSA should be In the Comoros there are currently three contradic- considered, ranging from improved knowledge of tory land tenure regimes that create complexity, smart irrigation options, awareness of local weather low-level disputes over land ownership, and land prediction information, soil conditions, and selec- abandonment. Both the National Agricultural tion of crop varieties that are more resistant to Policy and the National Action Plan to Combat diseases and adapted to the current climatic con- Desertification contain objectives to clarify the land text. Examples of projects that have focused on tenure regime to promote sustainable land manage- implementing CSA systems are provided in Box 10. ment and secure land tenure for farmers. Integrating Specifically, the opportunities agroforestry practices the three systems into a single regime with decentral- can bring on the higher slopes should be further dis- ized tenure securitization would provide legal clarity cussed with local communities. To cope with longer and strengthen social cohesion. The Institutional periods of droughts, nature-based solutions such Capacity Building Project (Projet de renforcement des capacités institutionnelles), financed by the 12  CSA is an integrated approach to managing landscapes— African Development Bank, proposed the establish- cropland, livestock, forests, and fisheries—that addresses ment of a Land Reform Commission to be in charge the interlinked challenges of food security and accelerating of producing a tenure reform roadmap, taking into climate change. CSA aims to simultaneously achieve (1) in- creased productivity, (2) enhanced resilience, and (3) reduced account the land strategy already available after its emissions (World Bank definition). political and legal validation (Sow 2021). | 44 |   Comoros Country Environmental Analysis Box 10. Enhancing Adaptive Capacity for Box 11. Global Climate Change Alliance Increased Resilience to Climate Change in (AMCC) the Agricultural Sector (CRCCA) The general objective of the national program In 2014, the GEF and UNDP donor-funded CRCCA under the European Union Global Alliance project was implemented. The project aimed to against Climate Change (Alliance Mondiale support the Comoros in reducing the vulnera- contre le Changement Climatique) was to con- bility of its agricultural sector to climate change tribute to the efforts made by the Comoros in and weather variability (GEF and UNDP 2019). terms of development and the fight against pov- The main outcomes achieved by the project erty. More specifically, the program focused on were: improving the importance attached to climate change by national and local actors in their • At the national level, adaptation approaches strategies, projects, and mechanisms of plan- for climate change resilience were integrated ning, coordination, and monitoring. One of the with agricultural strategies and sustainable results concerned the production and update development plans. of cartographic data, including high-definition • Farmers received several training sessions on aerial photographs, which made it possible sustainable agriculture and were introduced to update national databases and improve to rural entrepreneurship through the estab- the Geographical Information Systems (GIS) lishment of agricultural pilot farms. These pilot information. Agriculture is one of the key poten- farms support young farmers with modern- tial applications of these images, to obtain, for izing farming practices to move toward larger- instance, more reliable calculations of agricul- scale farming. Examples of modernization tural plots or counting of ylang-ylang plants. include water management for irrigation and This could lead to more accurate assessments of livestock and improvements in accessibility agricultural production and its local impacts on via new infrastructure such as roads. the environment, contributing to the necessary statistics required for further development and • Farmers were supported in terms of skills improvement of practices. The program identi- acquisition, resilient seeds, and access to tech- fied the need for further fundamental studies on nical tools and information. critical ecosystems in terms of productivity as • Four agro-meteorological stations were well as resilience to climate change, and it high- installed to provide weather broadcasts. lighted the potential to test the application of the high-definition images in pilot projects. To scale up the project and build upon its results, priority should be given to supporting rural entrepreneurship through the establishment the NDC 2021 indicates the way forward, as it sets of additional agricultural farms, as well as to three adaptation actions to be implemented for the promoting sustainable agriculture through the agriculture-livestock sector: (1) development of a acquisition of climate-smart agriculture skills climate-resilient and smart agricultural policy, (2) the and the distribution of resilient seeds and tech- development of agro-pastoral irrigation, and (3) the nical tools. The follow-up project should involve establishment of an early warning and effective inter- local NGOs in partnership with local authorities. vention system throughout the country in the event of the emergence of new bovine or caprine diseases. The national legislation of the agricultural sector is In addition, government institutions, agricultural characterized by a food law, a livestock code, a phy- enterprises, and farming communities have lim- tosanitary law, and a plant protection law (MAPETA ited technical capacities and knowledge of the risks 2021b). The World Bank Integrated Development and resulting from climate change. The capacities of the Competitiveness Project (PIDC) is supporting the institutions in charge of the agricultural portfolio are preparation of the text to implement this food law. very weak, with low budgets, limited staff, and limited Nevertheless, this framework does not include sus- understanding of the potential benefits that adaptation tainability considerations, thus raising the need to and mitigation strategies hold for both the economy mainstream environmental issues, including climate and the society. Furthermore, cooperation, coordina- change, in the sectoral legislation. In this regard, tion, and knowledge exchange among institutions Key Environmental Sectors   | 45 | are far from being fully systematized, although some forms of collaboration do exist, such as between the Box 12. Integrated Development and National Institute for Research in Agriculture, Fisheries Competitiveness Project (PIDC) and the Environment (INRAPE) and the National Agricultural Strategy and Livestock Directorate The PIDC is a World Bank project aimed at sup- (DNSAE).13  The World Bank PIDC project is currently porting the competitiveness in targeted Comoros being implemented in the Comoros to address these value chains in three priority sectors: agriculture gaps and strengthen value chains in strategic sectors, (fresh fruits and vegetables, export commodities capacity building of key public institutions, and devel- including ylang-ylang, cloves, and vanilla), live- opment of agriculture and livestock sectors in the pri- stock (dairy and poultry), and tourism. Project vate sector (Box 12). interventions are designed to help the public sector of the Comoros play its role as a provider of public goods (infrastructure, investment pro- 5.1.5. The Way Forward tection, provider of information, and coordina- tion services), and enable market dynamics to • Restore degraded land areas, adopt nature- foster private sector-led growth and develop- based solutions, and scale up agroforestry. On ment. In particular, given the potential of the pri- low-lying plots where soil fertility was lost be- vate sector to create job opportunities, the PIDC cause of soil erosion, restoration actions should aims to supporting micro, small, and medium focus on reestablishing soil fertility and health enterprises with a special focus on empowering and improving yields of food crops that are es- vulnerable and excluded segments of the sential for food security. In upland areas, agro- Comorian population, such as women and youth. forestry practices should be promoted to halt deforestation and soil erosion while contrib- The project aligns with priorities identified in uting to improve and diversify yields. Develop the Systematic Country Diagnostic (SCD), spe- sustainable irrigation strategies and related cifically with regard to addressing the invest- nature-based solutions such as natural water re- ment gap and leveraging national resources in tention measures to reduce agricultural vulner- agriculture and tourism sectors. Furthermore, ability to land degradation. the project aligns with the framework provided by the Accelerated Growth and Sustainable • Expand the uptake of CSA. This would include Development Strategy (SCA2D) and particularly improved knowledge of smart irrigation options, the PCE 2030, which calls for the acceleration of awareness of local weather prediction information, the structural transformation of the economy, understanding of soil conditions, and selection of sustainable management of the environ- more disease-resistant crop varieties adapted to ment, and consolidation of good governance, the current climatic context. including the investment climate. • Build on the results achieved by successful pilot projects (Enhancing Adaptive Capacity for Increased Resilience to Climate Change in the • Ensure that CSA, land restoration, and agricultural Agricultural Sector [CRCCA] and Family Farming innovation programs are carried out through a Productivity and Resilience Support Project participatory process involving local communities [PREFER]) to further encourage the transition to and especially women and young Comorians. This sustainable land use, increase climate change would allow the prioritization of activities sup- resilience, and support rural livelihoods. By ported by the villagers based on their emerging leveraging lessons learned and recommendations perceptions and needs and make communities from successful past projects, sustainable value more aware of land-related environmental chal- chain development and enhanced market access lenges and opportunities. Engaging women in could be promoted, and more farmers could be such programs would be crucial in terms of female trained in sustainable and CSA techniques. empowerment as, despite their importance in the matrilineal Comorian society, they are primarily involved in subsistence  agriculture and are par- Other agricultural institutions include the Ministry of 13  ticularly vulnerable to food insecurity and climate Agriculture, Fishing, and the Environment, in Charge change. Involving young Comorians in agricultural of Energy, Industry, and Handicrafts (MAPEEIA), rural economic development centers, NGOs, community-based activities would also be beneficial in terms of un- organizations, and village development associations. employment reduction. | 46 |   Comoros Country Environmental Analysis of land registration to create incentives to use Box 13. Pilot Project: Land Security land productively and invest in long-term land conservation. “Land Security, ” a pilot project supported by the National Programme for Sustainable Human • Promote capacity enhancement, coordination Development (PNDHD) and PREFER projects in and between relevant land management in- with IFAD financing, has been implemented stitutions, and participatory approaches. This since 2010 in the village of Hamavouna in Mwali. component should be embedded as part of fu- The project is based on the following approach: ture land-management and agricultural support programs, to enhance results and their long- • A landowner makes his land available to a term sustainability. Special attention should be group of farmers for 15 years through a frame- paid to staff and budget allocation. Participatory work agreement sponsored by local authorities. approaches toward sustainable land manage- • During this period, farmers may not plant ment involving local communities, authorities, any illicit crops that impair soil fertility and and other stakeholders is key to developing a farmers should ensure viable management collective vision of sustainable land manage- of the plot, using techniques that are known ment and restauration and achieving sustainable to be adapted to the environment where the outcomes. plot is located. • In return, a notarial deed is issued to the owner, identifying the owner as the “pos- 5.2. Forests sessor” of the land. • An intersectoral Land Commission is set up by the governor of Mwali to facilitate Key Features the implementation of the agreement and ensure respect for the commitments of the • Forests are important habitats of biodiversity stakeholders. and for CO2 storage for the Comoros. They rep- resent an essential source of livelihood and The pilot was successful in increasing agricul- food security for rural communities and have tural productivity, resilience to climate change, the potential to contribute more significantly incomes, and food and nutrition security for to gross domestic product (GDP) if sustainably the farmers involved. As such, lessons learned managed. could be drawn to prepare potential scale-up as a short-term option to yield quick and effective • Natural and planted forests, currently results, including in terms of disincentivizing accounting for 17.7 percent of the total land land abandonment and potentially increasing in the Comoros (World Bank 2020a), provide investment in land ownership whenever pos- many important ecosystem services for the sible. However, it would be important to set up Comorian population. adequate mechanisms beforehand to prevent • In  2020, the Comoros lost  266 hectares of instances of elite capture or corruption. tree cover, equivalent to  136 kilotons  of CO2 emissions. • Support the simplification and decentralization of the land tenure regime, to enhance legal certainty • The forests of the Comoros are declining due and strengthen social cohesion while ensuring to extensive and uncontrolled deforestation transparency. Ensure that the adjusted regime and unsustainable forest management. Illegal operates at the municipality level, leaving the and unreported deforestation and slash-and- established village land committees and the cadi14 burn agricultural practices are also contrib- in charge of customary and religious rights. The uting factors, although no specific data on decentralization of tenure securitization should this exist. be envisaged in the short term, complemented by • The consequences of deforestation are soil adequate capacity building of technical staff and erosion, land degradation, and watershed sufficient funding. In addition, reduce the costs degradation. Additionally, deforestation leads to loss of biodiversity, increased impacts of 14 Local Muslim judge (also spelled “qadi”). Key Environmental Sectors   | 47 | climate change, higher GHG emissions, and Box 14. Deforestation reduced resilience of rural livelihoods. The president of the Comoros recognized • Although Comorians are generally aware of deforestation as a major issue for the country. the damaging consequences of deforesta- During the COP26, he announced to the inter- tion, many are forced to overexploit forest national community his willingness to promote resources due to high levels of poverty. the reforestation of the country, intending to reforest 10 percent of the country’s territory • On Mwali, forests are protected in Mwali and designate 25 percent as a protected area by National Park. Two other areas of forest pro- 2030 (MAPETA 2021). tection, Karthala National Park on Ngazidja and Mount Ntringui National Park on Ndzuwani, are under development. products such as ylang-ylang. Forests also stabilize the soil, thereby preventing erosion, reducing the risk of flooding, and protecting the land from deg- 5.2.1. Sector Characteristics radation. Despite these numerous benefits, it should be noted that forests currently only account for 1.8 As part of the Madagascar and Indian Ocean Islands percent of the natural wealth of the Comoros (World biodiversity hot spot, the Comoros harbors rich Bank 2021d). terrestrial flora and fauna with high levels of ende- mism ( Ibouroi et al., 2021; Myers et al., 2000). The three islands were formally covered with evergreen 5.2.2. Deforestation, Forest Degradation, and tropical forests, extending from the coast to 1,800 Their Drivers meters in altitude. Although the lowland forests up to 500 meters have been mostly cleared, patches of During the past decades, the Comoros has expe- relatively intact montane forest remain above 800 rienced severe deforestation and forest degra- meters in elevation, especially on the southern slope dation. While little intact forest remains, most of of Mount Karthala on Ngazidja, the Maya Forest on the remaining forest is severely degraded, except Ndzuwani, and Mount Mlédjélé on Mwali. Endemic at higher elevations where the terrain is rugged. species include more than 500 plant species, 21 bird Between 1990 and 2020, the Comoros lost approxi- species, nine reptile species, and two fruit bat species mately 13,000 ha of forest area (from 24.75 percent (WWF , n.d.). to 17.69 percent of the total land), corresponding to a decline in forest natural capital per capita of approxi- Forests support the livelihoods of a large share of mately 20 percent (World Bank 2020b, 2021f). In 2010, the Comorian population. For instance, they pro- the Comoros had 132,000 ha of tree cover, extending vide both timber products for construction and fire- over 79 percent of its land area. In 2020, it lost 266 ha wood for household cooking, and nontimber forest of tree cover,15 equivalent to 136 kilotons of CO2 emis- sions (Global Forest Watch 2022). Forest habitat degradation and fragmentation differ across the islands because of the specific habitats, ecological systems, and human demographics of each island. Deforestation and forest degradation are more significant in Ndzuwani and Ngazidja, primarily because of their higher population density compared to Mwali (Goodman et al., 2010). Another reason for lower forest loss in Mwali is the presence of Mwali National Park which, because of its protected status, is less exposed to deforestation. 15 “Tree cover loss” includes change in natural and planted forest and is not necessarily caused by human activities, Women working in the forest in Ndzuwani whereas “deforestation” results from human activity (Global Photo Credit: Deltares Forest Watch, 2022). | 48 |   Comoros Country Environmental Analysis In the Comoros, deforestation and forest degrada- tion are primarily caused by clearance for agricul- Box 15. Terrestrial National Parks tural expansion(see section 5.1), underpinned by deep-rooted rural-based poverty, climate change, The Comoros currently enjoys one operational- and natural disasters, which further exacerbates the ized national park, Mwali National Park, which deforestation process, as more frequent extreme was expanded in 2015 to include approximately weather events and climate hazards add additional three-quarters of Mwali’s land area. In addi- pressure to the country’s forests. Comorians are tion to three marine parks (see section 5.4), two generally aware of the ongoing process of forest additional terrestrial parks are under develop- degradation and its consequences, but many have ment: Karthala National Park on Ngazidja and no alternative but to rely on forests for their live- Mount Ntringui National Park on Ndzuwani. lihood (Ibouroi et al., 2021). It was found that The decision to create additional national Comorians with sufficient income (for example, non- parks is in line with the National Park Strategy governmental organization [NGO] staff, professors, launched by the government in 2017. In addi- agricultural engineers, and other public officials) tion to this strategy, the GoC signed the Law on are less dependent on forests and natural resources the National System of Protected Areas of the than vulnerable groups, especially women, who Comoros in 2018, and established the Comoros are forced to sustain their livelihoods by overusing National Park Agency, although the decrees forest resources (Ibouroi et al., 2021). Thus, there for the individual parks still need to be signed. is a strong link between deforestation and the sub- Mwali National Park represents an important sistence activities of the rural-based poor, who are source of income for local communities due to induced to harvest forest resources to sustain their staff jobs and increased tourism, making local livelihoods. people less dependent on the exploitation of natural resources for their livelihoods (Ibouroi Another major driver of deforestation in the and others 2021). Comoros is wood harvesting, which occurs in a con- text of limited awareness, lack of alternatives, and Despite their status, even in protected areas, inadequate control mechanisms. A large share of the rate of deforestation remains high due to the harvested wood is used for household cooking, the growing demand for wood and arable land as 93 percent of the population relies primarily on (World Bank 2020d). Besides strengthening the fuelwood for cooking (World Health Organization enforcement of the ban on harvesting wood 2019a). The distillation process to produce ylang-y- in protected areas, conservation efforts may lang essence also contributes to wood harvesting, benefit from (1) maintaining sustainable pro- especially in Ndzuwani and Mwali (MAPETA 2021b). duction of forest products to enhance liveli- In the PCE 2030, the Government of the Union of hoods, (2)  establishing local markets to sell the Comoros (GoC) states its intention to reduce forest products, and (3) setting up an aware- the share of wood as an energy source by 60 per- ness campaign and initiatives for reforestation cent by 2030 (Union des Comores 2019b). One of the (Ibouroi and others 2021). obstacles to limiting the use of wood for cooking is Protected areas are an effective means to pro- the high costs of alternative energy sources such tect the ecosystem and biodiversity of the as renewable energy (solar, geothermal energy) Comoros, provided that they are sustain- (MAPETA 2021b). ably managed and enforcement capacities are in place. Between 1995 and 2018, the per 5.2.3. Costs of Inaction and Opportunities capita value of protected areas has increased, indicating the positive development of nat- for Change ural parks and efforts expended to protect Annual loss due to deforestation in the Comoros is natural resources (see also Box 22 on marine estimated at US$2 million  (Annex 2). It should be national parks). noted that both loss resulting from forest degrada- tion and biodiversity loss are not included in the calculation; therefore, the real value is likely to be in indirect losses for the tourism sector as well. The higher. Besides the direct economic costs of eco- current rates of deforestation are threatening the system service losses, deforestation could result islands’ biodiversity, which is one of the main assets Key Environmental Sectors   | 49 | for the potential of the tourism sector (C3-Comores Through the PCE, the GoC aims to promote an 2008; Palerm 2007). agroforestry industry using technologies adapted and accessible to the local population  (Union des Deforestation is also a major cause of soil erosion Comores 2019b). One of the key reasons for farmers and land degradation. Soil erosion leads to increases to be interested in sustainable forest management is in runoff and flooding, thereby reducing soil fertility the economic opportunities arising from the sale of and agricultural yields (World Bank 2020d). Moreover, products such as fruit, wood, and fodder. To make live- deforestation is known to have major impacts on lihoods more resilient, it is fundamental to develop watershed function. In Ndzuwani, almost 40 rivers that a range of climate-resilient local varieties capable flowed permanently a few decades ago have become of providing different environmental services as intermittent, causing severe issues with water scarcity well as diversifying income (Tschora and Cherubini (World Agroforestry 2019). More information about the 2020). The International Council for Research in impacts on watershed function can be found in sec- Agroforestry (ICRAF) identified several options of tion 5.3. Although a large proportion of the Comorian species suitable for cultivation by different types of population is dependent on forest resources, this neg- farmers depending on the varying socioecological atively affects their livelihoods, creating a feedback conditions, which will serve as a useful resource loop (Figure 20) that can only be broken by reforest- (Dumont, Bonhomme, and Mohamed 2021). In addi- ation and targeted investment that offer alternative tion, reforestation activities took place in the past but livelihoods. failed to protect reforested areas from further deg- radation. Therefore, future reforestation programs Agroforestry and reforestation can help reduce the should be accompanied by strategies aimed at sus- effects of anthropogenic activities on vulnerable tainably protecting replanted trees (MAPETA 2021b), primary forests and help halt forest degradation. as well as by awareness-raising campaigns and Traditionally, land management involves agroforestry capacity building on the benefits of sustainable forest practices that are well integrated with food crops. management and use. To prevent erosion and restore watershed functions, reforestation programs should be carried out in stra- To limit further deforestation, a forest zoning plan tegic locations where the livelihoods of local commu- should be incorporated into islands’ land-use plans. nities can benefit the most, with special attention to Such plans should recommend agroforestry, refor- the role Comorian women can play in these activities. estation, and protection of natural forest resources. Degraded areas should be replanted with local tree Buffer zones could be created around primary forest species, such as fruit trees, that can be valuable for the areas to better protect them and facilitate effective economy. participatory management with local communities. In buffer zones, agroforestry can help to provide sus- tainable livelihoods and create protection for the more vulnerable inner zone of protected forest. Outside the Figure 20.  A vicious cycle of poverty and deforestation. buffer zones, more intensive yet sustainable land-use practices can be stimulated. Poverty The Comoros has developed a land-use plan for the island of Mwali. This territorial planning document aims to determine major direction over the next 20 Dependence on years (MAPETA 2021b). Building on Mwali’s land-use Unstable and low rural incomes harvesƟng forest plan, the GoC should develop similar plans for each resources island. For example, the planting zones for ylang- ylang plantations should be restricted to the lowlands below 200 meters in altitude. Between the planta- tions, sufficiently large pockets of protected dry forest should remain in critical areas to prevent erosion Soil erosion, land DeforestaƟon and and sustain watershed functions. Between altitudes and watershed degradaƟon forest degradaƟon of 200 meters and 300–400 meters, diverse agrofor- estry practices can be expanded because they benefit the environment through the conservation of soil and Source: Deltares. | 50 |   Comoros Country Environmental Analysis water supplies, as well as the livelihoods of the people conservation and management, although their roles who depend on the forest through diversifying their and mandate are not clearly defined. The forest income sources (World Bank 2019b). Above 300–400 department of the DGEF suffers from a lack of ade- meters, the natural forests should be protected in quate capacity, as well as of financial and human national parks managed by trained rangers. resources. In addition, the absence of an opera- tional technical department of forests in the DGEF Reforestation would benefit from integrating both hampers the implementation of planned meas- scientific and local knowledge. It would be critical ures. At the municipal level, the lack of capacity to enhance scientific knowledge by improving forest and human and financial resources is a consistent inventories, data collection, and site monitoring to constraint. During recent stakeholder consultations better understand the ecological functions of trees conducted in the development of this CEA, the rela- at the landscape scale in the Comoros. At the same tionship between the GoC and NGOs was mentioned time, local forest communities often have sophis- as a liability to some extent for sustainable forest ticated knowledge about, and experience with, management. their local environment (World Agroforestry 2019). Moreover, given the aforementioned link between There is currently no practical and operational frame- deforestation and subsistence activities carried out work or control system for wood harvesting, and by rural poor, the National Environmental Policy no administrative structure is empowered to mon- (PNE) attaches great importance to involving vulner- itor this activity. Although there are bans on wood able groups in decision-making processes regarding harvesting in the national parks and restrictions on the management of forest resources, both in terms of wood harvesting in some areas, there is no legal fol- exploitation and preservation (MAPETA 2021b). low-up that can lead to convictions of offenders who cut down trees without authorization. Although some Reforestation in the Comoros could provide several local communities and municipalities have success- benefits and incentivize people to support and con- fully taken responsibility for imposing restrictions tribute to reforestation actions. Reforestation can on wood harvesting, these restrictions are often not trigger benefits in terms of protection and con- enforced. servation of water supplies, fuelwood and timber, nontimber forest products, and increased crop yields. Even though forests represent such an important In particular, access to water has been identified as aspect of Comorian livelihoods, there have been no a key ecosystem service, especially on Ndzuwani major projects from international donors with a spe- (Doulton et al., 2016). Through community-level refor- cific focus on forests. Instead, forests have comprised estation programs, farmers and other stakeholders only a small component of projects relating to agricul- can contribute to improving the drinking water supply ture or water ecosystems. To better incorporate sus- through reforestation around rivers and water collec- tainable forest management in future development tion points. Based on their experience, farmers dem- plans for the Comoros, it is strongly recommended to onstrated detailed knowledge about how different consider forests as a central aspect and treat it within tree species affect water cycles. the context of an integrated landscape management approach (see chapter 6). 5.2.4. Institutional and Legal Context The Forest Management Law (12-001/AU of 2012) dic- 5.2.5. The Way Forward tates the parameters of sustainable management and conservation of forest resources. It governs forests • Develop and implement land-use plans for both at the public and private levels. However, the law Ngazidja and Ndzuwani to protect the natural has not yet been finalized, and the existing texts do forest resources and stimulate reforestation. not adequately integrate sustainable forest conserva- Apply a zoning approach using the following zones: tion and management considerations. (1) agricultural zones (for ylang-ylang plantations), (2) agroforestry zones for sustainable produc- Although forest conservation and management fall tion, (3) zones for protected dry forests to prevent completely under the mandate of the GoC (General erosion and sustain watershed functions, and Directorate of Environment and Forests [DGEF]), (4) natural forests in national parks. Apply the numerous other actors are involved in forest same zoning approach to the Mwali Land Use Key Environmental Sectors   | 51 | that 93 percent of the population depends on Box 16. One Comorian, One Tree fuelwood for cooking. Sustainable production of forest products should be promoted (such as From 2022 through 2025, the GoC and UNDP , nontimber forest products), and the establish- supported by GDF and GEF , launched the “One ment of local markets should be facilitated. In Comorian, One Tree” project, a broad refor- parallel, awareness campaigns should be carried estation program to protect watersheds and out to sensitize local populations on the benefits accelerate the achievement of the country’s of reforestation and sustainable management NDC objectives. The campaign aims to plant and use of forests. 613,000 new trees on 571 hectares throughout the country. Integrating this initiative through a • Improve forest inventories, data collection, and ridge-to-reef approach could benefit the imple- site monitoring. The data made available will be mentation of the campaign by leveraging inter- instrumental in supporting adequate sustainable actions between production systems and natural forest governance and management strategies. forest areas. • Finalize the Forest Management Law and in- tegrate sustainable forest conservation and Plan, which was completed and validated by management considerations in the legislative the Government Ministerial Council on May framework. Support the implementation of the 11, 2022. Combine this strategy with an inte- Forest Management Law specifically via training grated landscape approach to ensure that all of inspections and equipment. Focus training activities in the area work in complementarity on field patrolling and facilitate the acquisition and that each specific zone is used for the pur- of equipment such as four-wheel drive vehicles, pose for which it is designed. Ensure consist- motorbikes, and communication tools. ency and exchange of data and information between the three land-use plans to stimulate • Support the enhancement of the capacity of cooperation and efficient use of funding. national and regional directorates to monitor the implementation of environmental and natural re- • Officially operationalize two additional terrestrial source regulations and policies. This objective national parks to enhance the effective protec- requires supporting an increase in human and fi- tion of the forest cover of the Comoros. The ini- nancial resources allocated to the directorates, as tiative follows up on the proposal included in the well as improving their technical and operational National Park Strategy adopted in 2017 and the capacities. pledge made at COP26 to designate 25 percent of the territory as a protected area by 2030. The parks should adopt a participatory co-management ap- 5.3. Water proach similar to the one successfully piloted in Mwali National Park. Operationalizing these two additional terrestrial national parks would also contribute to the protection of biodiversity and re- Key Features sult in positive spillover effects for the potential of • Water is an essential contributor to the NBT (section 5.6). Comoros economy and livelihoods. • Restore degraded areas by replanting local trees, • Water availability varies among the islands. particularly trees that offer economic benefits Ndzuwani and Mwali depend on surface and opportunities to diversify incomes of local runoff from perennial or intermittent rivers communities. Reforestation programs should be and groundwater in coastal areas. Ngazidja integrated into a sustainable landscape manage- relies on the collection of rainwater inland and ment approach in which local communities are in- groundwater in coastal areas, as there is no volved in both the planning and decision-making surface water. processes. As stated by the president of the Comoros during COP26, where he committed to • Although, in theory, water is an abundant reforesting 25 percent of the country’s territory, resource in the Comoros (World Bank 2021c), reforestation programs could also be envisaged current levels of water supply are insufficient with the objective of fuelwood production, given | 52 |   Comoros Country Environmental Analysis in Ndzuwani, classified as a Ramsar site, is con- to meet the needs of the Comorian population, sidered the main source of several rivers. Lake Dziani particularly given increasing demand for water Boundouni in Mwali, also a Ramsar site, is the lar- driven by population growth. gest freshwater body in the Comoros (AFD 2018). Underground aquifers have been found on all three • Water quantity and quality have distinct chal- islands but have not been extensively studied except lenges. In Nzwani and Mwali, permanent for Ngazidja, where part of the aquifer is exploited. rivers are becoming temporary, and tempo- There are no large dams or reservoirs in the Comoros rary rivers are becoming ephemeral due to and no major natural lakes. There is also almost no land degradation, reduction in forest con- irrigation on these islands—only 300 ha are irrigated servation and land rehabilitation, climate in Nzwani and Mwali islands. change, and inadequate infrastructure invest- ments (for example, water storage and con- Although in theory water is an abundant resource veyance systems). in the Comoros (World Bank 2021c), current levels of water supply are insufficient to meet the needs of • Access to safe drinking water in the Comoros the growing Comorian population. The Comoros is is very low, with 2020 levels estimated at 15 a country with significant water potential from sur- percent. Incomplete regulatory frameworks, face water resources in Mwali and Ndzuwani and monitoring systems, and coordination mech- groundwater resources in Ngazidja, but only about anisms are also hampering the develop- 2 percent to 3 percent of the total water resources ment of an efficient potable water network. are used annually (Table 10). The Comoros is con- Improving the drinking water supply is one of sidered a water-stressed country, with 1,474 m3 of the State’s key priorities. renewable water resources per capita (Figure 22) • The coordination of different levels of gov- —below the water-stress threshold of 1,700 m3 per ernment (national, island, and local levels), capita established by the UN.16 Although the total across sectors, and with the participation of volume of renewable water resources remained con- multiple stakeholders including vulnerable stant from 1962 through 2017, the country experi- communities, is fundamental to implementing enced a steady decline in per capita renewable water Integrated Water Resources Management resources. Water scarcity results from a combination (IWRM) in the Comoros. of factors, including rising demand driven by popu- lation growth, inadequate water management, inad- • The health and well-being of the Comorian equate human activities, land degradation, climate people require increased access to safe water change, and high operational costs. Water scarcity and sanitation. goes hand in hand with increasing water degradation, which is primarily related to polluting human activities and poor infrastructure. A more detailed description is provided below. 5.3.1. Sector Characteristics The Comoros presents significant information The primary water sources in the Comoros are gaps on key indicators for the development of evi- surface water, rainwater harvesting, and ground- dence-based decision-making, investment decisions water, though with significant inter-island variation and, ultimately, sustainable water and sanitation according to each island’s characteristics. Rainfall management. This includes data on the availability varies considerably from one island to another, as well of surface water and groundwater, the physical and as within each island, due to differences in altitude chemical characteristics of the water, and ease of and wind (World Bank 2021b). The natural drainage access to drinking water and sanitation services, espe- systems on each island depend on their geological cially in urban settings. Furthermore, the country has characteristics and soil composition. In Ngazidja, 95 no updated information on the impact of water, sani- percent of the rainfall infiltrates underground due tation, and hygiene (WASH) issues on health, with the to the high permeability of volcanic soils and asso- most recent figures dating back to 2004. ciated rock fissures. This results in the absence of a surface hydrographic network and an abundance of groundwater resources. Unlike Ngazidja, Ndzuwani and Mwali have surface water bodies (Figure 21),  quastat database: https://www.fao.org/aquastat/statistics/ 16 A although many of these rivers have been drying up, query/index.html;jsessionid=BCF25C6FC52B9ED24088E- as described in more detail below. Lake Dzialandzé 4D050984E7C Key Environmental Sectors   | 53 |   Maps of the 44 watershed basins on Ndzuwani (left) and 25 watershed basins on Mwali as identified in the National Figure 21. Water Strategy and Program. N N Echelle 1:14000 Echelle 1:12000 Source:  GCF and UNDP 2018a. 5.3.2. Water Scarcity, Degradation of Water basis and there is currently neither an active ground- water management program to monitor salinity and Quality, and Their Drivers pollution risks nor a plan for the sustainable use of Groundwater groundwater resources. However, there are ongoing initiatives to increase understanding of groundwater Access to groundwater remains a challenge. The resources in Ndzuwani and Mwali. For example, Comoros has small watersheds (less than 4 square the University of the Comoros is working with the kilometers on Ndzuwani, less than 2 square kilo- national company for water distribution, Société meters on Mwali, and on Ngazidja very small but Nationale chargée de l’Exploitation et la Distribution with exact dimensions unknown) and aquifers, des Eaux aux Comores (SONEDE), to monitor ground- which means that the country has little natural water water salinity levels in pumping wells. The national storage capacity. The steep terrain in the islands, par- university hosts the national water quality laboratory ticularly in Ngazidja, limits access to groundwater, and is the main knowledge base for groundwater in as the higher elevation requires increasingly deeper the country (GCF and UNDP 2019b). drilling to reach the groundwater table, which is gen- erally associated with high operational costs. This constraint is particularly concerning, considering that 90 percent of the total renewable water resources Surface Water in Ngazidja come from groundwater resources. There are no surface water bodies in Ngazidja, which Regarding Ndzuwani and Mwali, groundwater plays a makes the island primarily dependent on ground- fundamental role in the water supply to coastal areas, water and rainfall harvesting, but Ndzuwani and particularly during the dry season. Groundwater Mwali have perennial and temporary streams. For abstraction wells occur up to 2 to 3 kilometers from its water supply, Mwali relies on the availability of the coast and are prone to saltwater intrusion. In perennial variable rivers and has a clear river net- addition, despite their high salinity, they continue to work divided into three zones: an upstream, torren- be used for irrigation, livestock, or washing (Comte tial zone with rapid flow; an intermediate piedmont et al., 2016). Groundwater is exploited on an ad hoc zone, with a lower slope and medium or slow flow; Table 10.  Volumes of renewable water resources and their exploitation rates per island Total Renewable Renewable Surface Renewable Resources Water Groundwater Resources Surface Water Groundwater Island (billions m3/yr) (billions m3/yr) (billions m3/yr) Exploited (%) Exploited (%) Ngazidja 1.254 0.124 (10%) 1.130 (90%) 1.9 0.5 Ndzuwani 0.514 0.213 (42%) 0.299 (58%) 2.3 0.6 Mwali 0.117 0.078 (67%) 0.038 (33%) 1.2 0.5 Source:  Tshimanga 2015. | 54 |   Comoros Country Environmental Analysis Figure 22.  Trend in renewable water resources per capita (cubic meters/inhabitants) in the Comoros from 1962 to 2017. ϳŬ ϲŬ ƵďŝĐŵĞƚĞƌƐƉĞƌLJĞĂƌ ϱŬ ϰŬ ϯŬ ϮŬ ϭŬ ϲϮ ϲϳ ϳϮ ϳϳ ϴϮ ϴϳ ϵϮ ϵϳ ϬϮ Ϭϳ ϭϮ ϭϳ ϭϵ ϭϵ ϭϵ ϭϵ ϭϵ ϭϵ ϭϵ ϭϵ ϮϬ ϮϬ ϮϬ ϮϬ tĂƚĞƌƌĞƐŽƵƌĐĞƐƉĞƌĐĂƉŝƚĂ Source:  World Bank Group 2022. and a more or less extensive delta zone, where the UNDP 2018a). In Ngazidja, approximately 60 per- flow is slow to stagnant and mangrove vegetation cent of households use private and/or public rain- sometimes develops. Ndzuwani is currently facing water tanks. While during the wet season rainwater the serious problem of the disappearance of its sur- harvesting is enough to meet the needs of Ngazidja’s face water resources resulting from climate-induced population, during the dry season, water use tends to and human-related factors (Figure 23). While 49 per- be rationed. Changes in rainfall and temperature pat- ennial watercourses were listed in 1950, in 1970, only terns, such as prolonged dry seasons, are affecting about 30 remained. By 2005, data indicated that this the availability of rainwater resources available number had decreased to about 10 watercourses to end users. In addition to fluctuations in rainfall (Trenchard 2020).  This was due to a combination and temperatures, rainwater harvesting is subject of factors, including changes in rainfall patterns, to non-climatic hazards. For instance, the volcanic increasing temperatures, and extensive deforestation ash fallout from the Mount Karthala volcano is an and degradation of watersheds (see section 5.1) that ongoing threat to the quality of harvested rainwater. have disrupted waterways and caused soil erosion (Charmoille 2013). There is minimal water storage Drinking Water within the surface water distribution systems, and water supply is located far from instantaneous flow Although access to basic drinking water supply serv- schemes (GCF and UNDP 2018b). The shores of Lake ices was at the relatively high rate of 80 percent in Dzialandzé in Ndzuwani and Lake Dziani Boundouni 2019 and above the Sub-Saharan African average of in Mwali are used by breeders and farm livestock, 75 percent, the Comoros is still far from achieving resulting in higher pollution of these water bodies safely managed standards,  as only 65 percent of the (AFD 2018). Despite these challenges, the existing population has access to drinking water on their prem- surface water resources on Ndzuwani and Mwali ises (63 percent in rural areas against 71 percent in have sufficient excess capacity to meet the needs of urban areas) (WHO and UNICEF 2021). While access the population and sustain their livelihoods. to basic drinking water is relatively high, access to basic sanitation services lags behind and appears to be a neglected area for investments. Current access Rainwater Harvesting to sanitation services is 36 percent, which is above the Sub-Saharan African average of 28 percent but While rainwater harvesting is reportedly minimal far behind the world average of 78 percent (WHO and in Ndzuwani or Mwali, the inland communities in UNICEF 2021). Ngazidja, which account for half of the island’s pop- ulation, depend primarily on rainwater harvesting Water consumption is mostly limited to the strict due to the absence of surface water bodies and lim- minimum for daily needs (drinking, cooking, and ited access to groundwater on the island ( GCF and washing for hygiene). The household survey Key Environmental Sectors   | 55 | Figure 23.  Map showing permanent waterways in 1955 and 1973 in Ndzuwani. Legend Permanent watercourses (IRAT, 1973) Permanent watercourses (IGN, 1955) Drainage basins Source:  Astudillo 2012. conducted by Comte et al. (2016) in Ngazidja esti- up in vulnerable settlements, where land is leased to mated that 45 percent of households surveyed (mean them informally, often without connections to water household size of six people) used 20–100 liters per or sanitation networks. While 84 percent of Fomboni day per household (4–16 liters per day per person), and 80 percent of Mutsamudu residents have access falling short of the basic water requirements of 20 to water from their houses, only 29 percent of house- liters per person per day recommended by the World holds are connected to the water grid in Moroni. In the Health Organization (WHO). A further 18 percent used capital, public fountains are the main source of water 120–200 liters per day per household (20–33 liters per (over one-third of households use them), while in the day per person); although this might be considered rest of Ngazidja, households rely primarily on private “reasonable access, ” is still below the WHO guidelines tanks and reservoirs for their water supply.17 of 50–100 liters of water per person and far below the optimal accessibility of 100 liters per person per day Acknowledging the importance of the urban dimen- on average. Water consumption for half of the popula- sion to water and sanitation management, the tion of Mutsamudu in Ndzuwani was reported to be as “urbanization reimagined” structuring project of the low as 11 liters per day per person (Tshimanga 2015). PCE 2030 has a strong focus on developing municipal For households that can afford it, fresh water from infrastructure to improve rainwater sanitation, m obi- 54 wells on Ngazidja is distributed by water trucks to lize deep-water resources, and promote drinking water approximately 20 localities (or 35 percent of the pop- at the national level. In particular, consistent with ulation) (Comte et al., 2016). This service has been the National Drinking Water Supply and Sanitation on the rise during the last decade and has become a Strategy (AEPA), the PCE envisages the development highly lucrative business. of a master plan for rainwater sanitation, the imple- mentation of rainwater sanitation projects in Moroni, Although access to water is generally higher in urban and the deployment of alternative rainwater manage- areas than in rural areas (2019 access to basic water ment techniques based on infiltration and storage of was equal to 77 percent in rural areas against 88 per- weather-related water in all other agglomerations of cent in urban centers), cities are not equipped with 5,000 or more inhabitants. In addition, drilling will water and sanitation facilities to keep up with the be carried out and drinking water systems will be needs of the growing population,further contributing strengthened or built in cities and villages to expand to environmental degradation as well as to the likeli- access to drinking water. hood of diseases. Because of the limited availability and, consequently, higher costs of residential land in the capital, 56 percent of urban migrants have set 17 World Bank, 2021c. | 56 |   Comoros Country Environmental Analysis The underlying causes of the lack of drinking water whether individual or collective, has often proved to are multiple and varied, ranging from inadequate be unsafe due to bacterial contamination, the prolif- water infrastructure to insufficient storage capacity, eration of mosquitoes, and the presence of waste and poor water management, inadequate financing, and dust, among other contaminants, thus increasing the weak sectoral governance ( Figure 24). In addition to risk of waterborne diseases. According to the vulnera- the factors already discussed in chapter 4, the impact bility study conducted by AFD (2018), the main climate- of limited public financial resources is compounded induced risks for water resources do not concern water by the lack of interest by the private sector in investing quantity, but rather the deterioration of water quality in water supply, as well as by the current water tariff through the impacts of storms on watershed damages. system, which fails to achieve sufficient recovery Issues of water quality are compounded by the lack of returns to maintain and upgrade water infrastructure adequate and frequent monitoring of physicochemical (GCF and UNDP 2018b). and microbiological levels, which are often limited to once per week and in only a few locations. Furthermore, the country lacks protected water intakes and efficient distribution systems, both from A major constraint for improving drinking water in the an infrastructural and technological standpoint. The Comoros lies in the inadequate financial resources water supply service providers are currently unable allocated to investments in drinking water distribu- to guarantee adequate levels of operation and main- tion, maintenance of infrastructure, and wastewater tenance of the existing water supply infrastructure. treatment. To date, most projects addressing the In the urban and peri-urban region of Ngazidja, only drinking water supply have been financed by inter- 34 percent of the water volume is metered. Water national donors. The amount of official develop- leakage from the supply network is not sufficiently ment assistance (ODA) disbursed by donor agencies monitored but is estimated to be approximately 50 for water- and sanitation-related projects from 2001 percent on Ngazidja and Ndzuwani. Furthermore, through 2019 accounts for US$68 million (Figure 25). because of the volcanic nature of the islands, the high According to Accelerated Growth and Sustainable cost of exploring and exploiting underground sources Development Strategy (SCA2D), the costs of reduces the return on investment and limits access to implementing the drinking water supply program water for the poorest. were estimated at 30 billion KMF (US$64 million), 400 million KMF (US$0.85 million) for strengthening the In addition to having limited availability, drinking water monitoring and regulatory mechanisms for hygiene in the Comoros is of poor quality. In fact, water storage, and sanitation; and 1,600 million KMF (US$3.42 Figure 24.  The causal chain analysis of “poor access to drinking water”. Root Causes Intermediate Causes Immediate Causes Low income to connect to the water supply infrastructure Low connection rates of households Insufficient and failing water supply infrastructure Weak commitment Non-profitable water of the State Influence of tradition infrastructure management Social organization Distributed or collected water is POOR ACCESS TO Weak water Faulty water treatment untreated DRINKING governance WATER Unsanitary environment Insufficient and faulty Weaknesses of drinking water Associations, NGOs, media and Insufficient provisioning installations, sometimes educational over long distance destroyed during structures community conflicts Low capacities for initiative and organizations of communities and associations Poor conservation of Water stores in uncovered cisterns harvested water and other unsuitable containers Source:  Adapted from DGEME 2014. Key Environmental Sectors   | 57 | Trend in the amount of water- and sanitation-related official development assistance as part of a government-   Figure 25. coordinated spending plan from 2000 to 2020. Amount of water- and sanitaƟon-related official development assistance that is part of a government-coordinated spending plan 10 Millions constant USD 8 6 4 2 0 2000 2005 2010 2015 2020 Source:  UNSTATS 2022. million) for the installation of a drainage system for The GoC has committed to co-fund the operating and wastewater and rainwater. This amounted to a total maintenance costs for water supply for 15 years, during of 32 billion KMF (US$68 million) for 2018–2021. The which time water quality monitoring and water supply SCA2D indicated that 40 percent of the costs of the delivery will be demonstrated to the beneficiaries and drinking water supply program (12 billion KMF) were tariffs will be introduced in a staged approach. In this secured through the national budget, a further 11 regard, awareness raising among Comorians will be percent (3.3 billion KMF) were covered by technical needed about the costs required for water services, and financial partners and public-private partner- transportation, cleaning of reservoirs, and other cost- ships (PPPs) collectively, whereas the rest (14.7 bil- related factors. lion KMF , equivalent to 49 percent) was unsecured. In addition to insufficient financial resources, other key To date, improvements to drinking water supply challenges for water management in the Comoros and sanitation have been marginal. According to are related to the limited coordination of donor aid, the WHO and UNICEF Joint Monitoring Program to which is the result of insufficient human, technical, Water Supply, Sanitation and Hygiene, a decrease in and financial resources on the government side and access to at least basic water supply was observed lack of representation in the country on the donor during the last two decades from the highest level side. Indeed, interventions in the water and sanita- of 91 percent in 2000 to 80 percent in 2019.18  This tion sector, whether through community initiatives, decline is partially linked to the limited investment associations, NGOs, local authorities, the State, pri- to extend the service to a rapid growing popu- vate operators, or development partners, remain lation, which increased from 542,000 to 851,000 modest and largely uncoordinated. during that period. However, access to basic sani- tation (improved and not shared) services increased The GoC has recognized that the collection of from 29 percent in 2000 to 36 percent in 2019. The increased water tariffs will be a socially sensitive Voluntary National Report on the progress of the issue until the population starts receiving water of implementation of the Sustainable Development improved quality. While populations pay by volume Goal (SDGs) (Comoros Ministry of Foreign Affairs in the Moroni region, on Ndzuwani and Mwali, the 2020) confirmed that in terms of access to sustain- water user associations (WUAs) charge a fixed tariff ably managed water supply and sanitation serv- of 1,000 KMF (US$2.2) per month for water that is ices, the situation remains problematic, especially not potable. In the dry season, rural villagers obtain in rural areas, thus jeopardizing the achievement water from the town’s water supplies: a container of the objectives of SDG 6 (Table 11). The main chal- of 20 liters of non potable/nonsterilized water costs lenges to ensuring full access to safe water supplies 250–500 KMF (US$25–US$50/m3) in Ngazidja and 25 KMF (US$2.5/m3) in Ndzuwani. The difference in cost 18 World Health Organization and UNICEF Joint Monitoring Pro- reflects the higher quality of water in Ngazidja and the gram to Water Supply Sanitation and Hygiene, 2022. Como- greater degree of poverty in Ndzuwani (UNDP 2022). ros. Available at: https://washdata.org/data/downloads#COM | 58 |   Comoros Country Environmental Analysis include the mobilization of groundwater resources and safeguarding proper water storage. In urban Box 17. Access to Drinking Water as a High areas, drinking water supply relies on the refurbish- Priority ment and extension of the distribution networks, whereas in rural areas, access should be ensured Ensuring the supply of drinking water to the through water points (for example, public fountains, population has been a priority of the govern- wells, boreholes) in villages. ment development policy for nearly 20 years. As part of the Drinking Water Supply and Sanitation Project (DWSSP) (2010–2016) funded by the 5.3.3. Costs of Inaction and Opportunities for African Development Bank, the AEPA was devel- Change oped in 2014 to provide the institutional, organi- zational, and financial framework for addressing Water scarcity and degradation of water quality, com- the challenge of “establishing an efficient, pounded by natural factors that limit water access, accessible and equitable water management impede economic growth. Since approximately half system, meeting the needs of the population in of water use is for agricultural purposes (Figure 26), terms of drinking water and sanitation, in partic- water scarcity, alongside increasing aridity and soil ular of the most vulnerable such as small-holder degradation, has a dramatic impact on agricultural ” by 2030 farmers that rely on rainfed agriculture, productivity, given an agricultural water deficit that can (Programme Solidarité Eau 2022). This is in line last up to six months (GCF and UNDP 2018a). Given with the main targets of SDG 6, mainstreamed the Comoros’ mainly rainfed agriculture, changes in in the Strategy for Accelerated Growth and weather patterns significantly affect agricultural pro- Sustainable Development (2018–2021) and the ductivity, while also increasing the risk of uncontrolled PCE (2020–2030). forest fires. Water scarcity also has implications for women and girls, traditionally in charge of collecting To achieve these objectives, the national pro- water, who must travel long distances to access safe gram proposed by the SCA2D aimed to: water resources (GCF and UNDP 2019a), resulting in a reduction in the time they are available to actively • Review the institutional, regulatory, and finan- participate in the labor market or attend school. It is cial framework of the drinking water supply estimated that women and girls spend up to two hours and sanitation (DWSS) sector to enhance a day fetching water, implying a 25 percent reduction efficiency in time available for work (based on an eight-hour • Mobilize, protect, and monitor water resources workday).19 Other impacts include reduced fish pro- • Improve drinking water infrastructure to pro- duction caused by polluted freshwater influxes, health vide access to drinking water to the entire issues related to waterborne diseases, and threats to population political stability resulting from the spillover effects of competition over water resources, as occurred in May • Promote sanitation to raise the level of hygiene 2022 in the village of Hoani in Mwali.20 • Strengthen the capacities of stakeholders and partners for efficient and sustainable DWSS While demand for drinking water has grown consid- services erably as a direct result of population growth, water and sanitation infrastructure has not kept up with The SCA2D also proposed to establish a realistic growth. Access to water and sanitation services in the policy of cost recovery to ensure the economic Comoros remains problematic, particularly in rural viability of drinking water supply and public serv- areas, resulting in higher health risks for the popula- ices, and to support local authorities and com- tion. Indeed, limited access to clean and potable water, munity organizations in their efforts to set up the hygiene, and sanitation is a primary cause of child local water supply and sanitation systems. mortality as it is associated with health issues and diseases such as typhoid fever, diarrhea, and various water-borne diseases. The mortality rate attributed services was 50.7 per 100,000 population in 2016 to exposure to unsafe water, sanitation, and hygiene (WHO 2019a). Unsafe WASH is directly linked to sanitation-related 19 UNICEF , 2016. Annual Report Comoros. Available at: https:// sites.unicef.org/about/annualreport/files/Comoros_2016_ diseases (primarily diarrheal diseases). Disability- COAR.pdf adjusted life years (DALYs) attributable to WASH 20 La Gazette des Comoros, 23 May 2022, N. 4129. issues in the Comoros were approximately 8,750 in Key Environmental Sectors   | 59 | 2004 (WHO 2013). In children under five years, WASH- of the IWRM approach are being proposed in the attributable DALYs were approximately 5,700 in 2004. Comoros (MAPETA 2021a). Box 18 provides an over- More recent data are not available. The total cost of view of three recent projects that have adopted an measures to advert DALYs attributable to unsafe IWRM approach. WASH is US$40.8 million (see Annex  2). In addition to the impact on human well-being and health care costs, WASH issues result in higher costs for other 5.3.4. Institutional and Legal Context sectors as well, although no specific estimates are Water is a cross-sectoral issue that is embedded in available. Unsafe water results in high water treat- the mandate of multiple ministries and regional and ment costs and more time spent by households to local institutions, which makes the Comoros insti- treat drinking water. tutional framework for water resource manage- If managed sustainably, the water resources of the ment more complex. The General Directorate for Comoros can play a crucial role in the ecosystem, live- Energy, Mines and Water (DGEME) is the main state lihoods, economy, and reduction in gender inequality institution responsible for water resource manage- (Comoros Ministry of Foreign Affairs 2020). Water bal- ment. The National Water and Sanitation Directorate ance estimates show that on the islands of Ndzuwani (DNEA) under DGEME is responsible for designing and Mwali, the existing surface water resources have and implementing national water resources and water sufficient excess capacity to meet the needs of the supply and sanitation policy, regulation, and sectoral population and its growth. This indicates that under planning. At the regional level, each island has its proper management, the country’s available water Regional Directorate of Water and Sanitation (DREA), resources would be sufficient to meet the per capita which is supported by the DNEA in regulating the water need. water sector. Another important opportunity for improvement As part of decentralization, water competences have may arise from increasing the frequency and effec- been transferred to the 54 municipalities of the three tiveness of water quality monitoring. An inventory of islands. In Ndzuwani and Mwali, water management the drinking water resources and groundwater aqui- has been gradually shifted to the village communi- fers should also be carried out by national author- ties which have federated around the WUAs; how- ities in coordination with island and local authorities. ever, they are constrained by limited capacities in An important step in this direction is represented by maintaining and operating water infrastructure or a new laboratory reportedly currently under construc- equipment. In the rural areas of Ngazidja, there is tion as part of INRAPE. no structure similar to that in Ndzuwani or Mwali, greatly limiting progress on water management. In addition, despite recent progress, the effective- Against this backdrop, the absence of a regulatory ness of the implementation of water management framework clearly defining the roles and respon- programs could be further enhanced through better sibilities between the GoC, and the island entities coordination. Solid public communication campaigns adds another layer of complexity to the water- are also required to sensitize local populations on the management architecture of the Comoros (UNDP importance of consuming safe drinking water, the 2022). This calls for national- and island-level agen- benefits of paying for consumption, the value of water cies to improve the coordination of planning, pro- as an economic good, and the costs associated with gramming, and budget allocation, and to overcome the development of water infrastructure. the existing institutional fragmentation. Adoption of an integrated water resource manage- The Water Code of 1994, which established the ment (IWRM) approach would create opportunities founding principles of the Comorian water policy, was for change. An integrated approach would bring about revised in 2020. The newly revised water code lays the coordinated development and management of out the necessary reforms to improve water resource water, land, and related resources to maximize eco- management, in particular the harmonization of nomic and social welfare in an equitable manner procedures across all islands, the extension of the without compromising the sustainability of vital authority of SONEDE to the urban areas of Ndzuwani ecosystems. IWRM is also crucial for the Comoros and Mwali, and the adoption of a more effective and to address climate impacts on both water and food efficient institutional arrangement for delivering more security in an interconnected way, although the lack reliable water supplies. It addresses gaps related to of data and information on water resources limits access to high-quality water, agricultural use of water, sound planning. The dissemination and adoption and IWRM, setting the course for more equitable use, | 60 |   Comoros Country Environmental Analysis Table 11.  Progress on SDG 6 indicators Source:  Sachs et al., 2021. Figure 26.  Water use in the Comoros (2016). Industry 5 Municipal 45 50 Agriculture Source:  AMCOW 2018. the protection of water resources, and allowing for government is considering the revision of the AEPA decentralized and participatory development of water 2013-203014 and the Strategic Framework document resource management. to align with the PCE 2030 and the new Water and Sanitation Code. The newly revised water code mandates tariff reforms for the service providers of water supply The updated water code is a step in the right direc- as part of the ongoing reform of water governance, tion, but the Comoros still has room to further improve which aims to improve the sustainability of the water the institutional and legal context. Strategic prioritiza- sector. Nevertheless, this process is still in its very tion at the national level for the water resource, water early stages, and it is difficult to foresee the magni- supply, and sanitation sectors with a focus on hydro- tude, timing, and reliability of revenues from water climatic risk management can guide development tariffs. The code also envisages the creation of a and help operationalize important reforms and coor- National Fund for the Development of Water and dination among the different agencies at the national, Sewage Infrastructure (FNDIEA), although it offers island, and local levels. Master plans at the island level only broad indications of the sources of funds and can help identify and prioritize concrete infrastructure the management and supervisory structure (UNDP investments, enable land stewardship, and coordinate 2022). In 2015, the GoC also planned to transfer the surface and groundwater resource management. A mandate and responsibilities for managing water strengthened water resource monitoring system would resources and distribution from villages to muni- better inform planning and programming and support cipalities as a step toward greater efficiency. The building resilience in water resource management. Key Environmental Sectors   | 61 | Box 18. Projects in the Comoros That Have Ministry of Agriculture, Fisheries, Environment, Adopted an IWRM Approach Territory Planning and Urban and partners. It aims to strengthen water resource manage- The Adapting Water Resource Management ment, including groundwater management in the Comoros to Increase Capacities to Cope and the participation of local populations, with Climate Change project (2011–2016; US$3.7 expanding monitoring infrastructure, regu- million) financed by GEF and supported by lating stream flow, and protecting ecosystems. UNDP-UNEP focused on increasing the cli- It focuses on improving IWRM in 32 watersheds mate resilience of drinking water and irrigation and works to achieve a national paradigm shift water supplies on all islands. The primary activ- in water resource management. The object- ities included water management, reforesta- ives are to increase water supply to achieve full tion, land-use planning, and the construction of coverage of the population by 2030 and to pro- small rural water mobilization infrastructure. The vide all farmers with access to irrigation water. project also included awareness-raising activi- An important component focuses on capacity ties among community members on the bene- building for water planning, involving all rele- fits associated with reforestation activities and, vant stakeholders and integrating traditional conversely, the costs associated with deforest- knowledge with modern technologies, in line ation. Watershed committees were established with the principles of IWRM. in pilot areas and training was provided on the shared uses of water resources in the context of increasing scarcity due to climate change. 5.3.5. The Way Forward The Regional Integrated Water Resources and Strengthen further climate-resilient IWRM. • Wastewater Management Project (IWRM or Strengthened IWRM will enable the Comoros to GIRE) in the Atlantic and Indian Ocean Small adequately address the increasing demand for Island Developing State (SIDS) project (UNDP- water for drinking and for environmental and agri- UNEP; concluded in 2018) developed a national cultural uses. The approach should focus on (1) the IWRM plan to improve river and watershed man- identification and prioritization of infrastructure; (2) agement and provide a strong foundation for the promotion of watershed protection and resto- watershed ecosystem-based climate adaptation ration as one of the most effective solutions to im- responses. The project made important progress prove water retention, increase dry season flows, in the establishment of a watershed committee and reduce storm erosion; and (3) the integration and water resource management committees of groundwater sources within more holistic water- in pilot municipalities and provided training in management frameworks (Comte et al., 2016). This IWRM. The introduction of IWRM to the regional should also include the development of a robust water directorates has fostered improved coor- investment program addressing the requirements dination. The GIRE project implemented a water- of a strengthened monitoring framework, vulnera- shed and wastewater management program in bility and risk-assessment study, and island water the Mutsamudu River Basin of Ndzuwani and master plans. supported the Ndzuwani water-user associa- tion (Union of Water Committees of Ndzuwani • Scale up WASH programs and improve quality [UCEA]) to improve water management, for standards and quality control of drinking water. example, by setting water tariffs to cover the WASH programs should include the construction costs of water production and transmission. A and equipping of the new laboratory facilities for network of hydro-meteorological stations, flow, regular analyses of water quality, in conjunction and sediment measurement stations was also with the national health authorities. In parallel, installed. capacities of laboratory technicians and other staff will need to be developed through dedicated The ongoing Green Climate Fund (GCF)- capacity-building activities. In this regard, it would financed project Ensuring Climate-Resilient be important to operationalize the INRAPE. Water Supplies in the Comoros Islands (2019– 2027; US$60.8 million) was commissioned • Develop and enhance water infrastructure. The GoC by UNDP in partnership with the Comoros should step up its commitment under the AEPA to rehabilitate or establish collective drinking-water | 62 |   Comoros Country Environmental Analysis supply networks and energy-efficient systems • Facilitate the development of water master (incorporating renewable sources). At the same plans at the island level. Building on the action time, it is crucial to strengthen water treatment sys- plan presented in SCA2D (2018-2021), the master tems as well as expand water purification in areas plans will help identify and prioritize a progres- without access to safe sources of drinking water. sive investment plan for the development of Authorities should also enhance the protection of water resources and the delivery of a resilient water tanks through means that comply with the supply of drinking water, taking into account the standards of collection and storage of drinking different water sources, uses, and hydro-climatic water, in particular the rehabilitation of tanks in vulnerabilities on the three islands. They should impluvia at both the community and family levels. also provide mechanisms to enhance coordina- Furthermore, given water source limitations and tion of interventions between rural communities, the high leakage of water from the supply network, users (for example, agriculture), associations, it would be extremely beneficial for the country to NGOs, local authorities, the DNEA, SONEDE, monitor water losses and improve infrastructure private operators, and partners. Master plans to reducing non-revenue water. should also ensure strengthened participation and inclusion of local communities and women’s • Increase investments in sanitation. Given the organizations in sustainable water and sanita- critical lack of access to sanitation services in the tion management. country, it is critical for the GoC to bridge the in- vestment gap in the sector to develop the infra- • Conduct a vulnerability and risk assessment study structure for collective and autonomous sanitation for all water sources. The study will enable evi- and strengthen technical, material, and organiza- dence-based strategic prioritization in water re- tional capacities. source management, focusing on hydro-climatic resilience. The study will also inform island-level • Enhance the urban dimension of water and sani- master plans and investment programs. tation management. Acknowledging the growing urban population, it will be crucial to prepare tech- • Strengthen the water resource monitoring system. nical studies for upgrading water and sanitation A strengthened water resource monitoring system infrastructure in urban center to enable targeted in- is fundamental to inform programming, planning, vestments to improve supply networks of drinking infrastructure investments, and rehabilitation, water and increase access to sanitation services, in with particular emphasis needed on flood and line with what is envisaged under the PCE 2030. To drought monitoring and early warning systems. be effective, these investments need to be based Capacities should be enhanced to allow for proper on preliminary spatial planning policies and a cor- monitoring of rainfall, groundwater, stream flow, responding focus on urban planning aimed at de- waterways at risk of flooding, and water quality at signing functional cities, promoting smart urban the island level. An inventory of the drinking water growth, and counteracting urban sprawl. Another resources and groundwater aquifers should also key aspect includes gathering data and mapping be carried out by national authorities in coordina- city boundaries to have information on informal tion with island and local authorities. settlements that are home to the most fragile and segregated urban dwellers and have limited ac- • Conduct solid public communication campaigns cess to water and sanitation infrastructure. to sensitize local populations on the importance of consuming safe drinking water, as well as to • Clarify the roles and mandates under the decen- assess and increase public awareness of sanita- tralization process in alignment with the 2018 tion and hygiene issues. Such campaigns should constitution. For a robust water management in- stress the benefits of paying for consumption, the stitutional framework, it is crucial to overcome the value of water as an economic good, and the costs existing institutional fragmentation and improve associated with the development of water infra- coordination between national and island-level structure. Improved awareness about the costs agencies in terms of planning, programming, and required for water services, transportation, and budget allocation. Implementing the Water and cleaning of reservoirs would facilitate the effort Sanitation Code operationalizing the establish- by the GoC to introduce water tariffs in a staged ment of the FNDIEA is another step in the right approach and promote the uptake of commercial direction. water-distribution services. Key Environmental Sectors   | 63 | 5.4. Fisheries, Coastal, and Marine 5.4.1 Fisheries Sector Ecosystems The fisheries sector in the Comoros supports live- lihoods and jobs, contributes to food security, and generates revenue. The sector consists of three seg- ments: (1) subsistence, (2) artisanal, and (3) indus- Key Features trial fisheries. Subsistence and artisanal fisheries are Fisheries quite similar in the Comorian context and are both considered “small scale” for the purposes of this • Domestic fisheries make up 7.5 percent of GDP; document. however, seafood production does not cover national demand, making imports necessary. The fisheries sector, which consists of small-scale fisheries, is an important asset for the Comoros, • Fishery laws and decrees are in place, but accounting for 7.5 percent of GDP ( Table 12). The implementation remains a key challenge. exclusive economic zone (EEZ) of the Comoros is 86 times the size of the country’s land and offers • Fisheries remain threatened by IUU fishing, productive waters fueled by the presence of high- including in the domestic small-scale seg- biodiversity coral reefs, lagoons, mangroves, and ment, due to limited monitoring, control, and seagrass beds around the islands (World Bank surveillance (MCS). 2020j). Because of the limited availability of agri- • Co-management has proven to be successful in cultural land, fisheries play a vital role in providing managing fish stocks and other environmental nutrition for the Comorians, especially in densely resources more sustainably. However, the full populated Ndzuwani. According to a 2017 small- potential of fishery unions, associations, and scale census on Ndzuwani, 23 percent of men and cooperatives has not been fully harnessed. 34 percent of women were involved in fishery prac- tices, either as a first or second source of income Coastal and Marine Ecosystems (Freed et al., 2018). In addition, women play an important role in sales activities at the national • The coastal ecosystems of the Comoros harbor market and are also involved in octopus fisheries rich biodiversity and natural assets, including and postharvest operations, including preservation, mangroves and seagrass beds. transformation/processing, marketing, and sales (Youssouf 2010). Export of fish products is almost • While trends on habitat cover and quality are nonexistent, and seafood production does not for the most part not available, qualitative cover the national demand, which is supplemented analyses show that coastal ecosystems are by imports from Mayotte and Madagascar (Soilihi being degraded due to coastal erosion, pollu- 2017). In 2020, the Comoros imported fish (espe- tion, extraction of natural resources, natural cially sardines, mackerel, tilapia, and flatfish) in the disasters, and climate change. amount of US$3.3 million. • The marine environment of the Comoros is characterized by coral reefs and rich biodiver- sity, including many demersal and pelagic fish  Importance of the fisheries sector for the economy Table 12. of the Comoros species, such as snapper and grouper, as well as neritic and tropical tuna. Indicator Value • Marine and coastal assets are pressured by Fisheries GDP in 2020 (of total GDP) 7.5 % unsustainable practices and the impacts of cli- Fisheries GDP in 2020 US$1.19 billion mate change. Fisheries GDP in 2020 (of total agriculture GDP) 24 percent Direct and indirect employment in 2020 8,500 persons • The establishment of Mwali National Park and the co-management of marine resources was Percentage of the labor force in 2020 4.2 percent successful in reducing the degradation of fish Total fisheries production in 2020 13,089 metric tons stocks, protecting coral reefs, and increasing Sources:  World Bank 2020c; World Bank Database 2021; DGRH 2021; mangrove cover. However, sustaining these FAO 2020. results proved challenging. Note:  Exchange rate of KMF 1=US$0.00224 (June 2020), calculated with InforEuro (https://bit.ly/3Nw1TkQ). | 64 |   Comoros Country Environmental Analysis Figure 27.  Main pelagic and demersal species caught in domestic fisheries in Mt in 2020. Main pelagic species caught (Mt) Main demersal species caught (Mt) Keel-jawed Mackerel Brown-spoƩed needlefish scad grouper 415 306 39 Bigeye tune Honeycomb Deepwater 1,710 grouper longtail red 47 snapper Yellowfin 150 tuna Green 6,745 jobfish 63 Skipjack tuna 6,224 Rusty jobfish 123 Source:  DGRH 2021a. Fisheries are an important source of livelihood for the Industrial fishing in Comorian waters is being exclu- Comoros. Domestic fishing in coastal areas is tradi- sively conducted by foreign tuna fleets without tional and subsistence and artisanal in nature (Breuil landings in the Comoros (Breuil and Grima 2014). and Grima 2014). The census documented approxi- The main fleet is the tuna fleet from the European mately 9,000 Comorian fishers operating on various Union (EU) and associated countries, which mainly types of fishing vessels. Under the SWIOFish project, operates out of the Seychelles in the Western Indian more than 5,000 of these fishers were registered and Ocean. Foreign industrial fisheries are managed delivered an official fisher card. based on fish delivery agreements and/or annual licenses which establish several conditions, including In addition, a large number of on-foot fishers (more payment of fees (Breuil and Grima 2014; Golub and than 10,000), including a large proportion of women, Varma 2014). Non-EU foreign private companies target octopus and small fish in shallow areas of the operate under private licenses, and until 2017, the EU lagoons. Small-scale fishers use traditional wooden fleet operated under a sustainable fisheries partner- canoes powered by sails, paddles, or small engines, ship agreement (SFPA). This SFPA was used by tuna or motorized glass-reinforced plastic (GRP) boats. seiners and surface longliners from Spain (29 ves- sels), France (30 vessels), and Portugal (three vessels) The small-scale sector is transitioning to a more (Lallemand 2019). modern fleet. The proportion of nonmotorized boats in the fleet has been consistently decreasing In 2017, fees paid to the GoC for access to the Comorian from 2014 to 2020 (DGRH 2021a). The increased use EEZ by foreign vessels amounted to approximately of small, motorized boats (30 percent of the fleet) US$1.3 million per year or 0.7 percent of total govern- allows fishers to go farther offshore and fish on ment revenues. Approximately US$650,000 originated pelagic species, particularly tuna, and increase catch. from the EU SFPA, 50 percent for access and 50 percent A small number of artisanal fishers also target fishing for sectoral support. However, this revenue stream grounds farther offshore, outside of the EEZ of the ended in 2017 when the EU identified the Comoros as Comoros (especially the Glorieuses and the Lazarus a noncooperating country under the EU Regulation to banks) for high-value demersal species (DGRH 2021a; fight and deter IUU fishing,21 giving the country a “red UNCTAD 2017) (Figure 27). This is a concerning trend, card”22 and later denouncing the agreement. This had as fishing farther offshore increase risks and requires additional safety measures (FAO 2006) that are often not in place. Thanks to the SWIOFish project, regis- 21 European Commission, 2017. Fight against illegal fishing: Commission lists Saint Vincent and the Grenadines and the tration of fishing vessels in the Comoros requires a Comoros as non-cooperating, and issues warning for Li- safety visit and/or that vessels be built in accredited beria. Available at: https://ec.europa.eu/newsroom/mare/ shipyards. This trend of fishing farther offshore also items/65987/en indicates that coastal resources are not in good con- Comoros was issued a yellow card warning by the commis- 22  dition and cannot sustain the increasing demand. sion in October 2015, but inadequate progress on the agreed- upon roadmap led to issuance of the red card in 2017. Key Environmental Sectors   | 65 | a substantial impact on Comorian institutions23 that  The 2020 Environmental Performance Index (EPI) of had been receiving sectoral funds for their operations Table 13. the fisheries sector of the Comoros and that were now left with virtually no budget to func- Fisheries EPI score 10-year change tion (World Bank 2020j). Fish stock status24 23.8 −18 The industrial segment also includes several Marine Trophic Index25 13.4 − Comorian-flagged vessels that have beneficial owner- ship outside of the Comoros and operate outside of Source:  EPI 2020. Comorian waters. There is very limited information about the financial and socioeconomic impact of this The impacts of unsustainable fishing are visible, fleet on the country. However, inadequate monitoring especially on the reef habitats at Ngazidja and of the fleet triggered EU sanctions. In the last few Ndzuwani. In these habitats, low fish density and years, the Comoros has taken several steps to rectify limited diversity were observed during a survey the situation and has cleaned its registry. in 2018 and confirmed by fishers, who mentioned declines in stocks over the past decade (Samoilys The country’s fishing potential lies offshore in et al., 2018). The decline in the health of reefs not only pelagic fisheries (tuna and tuna-like species) and is affects the resilience of the fisheries sector but also estimated at approximately 33,000 metric tons (MT) directly contributes to the country’s increased vul- per year (Breuil and Grima 2014). The total landings nerability to climate change, as reefs provide essen- from artisanal fisheries were approximately 18,000 tial ecosystem services in terms of coastal protection metric tons in 2020 (DGRH 2021a), indicating oppor- (Harris et al., 2018). tunities to sustainably expand the fisheries sector through the modernization of national fisheries for In the Comoros, enforcement of the legal and reg- tuna and tuna-like species. However, given the cur- ulatory framework of domestic and foreign ves- rent status of yellowfin as overexploited, any expan- sels is limited, and resources thus face the risk of sion of fisheries should be done in accordance with overexploitation ( World Bank 2020j). For the IUU Conservation and Management Measure of the Fishing Index indicating the risk of IUU fishing in Indian Ocean Tuna Commission, including the yel- and by different countries, the Comoros has a high lowfin rebuilding plan. overall score, although it has improved slightly since 2019 (Figure 28) (IUU Fishing Index 2021). These prac- tices represent a challenge for the country’s fisheries 5.4.1.1. Degradation of Fisheries and Its Drivers sector and associated ecosystems, as they threaten Coastal communities of the Comoros are dependent local biodiversity, fish stocks, and the livelihoods of on subsistence agriculture and fishing and the pro- fishers and coastal communities. IUU fishing takes ceeds from sales of the surplus in local markets. place at both the industrial and small-scale levels. For Small-scale fishing, underpinned by other factors the industrial segment, a case in point is IUU fishing such as unsustainable fishing practices and limited for tuna in the EEZ of the Comoros (Zeller et al., 2021) enforcement, have put pressure on the coasts of the (Box 20). Because of insufficient efforts to combat main islands, as well as on the reefs of the Comoros, IUU fishing by vessels flagged in the Comoros, increasing environmental degradation and affecting the European Commission gave a red card to the fish stocks. Overfishing of larger and high-level spe- Comoros prohibiting exports from fisheries to the EU cies is indicated by a high-ranking Comoros Regional (European Commission 2017). Marine Trophic Index (RMI) (Table 13). Most demersal fish stocks in shallow waters are showing signs of either complete or overexploitation. Evidence of high fishing pressure was observed along the island of 24 Fish stock status is the percentage of a country’s total catch Ndzuwani, as illustrated by the absence of large fish that comes from overexploited or collapsed stocks, consider- and abandoned fishing gear (Freed et al., 2018). ing all fish stocks within a country’s EEZ. A score of 100 indi- cates that none of a country’s fish catch comes from stocks that are overexploited or collapsed, and a score of 0 indicates worst performance. 25 A high Marine Trophic Index (MTI) (scale 0–100) is explained Comorian institutions that received fees include the Ministry 23  by fish catches consisting of taxa from higher trophic levels, of Agriculture, Fishing and the Environment; the Directorate while lower scores consist of taxa further down the food General for Fisheries Resources; the National Center for web. If MTI decreases over time, this may be due to countries Fisheries Control and Surveillance; and other government depleting stocks of higher-level fish and resorting to lower- bodies. level taxa, also known as “fishing down the food web. ” | 66 |   Comoros Country Environmental Analysis Box 19. SWIOFish1 • Expanded fishery infrastructure such as cold storage, ice machine, and markets to support The First South West Indian Ocean Fisheries communities and reduce postharvest losses Governance and Shared Growth Project (SWIOFish1) was a regional World Bank-funded Continuation of activities developed under project active in the Comoros from 2015 SWIOFish1 is needed, in particular about the through 2021. It followed the Coastal Resources implementation of co-management, research Co-Management for Sustainable Livelihood and fishery statistics, and development of new Project (CoRecSud), which was the first World text for the fishery code. Bank investment project in the Comoros, and aimed to strengthen capacity to prepare fishery IUU fishing in the small-scale segment affects the co-management plans and increase access coastal fisheries of the Comoros at least as nega- to community-managed infrastructure. The tively as in the industrial segment. Strengthening objective of SWIOFish1 was to improve the the management of small-scale fisheries was one of governance and management of priority fish- the objectives of the World Bank South West Indian eries at the regional, national, and community Ocean Fisheries Governance and Shared Growth levels. The project supported activities in the Project (SWIOFish1) project,26 which contributed to Comoros, Mozambique, and Tanzania, as well addressing the IUU issue and broadened monitoring, as regional-level strengthening of the South control, and surveillance (MCS) efforts related to both West Indian Ocean Fisheries Commission industrial and small-scale IUU fishing, and generated (SWIOFC). relevant lessons learned. Among other activities, the SWIOFish1 project supported legislation enforce- In the Comoros, the project achieved the fol- ment by the police through co-management activities lowing results: with local communities and enhanced the small-scale monitoring and surveillance capacity of the National • Improved governance of fisheries through Center for Fisheries Control and Surveillance (CNCSP). strengthening the legal and regulatory Lessons learned from the project should be incorpo- framework rated into efforts to achieve resilient fisheries in the • Reinforced MCS and enforcement, including Comoros. with joint fishery patrols conducted by the Initiatives to counter both industrial and small-scale CNCSP , the coast guards, and marine park IUU fishing are hampered by multiple constraints. rangers Existing regional instruments have not been suc- • Improved fishery monitoring by setting up cessful at effectively addressing this issue, mainly registration systems for fishers and vessels because of limited political will and the lack of ade- quate human, technical, and financial resources. • Implemented a modern fishery data col- Enforcement in the small-scale sector is sometimes lection system using a smartphone app difficult given the potential impact on livelihoods as and centralized database, with the publi- well as the community aspects. The lack of available cation of the first Statistical Bulletins. Six and up-to-date data on the actual scale of IUU fishing co-management agreements have been in the EEZ is still an obstacle for the development developed and implemented for improved of effective measures. However, awareness raising fisheries management and improved bene- around the legal and regulatory framework, develop- fits for participating. Local communities take ment of co-management agreements, strengthening part in the management of fishery resources, the MCS, and cleaning the registry are contributing to including time-area closures of 100 hectares the fight against IUU fishing in the Comoros. of octopus fishing sites for four months, resulting in an increase in catch, and partici- pation in reef restoration. 5.4.1.2. Opportunities for Change • Provided fish aggregating devices to several Policy enforcement and sustainable management local communities to attract fish, including are essential to reduce pressure on fish stocks, and pelagic fish such as tuna 26 http://www.comorespeche.org/index.php Key Environmental Sectors   | 67 | Box 20. Projects Targeting IUU Fishing for food security through restoration of fragile ecosystems and assisting fishing communi- In 2012, the regional “FISH-I-Africa” task force ties to better manage their coral reef resources. was established to help address IUU fishing. The results of this initiative include improved FISH-I-Africa aims to combat IUU in eight African fisheries management around coral reefs, countries, including the Comoros, by tracking higher fish value chains and market access, and down illegal operators and sharing informa- reduced IUU fishing. tion on flagged fishing vessels, license lists, and vessel photographs. FISH-I-Africa works closely together with the IOTC, which played an impor- tant role in providing expert advice and informa- alternative livelihood options need to be devel- tion to the FISH-i Africa initiative. Specifically, oped to ensure income for communities. The Mwali IOTC contributes to the information-sharing National Park project (1998–2005) covering 400 portal of FISH-I Africa to support due diligence square kilometers has been focusing on addressing checks on vessels. However, FISH-I has lost these challenges with support from international momentum in the countries of the region. organizations and local communities. Results included benefit-sharing arrangements for local Currently, the Directorate General of Fisheries livelihoods such as NBT (see section 5.6) and the Resources from the Comoros, with support from increase in live coral cover. Despite the successful the Nairobi Convention SAPPHIRE project (2017– results, resources available to consolidate, con- 2023), is supporting policy harmonization and tinue to support, and scale up these activities are management reforms toward improved ocean lacking, especially now that new marine parks have governance. In addition, it will create a new been created in the Comoros. SWIOFish1 supported sector policy and operational implementation co-management activities with selected communi- plan to strengthen the capacity of local fishing ties for the Mwali park and in other areas identified stakeholders to combat IUU fishing. An impor- for creation of new marine parks (Box 21). As part tant aspect of SAPPHIRE consists of training of these activities, support was provided to develop and leadership workshops focusing on marine alternative livelihoods to fishing by creating activi- policy and ocean governance, with particular ties that add value to fishery products and support attention accorded to the role of women (Nairobi sales, as well as for activities beyond fisheries such Convention 2021). as agriculture and livestock. These type of alternative livelihood options also help decrease direct pres- Fishing surveillance has been strengthened by sures on coastal species (Dahari 2022), ultimately the PRSP of the Indian Ocean Commission (IOC) supporting sustainable management of natural and will be taken over by the IOC-EU ECOFISH resources. project. One of the ECOFISH project components is MCS, which aims to organize joint patrols A sustainable domestic, semi-industrial fishing fleet with the coast guard and patrols in marine parks could be a source of new jobs and income. Developing and to ensure the registration of fishing gear. a domestic semi-industrial fishery, potentially focusing However, these types of activities are finan- on tuna, would require substantial efforts on many cially challenging, as they require substantial levels. Incentives to engage in the activity need to be means for purchasing vessel fuel. Monitoring developed. Given the current status of infrastructure, will also be addressed in the recently initiated port landing and processing facilities are necessary, Oceans 5 project (2021–2024). Planned moni- as well as cold rooms and a quality control laboratory. toring programs include coral reef biodiversity, Investments are needed in upgrading vessels to make fish catch records and abundance surveys, and them suitable for longline fishing. Capacity building turtle, mangrove, and seagrass habitat moni- is also needed in many areas, including the safe use toring inside the country’s marine protected of longline gears, safety at sea, and quality control in areas (MPAs) (Wildoceans 2021). the case of processing and preservation. In the past, the Comoros had tried to modernize its fisheries with In 2019, FAO and the Ministry of Agriculture, the development of a semi-industrial fleet, but despite Fishing and the Environment launched an ini- investment from the private sector, this has not suc- tiative to improve coral reef fishery production ceeded, indicating the need for analysis to understand the reasons for these past failures. | 68 |   Comoros Country Environmental Analysis the sustainability of the results is needed, as well as Box 21. Co-Management of Marine Resources building on the results and enhancing achievements. Key challenges include the lack of stock assessments, The CoReCSuD project sought to strengthen cold storage capacity, and processing facilities, diffi- stakeholders’ capacity to prepare community culties in meeting international food safety standards, management plans for selected priority fish- and a weak professional training system (Breuil 2018). eries and increase access to community- While SWIOFish1 and other projects have been pro- managed infrastructure in pilot sites. As part viding infrastructure to support cold and value chain of the project, community management of development, the challenge of these investments in fisheries was strengthened in 27 pilot sites. the Comoros has always been ensuring their sustaina- Management plans and the development of bility given limited capacity to properly manage them alternative sustainable practices were devel- and little accountability. oped (World Bank 2016b). Furthermore, 17 co-management agreements were signed Co-management of fisheries could deliver environ- as part of the project on Ngazidja, Mwali, mental, social, and economic benefits simultane- and Ndzuwani (World Bank 2020f) and have ously. Co-management agreements have proven been implemented. Successful examples of successful in managing fish stocks and other envi- co-management in fisheries include seasonal ronmental resources sustainably. In the Comoros, closure of octopus fishing sites. co-management of marine resources started through the World Bank and Japan Social Development Fund The outcomes of the project have been stream- project, Co-Management of Coastal Resources for lined with the subsequent SWIOFish1 project. Sustainable Livelihoods (CoReCSuD) (2012–2017) Eleven co-management agreements including (Box 21), which helped successfully implement sustainable fishing practices have been revised fishery co-management agreements with com- and signed, and the implementation of six has munities in all three islands. Building on these been supported. Seasonal closure of octopus results, SWIOFish1 supported the establishment fisheries allows reefs to recover, stocks to of 11 co-management agreements, seasonal clos- regenerate, and catches to increase. In addi- ures to allow reefs to recover, stocks to regenerate, tion, coastal sheds have been constructed to and catches to increase (see Box 19 for more about house local materials. Other initiatives under achievements of SWIOFish1). Follow-up to the signed SWIOFish1 included ice machines, cold stores, co-management agreements with related plans and storage areas, and the establishment of selling activities is essential to ensure benefits for the envi- points. (See Box 19 for more information about ronment and the communities that depend on it for SWIOFish1.) their livelihoods. Follow-up of the signed co-management agree- As with terrestrial national parks, the marine park ments should ensure the implementation of in the Comoros has shown promising results in pro- plans and activities. An example of a follow-up tecting reefs, marine biodiversity, and coastal ecosys- initiative is the Strategy for the Expansion of tems (Ramadhoini Ali 2021). With the establishment the National System of Protected Areas (SNAP , of Mwali National Park in 2001, coral reefs in the pro- 2017–2021). This strategy aims to facilitate the tected area have been shown to be in comparatively establishment of at least five protected areas good condition with healthy hard coral and up to managed by local communities to improve their 80 percent cover. In addition, the park saw high fish standard of living. It also aims to establish an densities and species richness, in particular among environment fund and arrange education and species more vulnerable to fishing (Samoilys et al., training. Co-management lies at the core of the 2018). These findings indicate that the ban on destruc- strategy (GEF and UNDP 2022). tive fishing in the park is being effectively enforced by the village committee. Violations of regulations are handled directly by the committee and the case Additional benefits would result from the reduction of is transferred to a national judicial system when local post-harvesting losses, the increased value by raising solutions cannot be found (ASCLME 2012). Sharks, the number of landing sites and cold chain facilities however, were not sighted in the park during the study (World Bank 2019c), and enhanced safety at sea.  (Samoilys et al., 2018), calling for strengthened efforts Despite several of these challenges being at least par- to protect threatened species in the region such as tially addressed by the SWIOFish1 project, ensuring sharks. The establishment of additional national parks Key Environmental Sectors   | 69 | similar to Mwali National Park is beginning to protect and increase the resilience of the threatened coastal Box 22. Marine National Parks and Protected assets and marine biodiversity. Since support during Areas the creation of Mwali National Park only covered part of the costs and did not generate direct returns, com- In 2017, the GoC approved the National Parks munities have not been particularly motivated to drop Strategy, which lays out the government’s their livelihoods. To ensure the success of new national intention to manage more than 25 percent parks, it is crucial to involve local communities through of the national territory using a community co-management initiatives, with a special focus on approach and to establish three new national engaging women in awareness-raising and leadership marine parks. The development of additional roles. To ensure the long-term sustainability of results, national parks is in line with the objective of the the implementation of long-term assessments of the Blue Economy Strategic Framework to “protect financial needs of protected areas is also key. coastal aquatic and marine ecosystems” (Union des Comores 2018). In this regard, the National Significant opportunities may arise from activities to Protected Areas System Law (2018; No. 18-005/ be funded under the multidonor trust fund PROBLUE, AU) was adopted, as well as the Presidential which supports sustainable and integrated develop- Decree of Protected Areas (2019; No. 19-129/PR). ment of marine and coastal resources. The activity The GoC established RENAP , the institution in comprises a set of assessments and gap analyses on charge of the creation of these marine parks, and selected key topics and aims to increase the knowl- developed the National Parks Strategy, 2017. A edge base and capacities of national and international trust fund (Fond Environnemental des Comores stakeholders to deliver transformational results for the [FEC]) was set up in 2017 with the objective of development of the blue economy. The blue economy raising funds for the upcoming national parks. in the Comoros holds significant potential for bal- However, the fund is not yet functional to date, ancing conservation objectives with socioeconomic and a replacement for the Executive Director is development. still being recruited. PROBLUE consists of four key components: (1) The planned national parks for the protection boosting the blue economy agenda, (2) fisheries and of the coastal and marine environment of the climate change, (3) marine litter and plastic pollu- Comoros are: tion, (4) NBT (see Box 23). In particular, PROBLUE aims to contribute to reducing gender inequalities • Coelacanth National Park in the south of and gender-based violence by providing analyses Ngazidja highlighting the importance of including gender considerations in climate change mitigation and The proposed site is a marine and coastal adaptation actions for more sustainable fisheries area of 7,572 ha with 200 meters of beach and management. In addition, PROBLUE aims to iden- mangrove coastline. The marine area harbors tify circular economy opportunities to be devel- many whales and dolphins and features a oped around marine litter management, as well as coral reef that is in good condition. to improve knowledge about how to increase pri- vate sector engagement through the identification • Mitsamiouli Ndroude National Park in of innovative financing approaches to blue carbon northern Ngazidja projects. This park aims to protect the marine tur- tles which populate the island in particular, The potential of fishery unions, associations, and as well as to develop ecotourism. The park cooperatives is not being fully harnessed. The key would include coral reefs and seagrass beds function of unions and associations is to represent the that are frequented by Dugongs and endan- interests of fishers, whereas cooperatives have the gered green turtles. function of improving economic performance through group purchases, such as for equipment. In addition • Shissiwani National Park in Ndzuwani to the National Fishermen’s Union (NFU), there are regional unions for the three main islands. According This park includes the Bimbini reserve area to the NFU, there are approximately 121 cooperatives/ which covers 3,025 hectares of the marine associations in the Comoros, representing approx- environment and a 200 meter coastal strip. imately 7,600 fishers (Breuil 2018). In recent years, The area includes mangroves, coastal reefs, fisherwomen associations have also been formed, | 70 |   Comoros Country Environmental Analysis Association (IORA). Surveillance of large fishing beaches used by turtles as nesting sites, sea- vessels operating offshore takes place through the grass beds, and an agroforestry strip. Regional Fisheries Surveillance Program (PRSP) and was embedded in the EU ECOFISH program.27  The The decrees for the creation of these new EU ECOFISH program (Box 20) also aims to build parks are pending signature (GEF and UNDP synergies in fisheries management and the pre- 2022). With the FEC currently not functioning, vention of IUU across the Southwest Indian Ocean direct financial support to RENAP is required region. For more than 10 years, the Regional Plan to advance the creation of these three national for Fisheries Surveillance (PRSP) has supported the parks. Furthermore, development of the parks organization of regional joint patrols with other coun- should capitalize on the lessons learned from tries in the Indian Ocean. Mwali National Park, replicating the successful co-management approach, while paying specific The limited financial sustainability and follow-on attention to women, which was lacking during of completed projects pose significant constraints the Mwali National Park co-management activi- for their effectiveness; f or example, SWIOFish1  ties (UNDP 2012). achieved successes during the project that are at risk of deteriorating after the project ends. Insufficient funding following the completion of projects has specifically related to octopus fisheries. Within these resulted in reduced management effectiveness, activ- associations, women can receive training to self- ities, and levels of enforcement. Eco-guards have left organize and strengthen their collective capacity to projects once financing ceases and salaries are no better manage and protect marine resources. Women longer paid. In addition, means of defense against are also trained in association management skills and armed poachers have been inadequate (UNDP 2012). drying techniques (CEPF 2018). The main challenge for AFD has stepped in to support the marine park, but to fishery unions, associations, and cooperatives is to ensure effective longstanding co-management, finan- overcome the lack of a well-structured organization. cial and human capacity is required, in particular to This stems from the fact that the roles and responsibil- improve the organizational capacity of local commu- ities of unions, associations, and cooperatives are not nities. From the perspective of MCS, local communi- clearly defined, resulting in a lack of legitimacy and ties can be of added value if trained to collect local subsequent conflicts of interest. SWIOFish1 invested field data. in a series of initiatives aimed at improving the struc- ture of these associations, including co-management, safety at sea, and capacity-building activities (Breuil 5.4.1.3. Institutional and Legal Context 2018). During stakeholder consultations carried out The GoC has taken significant steps to enhance the during the development of the CEA, participants were regulatory legal framework for fisheries, in line with asked to identify the pending priorities for unions, SDG 14.4 to effectively regulate overfishing, IUU, and associations, and cooperatives. Suggestions included destructive fishing practices to rebuild fish stocks scaling and improving capacity building within (Comoros Ministry of Foreign Affairs 2020). The the cooperatives/associations to enhance sustain- Department of Fishing of the Ministry of Agriculture, able fishing methods, leveraging the success of the Fishing and the Environment is the body respon- fish aggregating device (see Box 19 on SWIOFish1), sible for domestic fishing policies. The sector is gov- and further improving fish conservation through erned through Law No. 07-011/AU of 2007, which was increasing the use of ice machines. updated in 2019 by Law 19-05/AU (see Annex 4 for an overview of fisheries laws and regulations). To com- Enhanced regional cooperation through projects plement this law, several implementing texts have and intergovernmental agencies could enhance been published in decrees and orders (Annex 4). results and ensure sustainability. Tackling challenges Decree No. 15-050/PR of 2015 implements the code at both national and regional levels is key, consid- and established the requirement for artisanal fishers ering the intrinsically regional dimension of issues to hold a license. It also provides the legal basis for such as sustainable fishing or IUU fishing. There a vessel register, boat marking, development plans, are several intergovernmental agencies active in and bans of unsustainable fishing gear (Breuil 2018). the Western Indian Ocean such as the Indian Ocean In 2020, another update was published to fight IUU Tuna Commission (IOTC), the Southwest Indian fishing (Decision 20-051/PR). Ocean Fisheries Commission (SWIOFC), the Indian Ocean Commission (IOC), and the Indian Ocean Rim 27 https://www.ecofish-programme.org/ Key Environmental Sectors   | 71 | Box 23. PROBLUE • Analysis of policies and best practices for sharing benefits from protected area tourism PROBLUE seeks to address key data gaps asso- with Comorian local communities ciated with the potential for the Comoros related to the blue economy. In line with this CEA, it aims to provide policy makers and other rele- While the improvement of the legal framework has vant national and international stakeholders (for been a remarkable first step toward achieving sustain- example, private sector, CSOs) with the data able fishery practices, several gaps remain. A compre- required to inform decision-making and the pri- hensive sustainable fisheries policy does not exist, and oritization processes for developing an effective the updated Fishing Code still needs additional imple- blue economy in selected key areas. mentation texts, for example, on management of strad- dling stocks (such as tuna) of deep-sea and artisanal Component 1: Boosting the blue economy fisheries. These texts have been signed but have limited agenda enforcement. • Analysis of the current MPA framework, man- Fisheries management is hindered by institutional agement structures, and effectiveness in the limitations and a chronic lack of funding, which has Comoros, including as they relate to inter- made the Comoros very dependent on external national commitments, and development of funding. This is illustrated by the fact that DGRH and recommendations for strengthening MPA the CNCSP28 received US$90,500 and US$271,400,29 management (including through alternative respectively, for their annual budgets, resulting in fre- management arrangements) and the benefits quent salary arrears (Breuil 2018). To overcome such of and potential for increasing MPA surfaces constraints, international donor projects have focused on addressing the key challenges in the implemen- • Assessment of potential for blue-carbon offset tation of fisheries laws and decrees. One example is in the Comoros (mangroves, seagrass) the SWIOFish1 project (Box 19), which contributed • Analysis of coastal degradation induced by ero- significantly to improving MCS, among other project sion, river siltation, unsustainable land man- achievements. Other international donor projects such agement, sand mining, and climate change, as as FISH-I-Africa, SAPPHIRE, and ECOFISH focused on well as other factors, and development of pro- addressing the IUU fishing challenge. posed recommendations to increase coastal resilience, including through NBS Data collection on fish landings takes place in the Comoros, but the assessment is conducted at the Component 2: Fisheries and climate change Indian Ocean Tuna Commission (IOTC). Data are col- lected on the landing sites of the three islands and, • Conduct in-depth study of the impacts of cli- as such, constitute important indicators of fishing. mate change on the fisheries of the Comoros In total, 23 different stocks are reported, including • Analysis of opportunity for the development of demersal and pelagic fish (FAO 2019). Through a semi-industrial fisheries fleet in the Comoros SWIOFish1, data collection efforts improved, resulting in the publication of annual Fisheries Statistics Collate lessons learned from fishery • Bulletins, which explain the data collection methods co-management rolled out in other African and report the production data for the artisanal countries and traditional fisheries (DGRH 2021a). Given that Component 3: Marine litter and plastic pollution SWIOFish1 closed in 2021, ensuring continued and enhanced data collection is essential to inform deci- • Strengthen the analytical base on marine litter sion-making in the country’s fisheries management. • Implement the Circular Economy Opportunities The GoC has adopted several legal texts with pro- Assessment for the Comoros visions for the protection of coral reefs, such as Component 4: Nature-based tourism Decree No. 15-050 prohibiting harpoon fishing and • Implement a combination of activities to pro- mote sustainable and inclusive NBT in marine 28 The CNCSP was established in 2007, as part of a regional EU and coastal areas project through Order N° arreté 07-31/MAPE-CAB. 29 Exchange rate of KMF 1=US$0.00226 (April 2022). Calculated with InforEuro (https://bit.ly/3Nw1TkQ). | 72 |   Comoros Country Environmental Analysis where the protection of sea turtle nesting sites was a prime motivator for the creation of Mwali National Park (ASCLME 2012). Mangroves Along the Comorian coast, mangrove ecosystems are limited and found at the southern coast of Mwali, Ngazidja, and Ndzuwani ( Table 14) (Global Climate Change Alliance [AMCC] 2019b; ASCLME 2012). Although they are present in limited cover, mangroves provide key ecosystem services for the Comoros such as providing nursery habitats and food resources for many fish species, influence the surrounding environment by stabilizing sediments and attenuating wave energy, and protect the coastline, mitigating the impact of flooding Sandy beach along the coast of Ngazidja and preventing coastal erosion. Additionally, mangroves Photo Credit: Deltares promote the establishment of offshore coral reefs by retaining sediments that would otherwise limit their foot fishing in coral reefs, but their application growth. In recent years, mangroves have been increas- remains limited. A concept note is currently being ingly recognized for their role in mitigating the contribu- developed by the GoC and the Green Climate Fund tion of the Comoros to climate change because of their for the restoration of coral reefs and associated eco- high rates of carbon sequestration, exceeding the carbon systems (see Box 25). storage rates of terrestrial forests (World Bank 2017b). 5.4.2. Coastal and Marine Ecosystems Seagrass Beds The coastal and marine environment of the Comoros The Comoros has several seagrass beds, which are consists of many rich but fragile ecosystems including extremely important for the conservation of its biodi- sandy beaches, rocky shores, mangroves, seagrass, versity and the protection of its coastal environment and fringing coral reefs. These ecosystems give rise (Figure 28). The seagrass of the Comoros is highly  to rich biodiversity, including many emblematic spe- important, supporting the enormous wealth of the cies such as dugongs, humpback whales, and green islands’ associated fauna such as dugongs and green and hawksbill turtles (World Bank 2020j), but are under turtles, and playing a significant role in blue carbon threat of degradation because of both natural and storage. Seagrass around the Comoros experiences anthropogenic drivers. strong seasonal variation. During the rainy season, the beds are heavily affected by sedimentation resulting from terrestrial soil erosion. Seagrass beds expand Rocky Shores and Sandy Beaches The shoreline of the Comoros is characterized by  Overview of cover (ha) of coral reefs and mangrove Table 14. rocky shores and sandy beaches. All islands of ecosystems (2018) the Comoros are of hot-spot volcanic origin, and morphological characteristics and soil type vary depending on the age of volcanism. As a result, the coastline ranges from coral sand to white beaches, basaltic rocks, black volcanic sand, mixed, and muddy sand beaches (Sinane 2013). The rocky shores are well preserved and protected from coastal ero- sion and harbor a diversity of plant and animal species. The 10 islets of the Comoros, mostly along the south of Mwali, are surrounded by coral sand beaches, which are considered important assets for tourism development. All country’s beaches pro- vide nesting sites for sea turtles, especially in Mwali, Source:  AMCC 2019b. Key Environmental Sectors   | 73 |  Distribution and density of seagrass beds around 5.4.2.1. Coastal and Marine Ecosystem Figure 28. western Ndzuwani island (upper image) and the Degradation and Its Drivers south of Ngazidja (lower image). Rocky Shores and Sandy Beaches N Coastal erosion of beaches that results from natural W E 3 km S factors is caused by a combination of natural phenomena, the local bathymetry, and climate variation. Swells, coastal currents, and tides directly affect the natural erosion of the coasts and beaches. Bimibini Peninsula The impacts of climate change may amplify this Seagrass process, as sea level and heavy rainfall are expected density 100 % to become more frequent in the coming decades 0% (see section 3). The strength of cyclones and tropical storms is also predicted to increase, putting additional pressure on the coastline of the Comoros. Coastal erosion is also exacerbated by the coral bleaching of 3 km adjacent reefs. Because of insufficient funds, the cost of maintenance to seawalls has not been budgeted; as a result, most sites are now exposed to coastal erosion once again. This raises the issue of the need for international support to build seawalls, especially considering that the average loss from flooding alone Seagrass is approximately $2.0 million per year. density N 100 % W E 0% S Anthropogenic activities such as the mining of sand and rock material has put additional pressure on Source:  Poonian, Tuharska, and Hauzer 2016. the beach systems. Sand and gravel extraction from beaches is driven primarily by growing urbanization which, in turn, has led to the increase in the demand during the southern winter due to more favorable envi- for construction materials (Sinane 2013) (see Box ronmental conditions (ASCLME 2012). 24). For instance, 54 percent of Mwali’s beaches (469 ha) was lost between 1950 and 1998 (Abdou, n.d.) and, more recently, in the 2010s, up to 14,000 m3 of Coral Reefs sand was extracted monthly in Ndzuwani for con- The marine ecosystem of the Comoros is char- struction purposes. Sand extraction causes not only acterized by fringing reefs that have a narrow degradation of beaches, but also threatens ecologi- platform extending from the steep volcanic shore- cally important habitats such as coral reefs, seagrass line. While a full inventory of the reefs does not beds, and mangroves and increases the country’s exist, 250 species have been identified in Mwali vulnerability to cyclones, heavy rainfall, and rise in National Park (ASCLME 2012). Coral reefs surround sea level. The progressive loss of the protective role 100  percent of the Mwali coastline (3,917.23 ha), of the beach affects infrastructure close to the coast- 80 percent of Ndzuwani (4,057.93 ha), and 60 per- line such as coastal roads, airports, and villages, cent of the Ngazidja coastlines (2,473.38 ha), for a while jeopardizing opportunities to develop the total of approximately 10,447 ha. This surface area nascent NBT sector (see section 5.6). Sand-mining corresponds to 16 percent of the total land area activities have led to severe depletion of sand, espe- of the Comoros. The condition of reefs varies spa- cially on less frequented beaches, while the most tially; more than half of the Comorian coral reefs frequented beaches close to urban areas have been (60 percent) are considered dead, including as many preserved from this activity thanks to self-regulation as 80 percent to 90 percent in some sites (ASCLME by local communities, an attitude which highlights 2012). Given the protection status of Mwali National the environmental benefits of co-management in Park, its coral reefs are significantly less degraded the Comoros. than those outside of the park and along Ndzuwani (Figure 29). In addition, Mwali’s shallower reefs Another stress on the Comoros marine environment have been found to be more degraded relative to the is the lack of solid waste infrastructure. Because of deeper reefs of Ngazidja and Ndzuwani. the small land surface, activities on land strongly and | 74 |   Comoros Country Environmental Analysis Figure 29.  Coral reef locations along Ndzuwani. Comoros archipelago Grande Cornore Jimilimé Anjouan Mohel Africa MayoƩe Madagascar Hajoho Mozambique Ountsoha channel Ouani N-W Coast Sima Mutsamudu Bimbini East-Coast Bambao- M’Tsanga Ntringui 1595 m S-W Coast Legend Coral reef Mova Road UrbanizaƟon 0 5 10 km Nyumakélé Chiroroni Source:  Ratter et al., 2016. directly affect the shores of the Comoros, and the lack primarily threatened by waste dumping, deforestation of waste and sewage management infrastructure, for heating and construction purposes, sand mining, compounded by the absence of a comprehensive and the expansion of urban infrastructure and villages. national waste management strategy, results in large Natural mangrove degradation results from sedimen- amounts of waste dumped on beaches and ending tation following coral bleaching events, coastal ero- up in the sea and reefs (see section 5.5 on waste sion, and the drying of rivers. management). Mangrove restoration projects have taken place with promising results along the coast of Ndzuwani, where it was found to be an effective nature-based flood- Mangroves defense measure to combat erosion ( Sinane 2013). Although mangroves are small in the Comoros, the reduction of mangrove cover is driven by the com- bined impacts of natural and anthropogenic factors, underpinned by the lack of appropriate management (Malterre et al., 2018). The country’s mangroves are  Litter on a beach in Ngazidja Mangroves in Ngazidja Photo Credit: Deltares Photo Credit: Deltares Key Environmental Sectors   | 75 | Box 24. The Case of Coastal Sand Mining To address environmental challenges due to sand extraction, affordable alternative liveli- The demand for construction materials has hoods need to be developed, such as through increased since the 1950s due to urbanization, NBT. Involving local communities in the leading to growing extraction of coral stone, co-management of coastal resources is key. coral lime, and sand. Coral lime was replaced Awareness among these communities can by imported mortar following the ban on beach be increased by leveraging initiatives such as sand and coral mining in 1989. Consequently, the United Nations Educational, Scientific and coral extraction activities significantly reduced Cultural Organization (UNESCO) Sandwatch in the 1990s. However, illegal sand extraction Program. Although not the ultimate solution, from beaches continues as the demand for con- offshore seabed mining can reduce the pres- struction material increases and enforcement sure on the coastline. The growth of this sector remains low (Sinane 2013). is one of the blue economy ambitions in the PCE (Comoros Ministry of Foreign Affairs 2020). Sand extraction is a subsistence activity for the poorest livelihoods. It takes place on Ngazidja and Ndzuwani during the dry season when the agricultural sector employs fewer people Restoration can be highly effective when biophysical (Sinane 2013). Truckers purchasing directly from conditions are favorable for mangroves and local com- extractors pay approximately US$34 per cubic munities are sensitized on the importance of the sus- meter on Ndzuwani. The materials are sold on tainable management of mangroves (Deltares 2016). A the markets for approximately US$39 to US$45 positive trend was seen in Mwali, where the decrease per cubic meter. in wood harvesting led to a reported increase in man- grove cover in 2017. The decrease in wood harvesting Illegal sand extraction does not meet the was driven by the introduction of protected areas, national demand for cement. Therefore, the which restricted access to mangrove forests. About Comoros is highly dependent on imports, repre- 30 forest eco-guards were recruited by the Island senting about 150,000 tons/year at an estimated Governorate in February 2013, approximately 25 of cost of US$15.2 million in 2020 (OEC 2020). The whom are assigned to the territory where the exten- volume of extracted sand on both Ngazidja and sion of the protected area is planned. Their mandate is Ndzuwani as of 2022 is not known. In the early to enforce the regulations concerning the prohibition 2010s, the volume was estimated at 14,000 cubic to cut wood on the coastline, along rivers, and in for- meters/year for Ndzuwani (Sinane 2013). ests (except by permit) and to contribute to reforesta- tion actions (Roby 2014). The production sites on Ngazidja and Ndzuwani were mapped as part of the Global Climate Change Alliance (GCCA [AMCC in French]) Seagrass Beds project implemented from 2014 through 2019 (see Annex 6). The project enabled the Comoros Although Mwali National Park has the largest cover to take part in the global effort to mitigate cli- of seagrass (up to 90 percent) (ASCLME 2012)sea- mate change, which can contribute to reducing grass beds and coral reefs, over the past two decades poverty (AMCC 2019). it has experienced a progressive decline (Ahamada 2021; Poonian, Tuharska, and Hauzer 2016). The exact Law No. 89-020 of 1989 and Decree No. 06-019/ extent of the decline is unknown, making recurrent PR forbid sand mining. In addition, the 1994 mapping of seagrass essential for the Comoros to Framework Law requires that any develop- properly quantify the trend and thus improve man- ment project have environmental authorization agement. The decline in seagrass cover is mainly through an EIA. Violation is sanctioned with characterized by the disappearance of an abundant imprisonment and/or a fine. However, enforce- key species (Thalassodendron ciliatum) because ment is nonexistent and should be enabled of coastal erosion and sedimentation from ero- via sufficient (remote sensing) monitoring and sion upstream (Ahamada 2021). Given the lack of surveillance resources within the Ministry of specific data, it would be beneficial to conduct a Fisheries, Environment and Agriculture. regional study on the distribution of this species to provide more insight on the causes of this decline. | 76 |   Comoros Country Environmental Analysis In contrast, seagrass beds around Ndzuwani, located sewage and solid waste contribute to further degrade mainly along the Bimbini Peninsula (1,419 ha), are the reefs of the Comoros: plastic pollution has been expanding due to terrigenous deposits from fresh- accumulating on both deep and shallow reefs of water streams (Malterre et al., 2018). Ndzuwani (Samoilys et al., 2018) and solid waste has been evident on the beaches of Ndzuwani (Freed et al., While some patches of seagrass are expanding, such 2018). as along Ndzuwani, several pressures on the habitat could cause degradation. Among these stress factors Reefs are further degraded by coral bleaching are sedimentation resulting from soil erosion, var- (Cowburn et al., 2018). Bleaching is caused by  ious types of pollution, overexploitation, urbanization, warming waters as a consequence of either climate and destructive fishing activities, such as foot fishing change or natural events. During the more recent (Malterre et al., 2018). Restoration of the most threat- coral bleaching event in 2016, reefs were found to ened species, as well as conservation pilot sites of the be affected with 10 percent to 60 percent bleaching. existing seagrass beds around the islands, can help The mortality of live hard coral was estimated at protect the habitats and ward off further decline, while less than 20 percent, and declines were present for supporting the NDC ambition to increase net CO2 Comoros reefs as well (Obura et al., 2017). Bleaching absorption. events are predicted to occur more frequently in the future because of the increase in extreme IOD events (FAO 2018). Furthermore, increasing sea sur- face temperatures, together with ocean acidifica- Coral Reefs tion resulting from rising CO2 levels, lead to further The coral reefs of the Comoros have degraded during degradation of these marine habitats. An analysis the past 40 years because of a combination of human- of the vulnerability of reefs in the protected Mwali related factors, natural events, and global bleaching National Park to future coral bleaching events (Breuil and Grima 2014; Obura et al., 2017). Pressures  found that they are resilient to the ongoing human- related to human activity include illegal practices such related pressures, though they might not be able as dynamite fishing, the release of toxic products into to withstand future climatic effects Cowburn et al. the water, and the use of mosquito nets that physi- (2018). Nevertheless, other coral reefs outside pro- cally harm the coral. Informal interviews with fishers tected areas could face more intense pressures and revealed that nets are often set on the reef, resulting in become more degraded. degradation as illustrated by coral debris (Harris et al., 2018). Dynamite fishing was found to have degraded Other natural events that affect coral reefs include reef sites around Ngazidja (Freed et al., 2018). Erosion tropical storms. In 2019, Cyclone Kenneth resulted and sedimentation of the reef resulting from defor- in the physical degradation of coral habitats in sev- estation and sand mining have been observed along eral locations along the coasts of the three major the coast of Ndzuwani (Freed et al., 2018). Finally, both islands, also affecting the associated fish and shellfish Figure 30.  Coral reef status in the Comoros by island in 2018. Source:  Ramadhoini Ali 2021. Key Environmental Sectors   | 77 | species. Since these natural hazards are expected to Commissioner, with technical and financial assistance become more frequent because of climate change, it from IOC-UNESCO beginning in November 2021. is foreseeable that coral reefs in the Comoros will be exposed to increasing pressure. 5.4.2.3. Institutional and Legal Context Sustainable management and conservation of coastal 5.4.2.2. Costs of Inaction and Opportunities for and marine habitats and the protection of their bio- diversity are included in the PNE (93-214/PR, in the Change process of being updated) and the Framework Law In 1998, the Regional Program for the Environment of of the Environment (FLE) (Decree No. 94-018/AF, also the Indian Ocean Commission estimated that the eco- in the process of being updated). This includes the nomic value of coral reef ecosystem services for Mwali management and protection of mangroves, beaches, National Park alone was approximately US$2.8 million, coral reefs, and seagrass beds, and their associated equal to 1.3 percent of the national GDP at that time biodiversity. Order No. 01/033/MPE/CAB provides the (Malterre et al., 2018). Assuming that the size and status  list of protected species. The regional directorates are of the reefs of the different islands have not changed responsible for the implementation of these environ- over time and given that Mwali’s reefs make up 38 per- mental policies. As with most environmental legisla- cent of the country’s total reefs, this equates to an eco- tion in the Comoros, implementation and enforcement nomic value of US$7.2 million for all of the reefs of the remain a challenge. With the adoption of the National Comoros, equal to 0.58 percent of GDP in 2020. Protected Areas System Law (2018; No. 18-005/AU) and the Presidential Decree of Protected Areas (2019; Protection and restoration of coastal and marine ecosys- No. 19-129/PR), there is more specific legislation in tems are fundamental to develop the Comoros tourism place for the protection of habitats (see Box 22). sector, whose potential is far from being fully harnessed (see section 5.6). Specifically, tourism on Mwali is quite dependent on the presence of the rich coral reefs, 5.4.3 The Way Forward though to what extent this is illustrated in income is unknown. To better understand the implications of coral Fisheries reef degradation for tourism, fisheries, and overall resil- ience, additional studies should be conducted. Scale up the implementation of fisheries • co-management with local communities, pro- The physical connectivity between coastal ecosystems viding livelihoods support to ensure effective man- (fringing coral reefs, seagrass meadows, and man- agement. The recommendation should capitalize groves) offers more ecological benefits than the sum on the successful experiences carried out under of each ecosystem’s benefits. The ecological benefits CoReCSuD, SWIOFish1, and SNAP , as well as by of one ecosystem extend to adjacent ones and increase local actors, and build on lessons learned to scale the capacity of each ecosystem to recover from stress. up the positive results achieved in terms of sus- Interrupting the physical interaction between man- tainable management of the sector and improved groves and seagrass by increasing land reclamation, livelihoods. for example, may lead to a cascade of negative effects that will significantly increase the cost of maintenance • Intensify efforts to combat IUU fishing. The of the overall Comoros marine environment. Comoros needs to be enabled to sanction IUU fishing, at the industrial but particularly the small- Thus, an integrated approach to coastal management scale level, given the significant, documented im- is needed to minimize the cost of ecosystem restora- pact of illegal artisanal fishing on coastal fisheries tion. The development of a sustainable blue economy and the ecosystem more broadly. IUU fishing in the as suggested by the PCE 2030 could serve as a tool small-scale segment can be addressed by building to achieve such an integrated approach, for example, on SWIOFish1 achievements and integrating les- through the development of an integrated coastal sons learned, including by training the staff of management plan and a blue economy roadmap unions, associations, and cooperatives who can, in (based on Strategic Framework for a National Policy turn, train fishers. For the industrial segment, the on the Blue Economy [BESF]), and supporting the Comoros should have its own IUU register, for ex- Marine Spatial Plan initiated by the General Planning ample, building to the IOTC IUU vessel list, as well | 78 |   Comoros Country Environmental Analysis as procedures to quickly address IUU events when Box 25. Global Fund for Coral Reefs they are identified. Better participation in interna- Investment Window tional and regional coordination efforts would also support efforts against IUU fishing and potentially As part of the Green Climate Fund private-sector offer opportunities to mobilize resources. program in the blue economy, the Global Fund for Coral Reefs Investment Window will create a • Improve the availability of data on the status of private equity fund to encourage investments in fish stocks. Data collection and analysis should be the blue economy, protecting coral reefs (Green improved to inform policy making that supports Climate Fund 2021). The Comoros is one of the effective monitoring, enforcement, and manage- 17 countries where this program will be imple- ment of fisheries resources. mented. The program aims to mitigate or elim- • Identify opportunities for private sector engage- inate existing local stressors on the coral reefs. ment through the identification of innovative fi- Investments will be made in the following sectors: nancing approaches to blue carbon projects. • Sustainable ocean production: These efforts • Adopt a sustainable fisheries strategy to improve will focus on supporting fishermen to adopt consistency among fishery decrees and help ad- more sustainable fish capture techniques, dress the key challenges. The strategy should pro- helping fishermen manage stocks or transport vide a range of options for how best to address more sustainably, and facilitating growth in key challenges (such as IUU fishing, unsustainable mariculture and aquaculture. fishing practices). The strategy should also include • Sustainable ecotourism: Measures include recommendations to support sustainable fishing, supporting sustainable hotel and tourism ac- ways to enhance international/regional cooperation, tivity businesses that incentivize the protec- and strengthen co-management of the resources. tion of coral reef ecosystems upon which the tourism industry is dependent. Coastal and Marine Ecosystems • Sustainable infrastructure and waste (pollu- • Restoration of mangroves and seagrass should be tion) management: This includes improved promoted, accompanied by the development of plastic waste management from new business an integrated coastal management plan and sup- models and technologies, improved treatment ported by improved local capacities. Mangrove of sewage and wastewater, and the adoption of restoration efforts should be underpinned by re- organic fertilizers, among other efforts. current mapping of mangroves to enhance the These interventions will strengthen adaptive understanding of current and future trends.The po- capacity, reduce exposure to climate risks, tential for mangroves to attenuate waves through increase reef resilience, and enhance the pro- nature-based flood defense should be assessed to tection and restoration of reefs. Delays have incentivize mangrove protection and restoration. occurred in implementation as a consequence of the COVID-19 pandemic. • Support the development of coral reef restora- tion projects, possibly under the Global Fund for The Ministry of Agriculture, Fisheries, Coral Reefs Investment Window. Technical and Environment, Tourism and Handicrafts is respon- operational assistance should be provided to the sible for the realization of projects under the Ministry of Agriculture, Fisheries, Environment, fund, through the National Designated Authority Tourism and Handicrafts and the Comorian NFP and the Green Climate Fund National Focal Point. for the GCF in the development of such pro- An accredited entity will need to be appointed to jects. Also recommended is a special focus on accredit the fund. The size and the content of the co-management principles, gender aspects, and projects in the Comoros are currently unclear. sustainability of activities beyond project closure, Thus, the Ministry of Agriculture, Fisheries, for example, by identifying diversified and sus- Environment, Tourism and Handicrafts, and the tainable income sources (such as tourism activi- NFP for the GCF would benefit from support in ties) and by improving capacity adequately. For the development of the project terms of refer- climate-smart interventions, a focus on the res- ence, as well as in assuring the involvement of toration of coral reef species that have shown re- local communities in the restoration efforts. silience to higher temperatures is recommended (see Morikawa and Palumbi 2019). Key Environmental Sectors   | 79 | • Strengthen financial support for the creation of Bank (2018), the Comoros generates 0.32 kilograms of the three national marine parks. Given that the solid waste per capita per day. While this rate is lower creation of the parks is pending signature and the than the global average and the Sub-Saharan African Comoros Environmental Fund (FEC) is not func- region rates, studies indicate that most of the waste tional, this process could be supported with more generated (83 percent) is inadequately managed investment to enhance the capacities of National (Jambeck et al., 2015). In addition, with regard to plas- Network of Protected Areas (RENAP). tics in particular, mismanaged solid waste is projected to increase significantly in the coming years (Jambeck et al., 2018). 5.5. Solid Waste Management Organic waste constitutes the largest fraction (60 percent) of household waste, followed by organic waste produced by markets. 30 As an example, Figure Key Features 31, which shows the composition of household • In spite of the relatively limited amount of waste in Mutsamudu Bay,31 Ndzuwani (Fouqué and waste generated on a per capita basis (0.32 Durand 2018), clearly illustrates that a large fraction kilograms) per day, open-air landfilling and of the waste is, in theory, recyclable and therefore open burning are widespread practices. could be recovered in lieu of being disposed of in unsanitary ways. • Limited available space, a growing population, and changing consumption patterns represent In spite of the relatively limited amount of waste major challenges to the development of sus- generated, household collection services and cov- tainable integrated solid waste management erage are currently nonexistent because of tech- (ISWM). nical, financial, and organizational challenges. Much of household-generated solid waste in the Comoros • Ineffective solid waste management threatens is not collected, severely affecting the environment. the health of the Comorian population through With no public collection services, households turn marine litter and its impacts. to the private sector for waste collection or find • Litter-polluted rivers, coasts, and seas damage other alternatives which negatively affect both the natural assets, including beaches, coral reefs, environment and health (Figure 32). For example, and marine life, and can hinder the develop- in Ndzuwani, household rubbish is often illegally ment of NBT. dumped or burned, while in Mwali and NGazidja, more than 56 percent and 40 percent of households, respectively, illegally dump trash on the side of the Solid waste management in the Comoros remains street or along the coast (World Bank 2021c). Only in a major challenge, and no significant improvements Moroni does public waste pick-up cover the majority have been achieved in recent years. Compared to the of households (approximately 60 percent), while pri- assessment made by the Indian Ocean Commission vate operator coverage is relatively low. Beach dis- in 1996, which noted a “virtual absence of public or posal is a critical issue, especially in Fomboni and private waste management and no waste treatment Mutsamudu. facilities” (Indian Ocean Commission, 1996), the cur- rent situation has not changed significantly aside Aligning the development, improvement, and oper- from some minor improvements in the larger towns ation of appropriate landfill sites with the required (Jaglin, Debout, and Salenson 2018). Despite several environmental standards is a main challenge. On initiatives, the responses of the State, local author- Ngazidja, the Itsoundzou landfill site is currently ities, village associations, and international partners being operated and accommodates the waste in the continue to be limited and ISWM, which combines municipality of Moroni, although significant improve- precollection, sorting, transport, treatment, recycling, ments are needed. On Ndzuwani, the commune of and disposal measures, remains severely underdevel- Domoni has a landfill site under development located oped (Union des Comores 2019a). in Hacharifou. Other sites are currently being evalu- ated in Mwali and in Ndzuwani (Union des Comores 5.5.1. Sector Characteristics 30 Markets in Moroni produce, on average, 1 ton of waste per day, 68 percent of which is organic waste (Commissariat Most of the waste generated in the Comoros is général au plan 2019). mismanaged, and waste generation is expected to 31 Waste composition data were only available for Mutsamundu increase in the coming years. According to the World Bay. | 80 |   Comoros Country Environmental Analysis Figure 31.  Composition of household waste in Mutsamudu Bay, Ndzuwani in 2014. 1.1% 2.2% 2.2% 0.9% 0.3% 5.3% 7.5% Organic Biodegradable liƩer Sanitary texƟle 16.4% PasƟc 64.3% Paper/cardboard Source:  Fouqué and Durand 2018. Solid waste along the coastline of Ngazidja Photo Credit: Deltares 2019). Technical analyses, environmental impact bronze, and batteries are reported to be exported to assessments, and additional studies on the capacity Tanzania, where they are recycled or reexported and coverage of landfills that are operational, under (Jaglin, Debout, and Salenson 2018). The significant development, and projected are needed. amounts of waste thrown on roads, beaches, and illegal dumping areas could potentially be recovered Recycling systems are largely undeveloped, and for local recycling. The establishment of the first recycling activities are mostly informal and occurring waste recycling and sorting center opened in 2018 by at the local level. Many informal initiatives are imple- the Municipality of Moroni currently treats 1 ton of mented by Comorians, such as making recycled bags recyclable waste per month and is a step in the right from recovered paper and fabrics, recycled rope from direction, if a modest one. plastic sacks, carpets using the remains of plastic san- dals from informal dumping on the coast, pots out of Hospital waste is a pressing issue for the Comoros, aluminum cans, and tablecloths created by groups especially in the aftermath of the COVID-19 pan- of women from used textiles, as well as the use demic. The majority of this waste is not properly cardboard bricks for fireplaces (World Bank 2021c). collected and ends up in the environment including Construction waste is often reused for embankments rivers and the ocean, threatening public health and or for new construction, supporting the potential for highly affecting air, soil, water, and wildlife.Treatment a viable recycling market; however, the ways it is cur- and disposal of the waste that is collected are unsafe, rently used tend to decrease the structural integrity and this waste ends up in uncontrolled dumpsites and, thereby, the resilience of buildings. Iron, copper, because of the lack of appropriate infrastructure, Key Environmental Sectors   | 81 | Figure 32.  Household solid waste disposal in the Comoros by method and island in 2017. Percent of househods 0 20 40 60 80 100 Fomboni Mwali Other urban Rural Mutsamudu Ndzuwani Other urban Rural Moroni Ngazidja Other urban Rural Private pick-up Public pick-up Roadside disposal Beach disposal Burial IncineraƟon Other (not specified) Source:  World Bank 2021c. certified companies, and specific guidelines on hos- of the growing population and new consumption pital waste. It is estimated that hospital and health and production patterns makes these efforts inade- centers in the Comoros generate nearly 230 tons of quate to properly manage the rising amount of solid waste per year, 45 percent of which is biomedical waste generated. waste. Approximately 73 percent of the 230 tons are produced in Moroni, and only half of what is pro- Insufficient budget, inadequate access to technology, duced in Moroni is estimated to be collected and and limited solid waste management skills further disposed of in the official dumpsite. This means that complicate the implementation of ISWM strategies. approximately 84 tons of hospital waste including Since the ISWM system cannot be financed and sup- toxic and infectious waste leak into the environment ported by the municipalities alone, the private sector and ocean. Additional studies and analyses on other and international donors are key partners to ensure hazardous wastes, such as construction or chemical the feasibility of such a significant structural change. wastes, are needed to properly quantify how much The participation of the private sector in solid waste waste is generated per island, as well as to assess infrastructure and service provision, if done properly, the collection and final disposal procedures, to can leverage investment and greatly improve service ensure the availability of sufficient information and provision and support economic development. At the reliable data to develop ad hoc policy interventions same time, the commitment from international donors and investment plans. is crucial, as indicated by the decision made at the Conference of Partners for Development Conference to finance a waste management structural project 5.5.2. Unsustainable Waste Management under the PCE. and Its Drivers Awareness of waste-related risks and challenges Allocation of appropriate landfill sites in alignment among the population is insufficient, whereas the with the required environmental standards is a main commitment of users paired with high social and challenge (Union des Comores 2019a). The island’s fiscal citizenship is fundamental for sound inte- mountainous terrain and limited space makes dif- grated waste management. For a country like the ficult for the GoC to identify and allocate adequate Comoros, where oral tradition is dominant, effec- landfill sites that respect the required environmental tive communication and awareness-raising cam- standards. Furthermore, inhabitants near landfills paigns could play a key role in supporting integrated fear the harmful effects on their health that result waste management. They could remind public from the poor conditions of the landfills and the waste service users of their rights, raise awareness accumulation of waste. On Ngazidja, some improve- of waste management issues and their impacts on ments are being made to the Itsoudzou landfill site, both health and environment, and promote indi- which has been recently developed and will soon be vidual and collective good practices and, ultimately, used for waste disposal. However, the combination behavior change. | 82 |   Comoros Country Environmental Analysis Growing urbanization poses an additional pressure of the population, while also increasing the risk for on solid waste management. Cities do not have the social unrest. Unauthorized landfills have become a required financial resources and infrastructure to major source of pollution of natural resources such keep up with growing urbanization, pushing more as water, land, and air, contributing to the prolifera- urban dwellers to live in informal settlings with very tion of disease pathogens. Furthermore, fly-tipping limited or no access to solid waste services. This trend and open-dumping sites constitute major sources of is exacerbated by the morphology of the archipelago: leakage of plastic waste, polluting both the terrestrial the islands’ mountainous terrain limits the areas avail- and marine environments (see section 5.4). As a result, able for new settlements, contributing to increased both air pollution and unsafe WASH are among the population density and a concentration of the house- most important risk factors accounting for the high hold waste generated within a limited area—which disease and death burden in the Comoros. In addition, is also an opportunity to establish an effective waste near cities and large villages, dumping sites are more collection system covering a limited area. In compar- abundant and are occasionally the cause of disputes.32 ison to urban areas, rural areas have a higher share of waste that is not collected and is left on the road- Against this backdrop, it would be crucial for the side, lower levels of public waste pick-up coverage, Comoros to develop a comprehensive strategy for and an equally strong contribution to environmental ISWM, considering interventions in waste preven- degradation. tion, collection, disposal, and recycling. The impor- tance of ISWM for the Comoros is clearly illustrated Efficient ISWM and strategic planning in the by the PCE, which has identified integrated waste Comoros are also constrained by the lack of good management as one of the six structural projects to be data. Reliable and updated data are essential to implemented, allocating €35.575 million (US$39.320 allow robust analysis of development scenarios million). The project will allow the establishment of an for the sector, while supporting the monitoring of operational system for the sustainable management progress against targets set forth in the PCE and of waste, while contributing to the strengthening of providing the basis for ongoing strategic planning. the logistical and operational capacities of the public The availability of good data is also essential to con- waste management service. The overall objective of duct environmental impact assessments for landfill the project is to reduce waste-related environmental sites. Evidence-based projections to anticipate future impact and economic losses by contributing to the changes in the sector are also lacking but are cru- development of better integrated management of cial for planning efforts to address the challenges household and special waste. The project has three linked to growing urban waste generation, as well specific objectives: (1) provide the country with the as to maximize recycling opportunities. Data collec- necessary infrastructure for the waste management tion and analysis are also needed to properly assess sector, (2) promote good practices on integrated the impact of the potential increase in tourists on the waste management, and (3) establish an institutional already fragile waste sector. and regulatory framework for waste management. Strengthening waste prevention policies is an impor- tant step to steer the country toward a sustainable 5.5.3. Costs of Inaction and Opportunities consumption and production pattern (Figure 33). for Change Indeed, prioritizing waste prevention is key, especially The lack of appropriate solid waste management in a small island state such as the Comoros, where services and infrastructure leads to unhealthy space for landfill infrastructure is physically limited. solid waste-handling practices and environmental In other countries in the region such as Zanzibar and degradation. As in many other low- and middle- Seychelles, for instance, certain types of items, par- income countries lacking in solid waste manage- ticularly plastic such as for plastic bags, are being ment capacity, the population without access to restricted, repurposed, or reused. In this regard, an solid waste collection services often resorts to open assessment of the most problematic waste products and uncontrolled fires to burn solid waste, including would be useful to inform decision-making to restrict plastic. This results in the release of chemicals and their circulation (for example, bans of or fees for plastic fine particles, which pose serious risks to public bags), incentivize design for reuse, and/or promote health and the environment (Velis and Cook 2021). alternative materials. If adequately implemented, this strategy could also enhance small community-based Unsanitary final waste disposal affects the environ- ment of the Comoros and affects the living conditions 32 La Gazette des Comores, May23 2022, n0 4129. Key Environmental Sectors   | 83 |  Waste hierarchy as part of an integrated solid path toward a sustainable and efficient waste manage- Figure 33. waste management strategy. ment system in the Comoros, while contributing to economic development. Waste hirarchy Final disposal facilities need to be upgraded, and fur- PRODUCT PREVENTION ther opportunities for circularity exist from waste (NON-WASTE) energy recovery. As mentioned in the sixth structuring PREPARING FOR REͳUSE project of the PCE (Component 3), energy recovery RECYCLING through the production of biogas is one of the three RECORVERY WASTE recovery/recycling schemes for household waste and has translated into the deployment of three bio- DISPOSAL reactors (for Ngazidja, Ndzuwani, and Mwali) (Union des Comores 2019a). Therefore, investments should be made in well-managed final disposal sites and to Source:  European Commission. upgrade/contain existing landfills, especially those close to the coast to prevent leakage into the sea/ coastal areas. For each island, an EIA should be car- businesses, thus generating benefits that go beyond a ried out to determine whether the proposed sites are reduction in waste volume. feasible. In addition to waste prevention, opportunities exist to Another key component revolves around opportun- expand waste collection services and increase volun- ities that may arise from improving waste composting tary collection points. These are already foreseen in and recycling. The large fraction of organic and food the sixth structuring project of the PCE (Component 2) waste provides a great opportunity for the Comoros as critical measures to prevent less sustainable to diminish the volumes of waste for disposal, reduce and more harmful handling practices, such as open the pressure on landfills and, in particular, produce burning or illegal dumping. Another major oppor- high-quality compost for local farmers. The sixth struc- tunity lies in the development of community-based turing project of the PCE (Component 3) foresees two “waste banks, ” which would encourage citizens to schemes for recycling: (1) installing compost produc- sort and deliver recyclable waste items (for example, tion units and (2) setting up composting platforms plastic bottles, aluminum cans, glass bottles, paper), at the national level. Additionally, a waste recycling especially if these products are exchanged for house- center should be set up on each island to support the hold items or food. optimal exploitation of recyclable waste (Union des Comores 2019a). Against this backdrop, the Comoros Against this backdrop, it would be extremely ben- would need to improve waste separation at the source, eficial for the Comoros to increase private sector a key component for recycling, which is still marginal engagement in waste services, which remains lim- with only 19.3 percent of households concerned with ited. A case in point is the city of Moroni, where the home sorting (Ali et al., 2018). The PCE 2030 aims to level of collection services provided by private oper- improve sorting systems at the source, while organ- ators is relatively low and the management of facilities izing garbage bins and garbage cans to receive sorted financed by public subsidies remains unsatisfactory. waste and transport the collected waste to the waste To step up the role of the private sector, it is funda- treatment centers according to their source. mental to strengthen the financial sustainability of the waste sector, gradually implementing a fee for waste In addition to these key areas, it would be extremely collection and setting up a professional private oper- beneficial for the Comoros to uphold any efforts ator with clear specifications and performance-based in making waste management more sustainable compensation (World Bank 2014). An increase in local through more intense and targeted communica- solid waste taxation would strengthen the sector’s tion between the institutions and population of the self-financing capacities and sustainability and rein- Comoros. More responsible behavior by Comorians force the PPP framework, which would create a favor- could represent a key enabler for an effective ISWM. able environment for much-needed private sector This could be achieved, for instance, by carrying out investments. Indeed, given that public expenditures awareness-raising campaigns on waste prevention alone would fail to address the challenge of waste and handling practices in schools and local commu- management, the participation of the private sector is nities. To create support from the population for the pivotal to leverage investments and trigger a positive establishment of ISWM, priority should be given to (1) | 84 |   Comoros Country Environmental Analysis making all practical information available to users, (2) supporting awareness-raising campaigns to promote Box 26. Overview of PCE Structuring Project 6: more responsible behavior in waste management, Integrated Waste Management and (3) obtaining greater commitment from target populations. Component 1: Final waste treatment • Development of three final waste treatment 5.5.4. Institutional and Legal Context centers Since there are no specific legal texts on solid waste • Installation of three bioreactors at sites for 30 management, this sector is broadly governed by the to 80,000 tons of waste/year 1994 Framework Law of the Environment, which is currently in the process of being updated (see chapter Component 2: Waste collection and transport 4). Apart from the 2011 law on plastic waste (Article 33 of Framework Law 11-006/AU of May 2, 2011), which • 243 voluntary waste disposal points was issued with the objective to halt plastic litter, there currently are no specific laws rooted in an overall • Acquisition of rolling stock: 60 waste skips, 486 vision for solid waste treatment or reforms aimed at dumpster trucks, 1,000 trolleys and wheelbar- encouraging the development of a circular economy rows, 1,500 waste bins, spare parts (Jaglin, Debout, and Salenson 2018). • Acquisition of outfits and 2,500 cleaning kits Hazardous and hospital waste also lack a sound legal for community staff and regulatory framework. Several articles of the 1994 law concern the management of chemicals and haz- Component 3: Waste recovery ardous waste, integrating the definition of hazardous • Three biogas and compost units for 30 to waste included in the Basel Convention, but implemen- 80,000 tons of waste per year tation would require further scale-up. In addition to the ratification of the Basel Convention,33 the Comoros • Three waste recovery centers also ratified the Bamako Convention34 and Stockholm Convention.35 The  1994 law does not specifically • 20 prefectural composting platforms address biomedical and hospital waste, which are not • Three engine oil refineries covered by an ad hoc legal framework. Component 4: Institutional and regulatory Acknowledging this critical gap, the Ministry of Health, which is responsible for hospital waste man- framework agement, adopted the five-year National Hospital • Revision of texts, particularly the Environmental Waste Management Plan (Plan National de Gestion Code des Déchets Médicaux [PNGDM]) in 2018. This plan identified five strategic pillars: (1) strengthening the • Implementation of the National Integrated legal and regulatory framework, (2) standardizing Waste Management Agency (ANAGID), devel- medical waste management practices, (3) building the opment of business plan and sector financing capacity of medical facilities with regard to medical plan waste management, (4) involving local communities, and (5) enhancing the evaluation framework. In April • Capacity building through continuing training 2020, with the support from the World Bank via the and graduate training (license and masters pro COMPASS Project, the GoC revised the plan to include “Waste Management and Recovery”) • Development of impact assessments and a 33 The Basel Convention, adopted in 1989 and entered into national waste management policy and asso- force in 1992, is a treaty on the control of transboundary ciated implementation documents movements of hazardous wastes and their disposal. 34 The Bamako Convention, adopted in 1991 and entered into Component 5: Information, communication, and force in 1998, prohibits the importation of hazardous waste good practices into Africa as well as dumping or incineration into the oceans and inland waters, including radioactive waste. • Organization, management, and dissemi- 35 The Stockholm Convention, adopted in 2001 and entered into force in 2004, aims to protect human health and the environ- nation of useful and practical information ment from persistent organic pollutants. Key Environmental Sectors   | 85 | can help finance waste management services, as well (ANAGID reception service, free phone as setting opportunities for investments by the private number, website, and social networks) sector and integration of the informal sector. • Communication on waste management issues (radio broadcast, awareness campaign, com- 5.5.5. The Way Forward munication media) • Develop a comprehensive strategy for ISWM, con- • Promotion of good practices (events, labeling, sidering interventions in waste prevention, collec- and annual awards) tion, disposal, and waste recycling. This should be in line with the PCE 2030, structuring ISWM. An im- Source:  Union des Comores 2019. plementation roadmap should be prepared for in- frastructural development, taking into account the implementation capacities of national, regional, and local governments, as well as societal parties. specific COVID-19 considerations and a budget plan • Invest in services and infrastructure capable of en- for implementation during 2019–2024. suring adequate waste collection, recycling, and dis- The current fragmented and decentralized institu- posal. Expand and enhance waste collection services tional setting represents another major challenge for to households that are not yet covered, minimize col- the implementation of ISWM, as the decentralization lection losses, and increase voluntary, community- process has resulted in redundant and unclear roles based collection points, including those for recyclable and responsibilities. Although local authorities have materials (“waste banks”). Improve recycling by set- the mandate to collect, treat, and dispose of waste,, the ting up recycling, biodigesters, and composting plat- country is still in a transition toward the full delegation forms. Finalize the landfill sites already identified in of competencies to local authorities and is in urgent the PCE and identify new final waste storage sites. need of developing and implementing sustainable • Reduce generation of solid waste by incentivizing waste management (World Bank 2021c). The National designs for reuse and using alternative materials. Agency for Integrated Waste Management (ANAGID) To facilitate this process, a life-cycle assessment of is not yet fully operational and lacks structural funding. the most problematic waste products, in particular A minimum operating budget is provided through a those with higher potential for reuse and recyc- subsidy from the State, providing ANAGID funding ling, should be conducted, followed by a feasibility for three projects currently being launched: (1) the study for policy and regulatory options to increase DECOR project financed by the government of Italy for circularity (for example, market-based instruments the establishment of a biogas and compost produc- to restrict, substitute, or incentivize reuse of plastic tion center, (2) a project on the management of chemi- items). cals and hazardous waste financed by UNDP , and (3) a recycling project to manufacture paving stones from • Raise awareness on waste-related risks and oppor- plastic and metal waste in collaboration with a South tunities, in particular the prevention of solid waste African company. generation and sorting at source. Communication campaigns, awareness-raising events, and capacity Improving the institutional and legislative framework building should be planned to promote behavior is a crucial enabler to adequate implementation of the change by all stakeholders involved. ISWM. From a legal perspective, it would be important • Improve private sector participation in waste man- for the Comoros to close this legislative gap by fol- agement. Promote dialogue with the private sector, lowing up the update of the Framework Law with the implement a waste-collection fee, and identify spe- development of comprehensive legislation for solid cific PPPs in Comoros cities. waste management. From an institutional perspec- tive, although the establishment of the ANAGID was an • Improve data collection and analysis. To develop ef- important first step, the Comoros still needs to clearly fective and sustainable ISWM policies, it is crucial for define the responsibilities of all actors involved in waste the GoC to conduct in-depth, sound studies on cost re- management, as well as to strengthen the technical covery and sustainability aspects, as well as to quan- and institutional capacities of all stakeholders. In addi- tify the environmental and public health footprint of tion, it would be important to combine such reforms waste in both rural and urban areas. Assessment of with the development of market-based instruments (for the potential impact of tourism-sector development example, environmental, tourist taxes, and levies) that on waste management in the country is also essential. | 86 |   Comoros Country Environmental Analysis Implementing such studies would be instrumental for 3.4  percent of national GDP36 (World Bank 2020j). the Comoros to close the gap through informed deci- Especially when compared with neighboring islands sion-making across all aspects of ISWM. such as Seychelles, Madagascar, or Mauritius, the tourism sector of the Comoros is significantly under- • Support the development of comprehensive legis- developed. The number of international tourist lation and help define the institutional framework arrivals varied between 20,000 and 30,000 per year for solid waste management. Adopting specific laws between 1996 and 2020 (Figure 34).37 Despite its and reforms rooted in an overall vision for solid geographical position as a strategic stopover, the waste treatment is essential for the country. In addi- Comoros is neglected as a cruise tourism destina- tion, it would be extremely beneficial to clarify roles tion, and only eight cruise ships visited the country and responsibilities between municipalities and cen- between 2008 and 2018. Air connections are also lim- tral government to address the gaps resulting from ited, with direct flights only to seven countries.38 The the incomplete decentralization process. In addi- sector employed approximately 1,600 people in 2018: tion, ANAGID should be provided with the required approximately 1,000 in Ngazidja, 470 in Nzwani, and funding and vision to implement its mandate. 140 on Mwali (Union des Comores et al., 2019). Diaspora tourism has a notable socioeconomic role 5.6. Nature-Based Tourism in the Comoros. Visiting families from the Comorian diaspora, in particular during the “grand mariage” season, represent more than 50 percent of the arrivals, Key Features whereas leisure and business travelers account for only 14.3 percent and 23.3 percent of total arrivals, • The tourism sector is dependent on the natural respectively.39 Moreover, since the French Comorian resource base of Comoros and currently con- diaspora travels mainly in July and August, the tributes to merely 3.4 percent of GDP. route becomes particularly costly during the high season, discouraging other travelers from visiting • The development of NBT is currently hampered the Comoros (World Bank 2013). France, including by limited tourism facilities, infrastructure (ports, French overseas departments and territories as well as roads, waste management, and freshwater the French Comorian diaspora, is the main reference supply), a historical image of political instability, market, representing almost 65 percent of arrivals limited connectivity of long-haul flights, and in the Comoros, including 7 percent coming from unfavorable conditions for private investors. Reunion and another 7 percent from Mayotte. • Prior to considering NBT as a key economic The development of the tourism sector is currently growth sector, it is essential to conduct an ex supported by the World Bank through the PIDC ante analysis to clarify the demand for tourism project. The PIDC includes a tourism component which and define the Comoros target market. focuses on strengthening key tourism sector institu- • The natural capital of Comoros could support tions, policies, and regulations. The activity is working the NBT sector’s growth, contributing to con- on enhancing the attractiveness of the country, serving the natural resource base and sus- paving the way for a sustained effort to address the taining local livelihoods. long-standing sector constraints, supporting the tech- nical capacities of tourism firms, and upgrading some • The ambitions for the tourism sector are high- lighted in the strategic pillars of the PCE 2030 36 The BESF indicates a general lack of reliable statistics on and as its first proposed flagship project. the number of jobs and revenues deriving from tourism in Comoros. • Sustainable management of natural capital, 37 This number was fairly stable from 1996 to 2017, with a and especially protected areas, is an essential decline from 2006 to 2011 due to political unrest and insecu- prerequisite for NBT strategy and implementa- rity, spiking to 35,000 and 45,000 arrivals in 2018 and 2019, tion plans. respectively, before the COVID-19 pandemic, which reduced international tourist arrivals to approximately 10,000 or less. 38 As of August 2022, these countries are Egypt, Ethiopia, Kenya, Madagascar, Mayotte, Reunion, and Tanzania. 5.6.1. Sector Characteristics 39 These figures refer to the latest year available, namely 2011 (World Bank, 2013). As further illustrated in this chapter, the The current tourism sector of the Comoros is lack of updated and reliable data is a constraint for sound still largely underdeveloped, contributing to only development of the sector. Key Environmental Sectors   | 87 | Figure 34.  Trend in the number of international tourist arrivals in the Comoros from 1996 to 2020. InternaƟonal tourism arrivals 50000 40000 Nmber of arrivals 30000 20000 10000 0 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 Source:  World Bank 2020e. tourism sites. An emerging tourism sector may also be inadequate and unsafe transportation infrastructure an opportunity for agribusiness development, as more (Union des Comores 2019c). Currently, only 65 percent dynamic tourism in the country, especially by foreign of all roads are paved, and roads are generally of poor tourists, could increase the demand for high-quality quality because of lack of investments, with 80 per- local food products, provided that food production is cent in need of rehabilitation (World Food Programme able to meet international standards. 2019). Inter-island connectivity, which is specifically important for NBT, comes with safety issues resulting NTB, a tourism segment that includes activities and from unsafe boats and is hampered by high costs products that depend on natural resources in a wild or associated with air transportation (World Bank 2020j, undeveloped form (World Bank 2020l), could develop 2020n). Another main hurdle hampering the develop- in the Comoros by leveraging its rich natural asset ment of this tourism segment is the lack of adequate base. As illustrated throughout this CEA, the “per- port infrastructure, despite the significant (yet insuffi- fumed islands, ”40 as the Comoros is also called, are cient) efforts to improve the main port of Moroni for abundant in natural resources such as forests, coastal use as cruise terminal. Importantly, the planning and and marine ecosystems, and biodiversity. Ngazidja development of environmentally sustainable NBT is is known for caves, turtles, and the Karthala volcano not adequately supported by an upstream analysis (Ramsar site). Ndzuwani has the Bimbini peninsula on how the sector could position itself at the local and offers essential ingredients from the perfume and international levels. Sufficient, updated informa- industry, as well as highly valued flora and fauna such tion on current tourism performances, the impact of as lemurs, Livingstone’s fruit bats, orchids, and tree tourism on the country’s ecosystems and biodiversity, fern. Mwali, with its national park, offers exceptional and specific guidelines on the carrying capacity of marine biodiversity and is considered the world’s each island are also nonexistent. leading egg-laying site for sea turtles, with 30,000 per year laying eggs on 45 nesting beaches. The island and Despite the sector’s performance and the need for its surroundings offer mangroves, islets with nesting an upstream opportunity assessment, NBT could seabirds, humpback whales, and coral reefs with their have potential as a socioeconomic contributor, while associated species. On land, the Mlédjélé Forest of helping preserve the rich natural resource base and Mwali offers a habitat to endangered species such as strengthening climate resilience. The Comoros faces Livingstone’s fruit bat, the Eulemur mongoz lemur, a significant competitiveness gap compared with and two species of endemic birds (Union des Comores neighboring Madagascar, Mauritius, and Seychelles, et al., 2019).  where tourism accounts for 39 percent of GDP in 2019 (World Bank 2020i) and effective marketing strat- Despite its potential, NTB is largely untapped. Main egies toward luxury tourism led to a record 10 times constraints to the development of tourism, and NBT more international tourist arrivals than the Comoros more specifically, include the lack of waste services (Commission Économique pour l’Afrique 2017). and sanitation, poor quality of hotel services, and Despite the sector’s challenges, there is nonetheless an opportunity for the Comoros to capitalize on its 40 The Comoros archipelago is also referred as the “perfumed rich natural endowment, providing livelihoods sup- islands” for their fragrant plant life and high production of ylang-ylang, valued for the perfume extracted from its flow- port and improved well-being opportunities to local ers and its oil, which is used as a base oil for perfumes. communities, while protecting its natural resources, | 88 |   Comoros Country Environmental Analysis and ultimately contributing to the economy (Union other sectors, including transportation, commerce, des Comores et al., 2019). In alignment with the energy, fishing, crafts, and telecommunication, the government’s vision and ambitions, the development integrated development of the tourism sector is of NBT could represent a significant source of income expected to have a trickle-down effect, resulting in for otherwise marginalized local communities and, reduced dependence on imports and enhanced pres- as such, be a suitable opportunity for the Comoros ervation of the environment. The ambition for the to support socioeconomic growth while protecting sector is to exceed 200,000 tourist arrivals by 2030, its rich natural resource base.  The development of by having an annual growth of 15 percent per year the NBT sector could also represent a leapfrogging with gradual upscaling. Focusing on NBT, the govern- opportunity for the country to build resilient and ment envisions the development of a seaside resort low-carbon infrastructure at the core of its develop- in Ngazidja, the creation of a tourism village and ment, enhancing the vision of NBT development as agrotourism in Ndzuwai, and the development of an an engine for sustainable development. NBT zone around the Nioumachioua park in Mwali. To improve governance, the GoC aims to advance a favorable framework to attract private investors. The 5.6.2. Government Vision GoC’s priority for the realization of the ambitions for The GoC’s vision and ambitions for the NBT sector the sector will be taking place through the PCE 2030’s are laid out in three key strategic planning docu- flagship project, “A New Tourist Bub in the Indian ments: (1) the PCE 2030 and its flagship project, Ocean, ” 2030 (see Box 27), although the required which serve as the entry point for the prioritization of financial resources have not been secured to start accommodation developments as well as targets for planning implementation. the sector; (2) the National Tourism Strategy report In addition to the PCE 2030, the 2019 National Tourism and the accompanying Strategic Plan 2019–2035, Strategy report, supported by the Strategic Plan which provide planning context and specifications 2019–2035, serves as the basis for planning tourism with regards to governance requirements, the cur- activities (Figure 35) (Union des Comores 2019c). The rent offer, and promotion of the sector (Union des strategy describes accommodations and other infra- Comores 2019c); and (3) the Sustainable Tourism structure to be constructed. The Strategic Plan 2019– Management Plan, which is still in a draft mode and 2035 recognizes the importance of NBT, calling for the is expected to highlight the sustainable develop- development of national parks and focusing on proper ment and management principles for the sector.41 marketing around the biodiversity and endemic However, these strategic planning documents are species of the Comoros. The 2019 National Tourism not fully aligned with one another other, making it Strategy outlines the first steps toward detailed spatial difficult to prioritize interventions and allocate finan- development plans to be developed by the ministries cial resources accordingly. responsible for tourism, finance, and environment, The PCE 2030 envisions the Comoros as a reference as well as by local authorities (Figure 36). It suggests tourist destination in the Indian Ocean Region by the development of land allocation procedures and 2030. Tourism is seen as the potential driving force, status, the location of permanent construction and the as it will lead to increased revenues and GDP , job maximum authorized capacity, and eligibility for tax creation, and livelihood diversification opportun- and financial benefits. The Maison de l’Écotourisme ities. Since the tourism sector encompasses many has been put into place as an institution that acts as a bridge for NBT development and activities. However, 41 The Sustainable Tourism Management Plan was developed due to the COVID-19 pandemic, these activities of in 2021 as part of the UNESCO project “Capacity Building the National Tourism Strategy have not progressed. in Sustainable Tourism Development and Management for Nevertheless, specific guidelines for NBT and spa- World Heritage in Comoros. ”The project sought to strengthen tial planning to ensure activity development within the capacities of key stakeholders in Comoros and develop the Sustainable Tourism Management Plan and an imple- a framework of environmental sustainability are still mentation strategy for the promotion of the cultural sector needed. in Comoros. Cultural and natural resources in Comoros were also mapped through the project, trainings were carried out for local tour guides in the Historic Sultanates of Comoros (UNESCO, 2021), and workshops were facilitated using the 5.6.3. Opportunities for Change UNESCO Sustainable Tourism Toolkit (Figure 44). However, Before planning and implementing infrastructural the status of the project is currently unknown, the Sustain- able Tourism Management Plan has yet to be drafted, and development and investments in NBT, it is critical overall results are not yet openly available. for the Comoros to carry out an ex ante opportunity Key Environmental Sectors   | 89 | analysis of the sector to identify any comparative Box 27. “A New Tourist Hub in the Indian advantages of the Comoros in the tourism market Ocean”: Flagship Project of the PCE 2030 and inform the country’s development of its own competitive NBT offer. Acknowledging the significant The GoC considers the development of the competitiveness gap of the Comoros compared to tourism sector as a driving force for the trans- neighboring tourism hot spots such as Madagascar, formation of the economy of the Comoros and Mauritius, and Seychelles, it is fundamental to conduct one of the five pillars of the PCE 2030 (Union des an upstream opportunity assessment and demand Comores and others 2019). “A New Tourist Hub in analysis to better understand the demand for tourism the Indian Ocean” is the first flagship project of in the Comoros and the current tourism performance, the PCE 2030 (Table 15). assess the real potential for NBT and if and how the subsector could position itself at the local and interna- tional levels, and decide upon the strategic direction to Description of the flagship tourism project   Table 15. take. Given this framework, it would be key to update of the PCE 2030 the 2013 Comoros Tourism Sector Review to pro- Project Description vide useful insight into tourism patterns and improve understanding of tourist profiles (for example, moti- “A New Tourist Hub in the Indian Ocean” is a flagship project of the vation for traveling, country of origin, length of stay, PCE 2030, as tourism is the cornerstone of the emerging economy of and tourism receipts). Such evidence-based analyt- the Comoros. The natural and cultural characteristics in each island ical studies and updated data are needed to inform of the Comoros will be highlighted to stimulate the tourism sector and, consequently, the economy of the Comoros by 2030. the development of realistic and targeted NBT strat- egies and plans and related marketing strategies, General Estimates including the improvement of air and maritime access 1.  Number of tourists in 2026: 100,000 to the archipelago and investments in accommodation 2.  Number of tourists in 2030: 200,000 facilities. 3. Number of beds in 2030: More than 4,000 beds (in newly built hotels, eco-lodges, accommodations, existing hotels, and exten- Conditional to positive results stemming from the sions to existing hotels) proposed upstream opportunity assessment, the sus- tainability of NBT development should be ensured. Technical Description Firstly, in alignment with the government’s National 1.  Construction of three hotels (600 beds) in Ngazidja, one hotel Park Strategy, the expansion of the country’s pro- (200 beds) in Ndzwani, and two hotels (400 beds) in Mwali tected area would need to be formalized. In parallel, 2.  Construction of eco-lodges in Mwali (100 beds), Lac Salé (100 it is crucial to ensure sustainable management of the beds), Mount Tringuini (100 beds), around the Karthala volcano protected area through strengthened capacities of (100 beds), and in Chindini, Chomoni, Male, and Bouni (160 beds) relevant institutions, improved skills in biodiversity Construction of marina in Mitsamiouli 3.  conservation and NBT development, and enhanced 4.  Development and sustainable management of Karthala National biodiversity and ecosystem monitoring. Financial Park, with tourist relays and tourist site and hiking markings sustainability of protected areas is also a key enabler 5.  Development of eco-tourism sites at Mwali National Park of sustainable management and enforcement capaci- 6.  Support for the development of micro-housing ties and, as such, should be taken into account. There 7.  Creation of eco-tourism relays (Mount N’Trigui) are currently limited data on the management effec- 8.  Restoration of the Citadel of Ndzuwani tiveness of Mwali National Park, including on status 9.  Hotel restoration (Al Amal, Sultan MAWANA hotel complex) of biodiversity. The availability of such data would 10. Development of agro-tourism in Ndzuwani improve the sustainability of management, pro- vide lessons learned for the new parks to be estab- Total Project Cost lished, and improve the overall prospects for NBT US$0.746 billion development. Finally, the development of resilient, low-carbon infrastructure would need to be placed at Economic Information center stage to boost climate resilience and the pros- Estimated direct revenue for 2030: US$0.259 billion, equivalent to pect of sustainable development. 10 percent of GDP in 2030 Protected areas could be at the core of NBT devel- Source:  Union des Comores, République Française, World opment in the Comoros as a livelihood support Bank, and UNDP, 2019. asset and potential engine for growth. Building on the successful results of Mwali National Park, | 90 |   Comoros Country Environmental Analysis Figure 35.  Overview of the proposed locations for tourist infrastructure of the 2019 National Tourism Strategy. Source:  Union des Comores 2019c. under the National Park Strategy the GoC com- benefit-sharing mechanisms such as co-management mitted to expanding the protected areas system to agreements with local communities. 25 percent of the national territory, establishing an additional two terrestrial parks (Karthala National The sustainability of NBT development plans would Park on Ngazidja and Mount Ntringui National Park need to be ensured through spatial planning for NBT on Ndzuwani) and three marine CAs (Coelacanth and specific guidelines on the carrying capacity of each National Park in the south of Ngazidja, Mitsamiouli island. This could include, for instance, information Ndroude National Park in northern Ngazidja, and on the maximum number of tourists that can be Shissiwani National Park in Ndzuwani) managed accommodated to avoid environmental degradation through a community-based approach. As under- and requirements to prevent accommodations from lined in the Banking on Protected Areas World Bank overburdening existing infrastructure and increasing report (World Bank 2021e), protected areas often get pressure on the natural resource base. This is in overlooked in economic development plans, because line with recommendations from the 2019 National they are often regarded as mere conservation tools Tourism Strategy (Union des Comores 2019c), which with no linkage to economic development. Yet, in a proposes that these guidelines be developed by country such as the Comoros with rich natural assets, the Ministry of Agriculture, Fisheries, Environment NBT revolving around protected areas could repre- Tourism and Handicrafts. The spatial planning exercise sent a cornerstone for ecosystem conservation, finan- and guidelines on carrying capacity would need to cial sustainability for protected areas management, consider the long-term view to ensure that the natural economic growth, and improved well-being of local capital remains well preserved and, as such, attractive populations. Such an ambitious objective could be (AMCC 2019b; General Secretary of the Presidency achieved in the Comoros by following recommenda- and General Planning Commission 2017). The long- tions from the Banking on Protected Areas report, term view would also need to include the current namely leveraging the attractiveness of sustainably and potential impacts of climate change to be able managed protected areas, ensuring the inclusive- to adequately plan related mitigation and adaptation ness of decision-making processes, and establishing measures. On the basis of such guidelines and spatial Key Environmental Sectors   | 91 | Figure 36.  Overview of components of the UNESCO sustainable tourism toolkit. Sustainable Development GDP Total Wealth Non- Net Produced renewable Human Renewable Natural Capital Foreign Capital natural capital Assets capital Knowledge Machinery Fossil Skills & Urban fuels, Agriculture Protected Experience Assets - Equipment Mangrowes Forests Fisheries Land minerals land Areas in LiabliƟes Structures Worforce. Gender STRATEGIC FOUNDATIONS Guide 1 Guide 2 Guide 3 Guide 4 Understanding Strategy Governance Engagement CORE DELIVERY (ONLY WORK IF STEPS 1 TO 4 ARE UNDERTAKEN) Guide 5 Guide 6 Guide 7 CommunicaƟon Infrastructure Value Guide 8 Guide 9 Guide 10 Behaviour Investment Monitoring Source:  UNESCO 2021. planning analyses, implementation strategies and The potential of NBT development to deliver results enforcement plans could then be envisaged and for the local economy hinges on the establishment implemented at the island and local levels (Moussa of participatory approaches in the decision-making Sambaouma et al., 2017). process and the establishment of benefit-sharing | 92 |   Comoros Country Environmental Analysis mechanisms with local communities, such as co-management of protected areas. Local communi- Box 28. EU Tourism Co-management Project ties need to benefit directly from the tourism activity, for Improved Local Livelihoods not only through jobs and livelihood diversifica- tion opportunities but also through revenue-sharing Co-management of tourism bungalows has arrangements and improved access to public goods been implemented in villages on Mwali in (for example, schools, roads, and health clinics). a project financed by the EU as part of the Benefit sharing could include direct sharing of fees Programme Pluriannuel de Micro Réalisations and other charges, indirect benefits from the gen- (2000–2006). In this €4.4 million project, the local eration of employment, and PPPs connected with community constructed and co-managed bun- tourism in protected areas. Capitalizing on the pos- galows for tourism. All employees at the bun- itive experience of the protected area in Mwali, the galows were local volunteers who were elected GoC should ensure involvement of local communities democratically on an annual basis. Tourists who in upcoming protected areas, with a specific focus on stayed at the local bungalows could make a youth and women, given that they have the highest positive impact through local revenue genera- unemployment rates. Mobilizing and involving local tion that was invested in scholarship grants and communities in NBT development plans and oppor- improvements to health centers. However, fol- tunities would also contribute to reducing poten- lowing the cyclone in 2019, only one bungalow tial social tensions due to controlled use of natural remained operational, at Itsamia village. Given resources and support behavioral change toward that the community bungalows were considered the natural asset on which revenue generation and successful and beneficial for local investments, overall wellbeing is based. Awareness raising and similar projects focusing on reinvesting part capacity building on the benefits of protecting the of the revenue in local villages could be con- natural assets and leveraging sustainably its rev- sidered in other nature-based touristic areas. enue potential would also be needed for local popu- lations to ensure understanding and incentivize participation. energy infrastructure or envisaged to be self-suffi- cient through, for instance, solar power for energy The future of NBT development in the Comoros generation. Circular approaches to waste and sani- strongly depends on the availability of appropriate tation management could be envisaged to support transportation infrastructure on and between islands sustainability innovatively while attracting the high- and at the national level. In line with both the flag- end tourism segment. ship and structuring projects of the PCE 2030, the GoC For the Comoros to leapfrog the competitiveness gap aims to improve roads, ports, and airports and intro- in tourism with neighboring countries, a sustainability duce ferries (Union des Comores 2019a; Union des certificate for hotels and accommodations could Comores et al., 2019), with a special focus on investing be envisaged and the “Vanilla Islands”42 concept in safe and fast inter-island transportation. The PCE could be leveraged. The certificate aligns with the 2030’s “Unifying the Islands by Sea” flagship project ambitions laid out in the 2019 National Tourism foresees the development of an inter-island ferry Strategy report and could mainstream sustainability service, which requires both the development of tech- practices in the country’s hotel business, benefiting nical capacity and investments in equipment. It will both the tourism sector and the ecosystem. According be crucial to ensure that these plans are designed and to the 2019 National Tourism Strategy report, this implemented within a context of socioenvironmental certificate should be designed and managed by the sustainability. Maison de l’Ecotourisme (Union des Comores 2019c). Accelerated progress in drinking water manage- The  Sustainable Tourism Label (SSTL)43 has already ment, safe sanitation, and waste management is also a key requirement for increasing the pro- 42 The Vanilla Islands is a regional cooperation aiming to pro- spects of NBT development. Waste and sanita- mote tourism in Comoros, Madagascar, Mauritius, Mayotte, tion infrastructure and management of freshwater Reunion, and Seychelles. Vanilla is the common asset of these resources are required to safely and adequately island nations. More information can be found at https:// www.vanilla-islands.org/. accommodate tourists while avoiding increasing 43 The SSTL is a sustainable tourism management and certifi- pressure on the country’s natural resource base. cation program designed specifically for use in Seychelles. Accommodations should either be connected to the It is voluntary, user-friendly, and designed to inspire more existing and planned water, sanitation, waste, and efficient and sustainable ways of doing business. Key Environmental Sectors   | 93 | been adopted successfully by Seychelles, which could would need to formalize the expansion of the be used as a reference point in support of the design country’s protected area cover in alignment with of the program and establishment of criteria44 for the government’s National Park Strategy, ensure earning the certificate. To successfully implement the sustainable management, adequate biodiversity, certificate, financial support and technical capacity and ecosystem monitoring, and envision mechan- development would need to be provided to enable the isms that may ensure financial sustainability. hotels to comply with the requirements. In parallel, the Comoros could leverage the “Vanilla Islands” concept o Improve data availability and monitoring on biodi- by enhancing marketing and branding opportunities versity and ecosystems in protected areas. Regular and benefiting from improved integration with the assessments of the status of biodiversity and eco- regional tourism market, which currently focuses systems in protected areas are recommended to on neighboring Madagascar, Mauritius, Mayotte, inform the shaping of policies, improve NBT serv- Reunion, and Seychelles. The sustainable expansion ices, assist local communities effectively, and en- of the port at Moroni would have to be prioritized to sure proper conservation of the natural capital of facilitate cruiseship stopovers and would need to be the Comoros. done within the framework of socioenvironmental o Adopt specific guidelines on the carrying capacity sustainability. of each island to ensure that NBT planning and de- Finally, NBT development needs to be embedded in a velopment are sustainable. The carrying-capacity sound and effective institutional framework. Currently, guidelines would need to consider the long-term the PCE 2030, the National Tourism Strategy report, view to ensure that the natural capital remains and the Strategic Plan 2019–2025 are not fully aligned. well preserved and, as such, attractive. Therefore, it would be crucial for the GoC to increase o Ensure participatory approaches in deci- coordination between these strategic documents to sion-making processes, upscale co-management ensure a common strategic direction, effective pri- opportunities, and ensure the establishment of oritization of interventions, and adequate financial benefit-sharing mechanisms with local commu- resource allocation. nities. Successful co-management pilots such as the community bungalows established in 5.6.4. The Way Forward Mwali National Park ensure local benefit sharing of tourism revenues and provide an incentive • Conduct an upstream opportunity analysis and data for behavioral change of local communities to- gap analysis to understand the demand for NBT, its ward the value of environmental conservation. potential, and the best-suited market for NBT as a Awareness raising and capacity building on sus- prerequisite to development of sector strategies tainable tourism management and the benefits and plans. This should include updating the 2013 of environmental conservation are also recom- Comoros Tourism Sector Review to provide an ev- mended to ensure understanding and incentivize idence-based understanding of how the Comoros participation. could position itself in the NBT market. Conditional to positive results stemming from the above ana- o Develop safe and sustainable transportation lysis, the following are suggested: infrastructure, ensuring that plans are de- signed and implemented within a context of o Value the key role of sustainably managed pro- socioenvironmental sustainability. Many infra- tected areas as effective conservation tools but structural improvements are required to facilitate also as livelihood support assets and potential NBT development, including for tourist transpor- engines of growth through NBT. The Comoros tation on and between islands. As inter-island transportation is currently unsafe and/or costly, 44 SSTL criteria could include systemic sustainable man- priority should be given to the development of a agement of health and safety; waste reduction, recycling, ferry service, as proposed in the PCE 2030 flag- and circularity; reducing the amount of fresh water used through rainwater collection, water reuse, and recycling; ” ship project “Unifying the Islands by Sea. reducing energy expenditure; fair treatment of staff and providing opportunities to local people; conservation by o The development of the NBT sector needs to be making a positive contribution to the local community and supported by accelerated progress in drinking conservation initiatives; receiving and displaying gestures water management, safe sanitation, and waste of recognition by the community for conservation practices; and recognition of guest satisfaction with the sustainability management. The development of waste and of the business. sanitation infrastructure and the management of | 94 |   Comoros Country Environmental Analysis freshwater resources are required to safely and offer while contributing to conservation of the adequately accommodate tourists, while avoiding natural resource assets on which the offer would increasing pressures on the environment. be based. o Leverage existing regional opportunities to im- o Ensure alignment between government strategy prove branding of the Comoros as a tourism desti- documents for the sustainable achievement of the nation. This may include developing a sustainability GoC’s ambitions for the NBT sector. This would in- certificate for accommodations and promoting the clude supporting alignment of the PCE 2030 with “Vanilla Islands” concept used by neighboring the National Tourism Strategy report and Strategic tourism hot spots like Mauritius, Madagascar, and Plan 2019–2025. The draft Sustainable Tourism Seychelles. The sustainability certificate, which Management Plan should be aligned with the could follow the criteria identified by the Seychelles previously mentioned strategies, finalized, and SSTL, could increase the attractiveness of the NBT adopted. 6. Looking Ahead T he Comoros has abundant and valuable but Law of the Environment (FLE). Attention to the envi- fragile natural resources on which the Comorian ronment is also outlined in the Comoros Emerging people are greatly dependent for their live- Plan (PCE) 2030, which envisions strong, inclusive, lihoods. The sustainable potential of this natural and equitable growth of the emerging economy resource base is not fully harnessed and could con- without compromising natural resources and the tribute much more to economic development if prop- environment. Three pillars of the PCE 2030 are rele- erly managed. Agriculture and fisheries are key for the vant for this country environmental analysis (CEA): Comoros economy as well as for Comorians’ food and (1) modernized agriculture for food security, (2) an nutrition security. Forests are important habitats and established blue economy, and (3) tourism and entre- an essential source of livelihood for rural communi- preneurship. Against this backdrop, to avoid fragmen- ties. The country’s coastal and marine ecosystems pro- tation, it is crucial that any new program or project be vide not only protection to the islands from extreme aligned with the PCE 2030. meteorological events but also harbor rich biodiver- sity that sustain the livelihoods of coastal communi- The PCE 2030 lays the foundation for the struc- ties. The tourism sector, which holds great promise tural transformation of the national economy by for diversification and structural transformation of the improving drinking water, sanitation, and water economy, is heavily dependent on the Comoros nat- resource management. In addition, the objective ural resource base. of the 2018 Blue Economy Strategic Framework (BESF) is to integrate the Comorian maritime space The main challenges related to the sustainable exploi- and resources into a long-term sustainable soci- tation of the country’s natural resource base include oeconomic development policy. Implementation low enforcement capacity, poor governance, and of the BESF must be achieved through the accom- inadequate financing. Enforcement capacity at all panying action plan. In addition, in its nationally governmental levels is needed, especially given that determined contribution (NDC), the GoC pledges to environmental challenges such as overexploitation, reduce its net greenhouse gas (GHG) emissions by deforestation, soil and coastal erosion, water degrada- approximately 23 percent in 2030 (excluding LUCF), tion, and waste management are closely interlinked. comprising USD 1,005 million for mitigation meas- Although a decentralization framework is in place, the ures and US$445 million for adaptation measures. devolution of competencies and associated financial On the international donor side, the World Bank’s resources is not yet clear, exacerbating a disconnect Country Partnership Framework (CPF) 2020–2024 has between the State and local traditional authorities. on two focus areas: (1) crisis response and building A chronic lack of financing at all governmental levels resilience and (2) economic recovery  and inclusive makes the country dependent on international donors growth. All key recommendations in this chapter aim for the implementation and enforcement of environ- to bring the implementation of the above-mentioned mental laws and regulations. institutional frameworks to the next level, with the PCE 2030 as the lead program. The Government of the Union of the Comoros (GoC) acknowledges the pivotal role of a healthy natural To trigger effective, deep, and lasting changes, it is resource base for the development prospects of the key for the Comoros to adopt an integrated approach country. In this regard, important institutional frame- to natural resource management, addressing issues works are in place such as the (soon to be) updated at the landscape scale, promoting sustainable fish- National Environmental Policy (PNE) and Framework eries and marine and coastal management, and 95 | 96 |   Comoros Country Environmental Analysis advancing integrated waste management. In this • Strengthen data collection and gap analysis. The way, the country will be able to optimize the devel- lack of adequate data on major natural resource opment of each sector without compromising the management issues is a key constraint for the de- others in the process and can capitalize on the inter- velopment of effective evidence-based policies and actions between the core elements of its natural cap- strategies and prioritization of interventions. ital and the ecosystem services they produce. This integrated approach requires a participatory and inclusive process that places local communities at the Recommendation 1: Strengthen core of the government’s action. Special focus should be accorded to the poor and vulnerable, whose live- Environmental Governance and Support lihoods are highly dependent on natural resources Institutional Capacity and thus under growing threat from disasters, This recommendation aligns with the Strategic the impacts of degraded ecosystems, and climate Framework for a National Policy on the Blue Economy change. Additionally, for an effective integrated nat- (BESF) (adapting the institutional framework) and ural resource management, the Comoros would need Country Partnership Framework (CPF) focus area to adopt a long-term perspective to ensure lasting 2 (improving governance). impact, foster local ownership of the initiative, and enhance the commitment to continue investing in • Strengthen the capacity of general and regional these efforts. directorates to fulfill their mandate by mobilizing human, technical, and financial resources. Develop This CEA presents five key recommendations to sup- targeted continuous professional development port the country in this sustainable, inclusive, and programs for technical staff at different levels as well climate-resilient development. For every recommen- as capacity building for other stakeholders. Carry dation, the connections with the institutional frame- out a human resource needs assessment to ascer- work are explained. tain the specific level of support needed for the dir-  he following enabling conditions are relevant for all T ectorates to carry out their functions and increase key recommendations: service delivery. Align environmental expenditure with priorities and use results-based agreements • Organize capacity building at all levels (ministries, to improve effectiveness and efficiency in the use regional directorates, municipalities) with tech- of public resources. The Comoros may benefit from nical and governance assistance. Focus specifically a dedicated environmental expenditure review to on the integrated nature of both the opportunities provide more clarity on the specific challenges and and challenges related to sustainable manage- needs in each sector. ment of upland, lowland, and coastal and marine • Approve the updated FLE and PNE to upgrade en- resources. vironmental priorities, incorporate emerging issues • Pay particular attention to inclusiveness, engaging and lessons learned, and facilitate the implementa- locally based nongovernmental organizations tion of ambitious environmental management ob- (NGOs) and associations, local communities, young jectives. Accompany the updates with a monitoring people, women, and the diaspora. system that allows tracking of the implementation of the FLE and PNE. Environmental monitoring sys- • Assess financing mechanisms such as international tems to evaluate the implementation of environ- donors and public-private partnerships (PPPs) for mental law, policies, and programs can help inform each recommendation, and identify entry points to decision-making in a variety of aspects, from pro- increase private sector engagement. gram performance management to the setting of • Focus on longer-term projects (greater than five environmental priorities. Ensure access to collected years), and use phased approaches. Each project data and associated analyses to strengthen trans- should build on the results and lessons learned from parency and accountability from environmental previous projects, and planning for the continuation institutions. of results following project completion is essential. • Boost law enforcement capacity with targeted • Focus on economic diversification and development livelihood support and community empowerment of entrepreneurship skills in each program or project programs. Strengthen enforcement capacity of to ensure sustainable alternative livelihoods beyond laws related to key environmental challenges such the project. as overexploitation, deforestation, pollution, water Looking Ahead   | 97 | supply, and illegal, unreported, and unregulated generate co-benefits such as jobs and income oppor- (IUU) fishing. Dedicate targeted efforts to enhance tunities, reducing widespread poverty, and fostering law enforcement capacity by providing human, tech- synergies between mitigation and adaptation in the nical, and financial resources for the implementation country. of environmental and natural resource regulations • Develop and implement land-use plans for and policies. Enforcement needs to be coupled with Ngazidja and Ndzuwani to protect the natural a co-management approach that involves and em- forest resources and stimulate reforestation. powers local communities in the management of Apply a zoning approach to identify the usage natural resources and livelihoods. Co-management for different zones, including agriculture, agrofor- creates a framework for dialogue and consultation estry, protected dry forests, and natural forests in among the various stakeholders concerned about national parks. Support the Mwali Land Use Plan the exploitation of natural resources. The involve- that is currently being developed and build on the ment of local communities in the decision-making same zoning approach. Combine this strategy with process ensures more effective implementation and an integrated landscape approach to ensure that all enforcement of the management measures that are activities in the area work in complementarity and adopted. that each specific zone is used for the purpose for • Ensure that the environmental implications of pro- which it is designed. Ensure consistency and ex- jects and actions are taken into account by the change of data and information between the three Government of the Union of the Comoros (GoC) be- land-use plans to stimulate cooperation and effi- fore the decisions are made. Enhance the technical cient use of funding. capacity of enviornmental institutions to evaluate Promote reforestation and soil fertility and • the environmental impacts of a proposed project strengthen climate-resilient Integrated Water or development plan, taking into account both the Resource Management (IWRM). Conduct reforest- beneficial and adverse socioeconomic and human ation by planting native trees that offer economic health impacts. Update the environmental impact benefits and opportunities to diversify incomes for assessment (EIA) regulatory framework and man- local communities. Reestablish soil fertility and soil agement system by (1) strengthening the capacity of health and improve the yields of food crops that are the EIA committee, (2) enhancing the capacity of the essential for food security on low-lying plots where EIA unit and monitor the implementation of man- soil fertility was lost because of unsustainable ag- agement plans, (3) reviewing and approving existing ricultural practices. IWRM should focus on (1) the and new EIA sectoral guidelines, (4) establishing a identification and prioritization of green and grey in- transparent environmental management informa- frastructure, for example, to transition from rain-fed tion system, and (5) operationalizing a dedicated agriculture to irrigation; 2) watershed protection and financial system. Develop and strengthen the insti- restoration as one of the most effective solutions to tutional capacity for Strategic Environmental and improve water retention, increase dry season flows, Social Assessment (SESA) implementation. and reduce storm erosion; and (3) the integration of groundwater sources within more holistic water management frameworks. Recommendation 2: Promote Sustainable • Upscale the simplification and decentralization of Land, Forest, and Water Management the land tenure regime to enhance legal certainty and strengthen social cohesion while ensuring This recommendation aligns with the PCE 2030 transparency. Ensure that the adjusted regime op- (modern agriculture for food security), the Accelerated erates at the municipality level while leaving the Growth and Sustainable Development Strategy established village land committees and the cadi (SCA2D) (mobilize, protect, and monitor water in charge of customary and religious rights. The resources), the BESF (protect coastal aquatic and decentralization of tenure securitization should be marine ecosystems), and CPF focus areas 1 and 2 envisaged in the short term but requires capacity (resilience and inclusive growth). building of technical staff as well as funding. Reduce the cost of land registration to create incentives to • Adopt an integrated landscape approach to promote use land productively and invest in long-term land sustainable use and conservation in an equitable conservation. manner, enabling the country to maximize produc- tivity, improve livelihoods, enhance natural capital • Protect terrestrial, coastal, and marine ecosys- while reducing negative environmental impacts, and tems and biodiversity. Officially operationalize | 98 |   Comoros Country Environmental Analysis the five additional national parks proposed under the National Park Strategy adopted in 2017 Recommendation 3: Promote Sustainable and the National Protected Areas System Law Fisheries and Integrated Marine adopted in December 2018.45 Adopt a participatory co-management approach in the parks with a central and Coastal Management role for local communities, capitalizing on the suc- This recommendation aligns with the PCE 2030 (Blue cessful experience of Mwali National Park. Empower Economy), BESF (enhancement of key sectors, protect the Agency of National Parks with adequate tech- coastal aquatic and marine ecosystems, adapting the nical assistance and financial support. institutional framework and regional cooperation), the • Reduce rural communities’ vulnerability to the im- NDC (mitigation and adaptation measures), and CPF pacts of climate change and improve sustainable and focus area 2 (inclusive growth). climate-resilient agricultural capabilities. Establish a • Support the development of a sustainable fisheries climate-resilient agriculture plan, building on suc- strategy. Ensure consistency among fishery decrees cessful projects such as the Global Climate Change to address related key challenges such as sustain- Alliance (AMCC), Enhancing Adaptive Capacity able fisheries, IUU fishing, international/regional for Increased Resilience to Climate Change in the cooperation, and co-management of coastal and Agricultural Sector (CRCCA), and Family Farming marine resources, providing livelihoods support to Productivity and Resilience Support Project ensure effective management. Include a fisheries (PREFER). Improve the irrigation system as part of management plan in the strategy, where science the Agriculture Plan. Develop a sustainable irrigation and research on the status of fish stocks inform deci- strategy that includes investments in nature-based sion-making. Ensure that the fisheries management solutions such as natural water retention measures. plan is built on an assessment of coastal and marine In line with the revised NDC (2021), strengthen the resources,46 fisheries, and key issues in fisheries. resilience of the agricultural sector to extended The results from South West Indian Ocean Fisheries periods of drought and reduced rainfall and improve Governance and Shared Growth Project (SWIOFish1) response readiness against increased risk of forest can be used as a stepping stone to develop the fish- fires and reduced water availability. This could in- eries management plan. Combine co-management clude providing access to irrigation and increasing efforts with capacity building at multiple levels, sponge functioning specifically in the upland areas, while strengthening fishery unions and associations but also in the lowland areas where possible, with a train-the-trainer approach. Improve the sus- depending on the topography and soil characteris- tainability of fisheries via trainings and investment, tics of the terrain. Involve local communities from including sustainable fishing gears, product devel- the start and focus on co-management of water re- opment, the use of fish aggregating devices, the use sources while establishing sustainable irrigation and of safety equipment, engine repair, troubleshooting, natural water retention measures. Integrate climate- conservation of fish, and the use of ice machines. smart training for farmers into the Agriculture Plan to increase the sector’s resilience against the ef- • Intensify efforts to combat IUU fishing. The Comoros fects of climate change and improve yields and soil needs to be enabled to sanction IUU fishing, at the fertility. industrial but most especially at the small-scale level, given the evidenced large impact of artisanal • Scale up water, sanitation, and hygiene (WASH) illegal fishing on coastal fisheries and the ecosystem programs and increase investments in sanitation more broadly. IUU fishing in the small-scale seg- infrastructure to ensure improved drinking water ment can be addressed by building on SWIOFish1 quality and higher sanitation standards and to achievements and integrating lessons learned, in- increase access to sanitation services in both rural cluding by training the staff of unions, associations, and urban areas. The Comoros has higher mortality and cooperatives who can, in turn, train fishers. For rates than its neighboring countries because of un- the industrial segment, the Comoros should have safe WASH, and the percentage of Comorians with its own IUU register, for example, building to the access to sanitation services lags far behind the Indian Ocean Tuna Commission (IOTC) IUU vessel world average. Urgent efforts are needed to address list, as well as procedures to quickly address IUU this situation. events when they are identified. Better participation  ffective management could be guided by, for example, im- 46 E 45 The decrees of the two terrestrial and three coastal and ma- proved availability of data on the status of stocks and catch rine national parks are pending signature. and effort, rapid assessments, and gear selectivity studies. Looking Ahead   | 99 | in international and regional coordination efforts areas, and their blue carbon offsetting potential. would also support efforts against IUU fishing and Accompany protection and restoration efforts with potentially offer opportunities to mobilize resources. capacity building and awareness raising among local communities, especially about the damages of • Protect and sustainably manage coastal zones and harvesting mangroves for firewood and construc- reduce the impacts of climate change. Develop an tion activities. Integrated Coastal Management Plan (ICMP) and Blue Economy Roadmap (BER) and support the Marine • Develop coral reef restoration projects by providing Spatial Plan in one integrated process. Identify man- technical and governance assistance to the Ministry agement objectives, measures, actions, and op- of Agriculture, Fisheries, Environment, Tourism, portunities. Involve relevant stakeholders from the and Handicrafts. The Comorian NFP for the GCF48 beginning to co-create the BER and increase aware- also needs assistance in the development of coral ness, as well as to provide a higher degree of legit- reef restoration projects, possibly under the Global imacy. Support the Marine Spatial Plan initiated by Fund for Coral Reefs Investment Window. Invest in the General Planning Commissioner, with technical strengthening adaptive capacity, reducing exposure and financial assistance from IOC-UNESCO begin- to climate risks, increasing reef resilience from the ning in November 2021. Assess interactions between reduction of local stressors, and protecting and re- maritime sectors, improve the compatibility of mar- storing reefs. Ensure that projects are based on itime socioeconomic activities with the carrying ca- co-management principles and include capacity pacity of marine resources, and prevent conflicts building on sustainable fishing practices to reduce between sectors and enhance their synergies. pressures on the reef. • Support the Blue Economy Committee as the main beneficiary of the ICMP and BER. The committee was established after the completion of the BESF Recommendation 4: Invest in Integrated and provides an opportunity to operationalize the Solid Waste Management blue economy by building upon an existing insti- tution. Arrange structural and long-term funding This recommendation aligns with the PCE 2030 (struc- for the committee. The roles and responsibilities turing project on integrated waste management) of the committee, such as the coordination of blue and SCA2D (promote sanitation to raise the level of economy activities, need to become clear through hygiene). statutes and a mandate, formalized in a new decree. • Support the implementation of the PCE 2030 The committee members need to be trained to fully structuring project “Integrated (Solid) Waste grasp the interactions between the socioeconomic, Management.” Set up an implementation roadmap environmental, and institutional dimensions of the for infrastructural development, taking into account blue economy paradigm. The committee can ben- the implementation capacities of national, regional, efit from governmental organizations of other island and local governments, as well as societal parties. states working with the concept of a blue economy, Provide structural financing to the National Agency for example, the Indian Ocean Commission, the for Integrated Waste Management (ANAGID) and Blue Economy Working Group of the Indian Ocean raise public awareness on preventing solid waste Rim Association, the Western Indian Ocean Marine generation in the first place. Science Association, and the Nairobi Convention. Countries to learn from include Seychelles and Cape • Invest in services and infrastructure capable of en- Verde. Twinning projects could be initiated with suring adequate waste collection, recycling, and these organizations and/or countries.47 disposal. Expand and enhance waste collection services to households that are not yet covered, • Promote the protection and restoration of man- minimize collection losses, and increase volun- groves and nature-based flood defense. Conduct a tary, community-based collection points, including study on the current extent and status of the man- those for recyclable materials (“waste banks”). This groves, their ability to attenuate waves, the poten- process will significantly reduce harmful waste- tial to improve their role in flood protection through handling practices such as open burning of plastic restoration efforts, their function as spawning waste and result in positive spillover effects on public health and the environment. Improve recycling by Twinning projects bring together public sector expertise 47  setting up recycling, biodigesters, and composting from two or more countries with the aim of achieving oper- ational results through peer-to-peer activities (derived from https://bit.ly/3vWZVCo). 48 National Focal Point for the Green Climate Fund. | 100 |   Comoros Country Environmental Analysis platforms. Finalize the landfill sites already identified in the PCE 2030 and identify new final waste storage Recommendation 5: Promote Nature- sites. Based Tourism • Reduce the generation of solid waste by incentiv- This recommendation aligns with the PCE 2030 izing designs for reuse and using alternative mater- (tourism), BESF (enhancement of key sectors), and ials. To facilitate this process, carry out a life-cycle CPF’s focus area 2 (inclusive growth and improving assessment of the most problematic waste products, connectivity). particularly those with higher potential for reuse and recycling, followed by a feasibility study for policy • Develop upstream opportunity assessments and and regulatory options to increase circularity (for ex- demand analyses to close the data gap and clarify ample, market-based instruments to restrict, substi- a realistic market space for NBT in the Comoros. tute, or incentivize reuse of plastic items). Filling this data gap would be a prerequisite to the development of strategies and plans. This should • Promote composting to reduce the volume of re- include updating the 2013 Comoros Tourism Sector sidual organic waste and increase benefits for Review to provide evidence-based understanding farmers. High-quality compost has the advantage of the Comoros NBT sector’s effective potential as a that it can be sold to farmers as a biofertilizer, to growth driver for the country. reduce air and water pollution, lower operational costs, and increase income generation. • Place natural endowments and biodiversity at the core of the future of the Comoros NTB sector by • Raise awareness on waste-related risks and oppor- conceiving of protected areas not only as a con- tunities, in particular the prevention of solid waste servation tool but also as a livelihood support generation and sorting at source. Communication asset and potential engine of growth. Expand the campaigns, awareness-raising events, and capacity protected areas coverage in alignment with the building should be planned to promote behavior government’s National Park Strategy. Ensure the change by all stakeholders involved. sustainable management of the protected areas, • Improve private sector participation in waste man- strengthening the capacities of relevant institu- agement. Promote dialogue with the private sector, tions, building skills in biodiversity conservation, implement a waste-collection fee, and identify spe- and monitoring of NBT development, biodiversity, cific PPPs in Comoros cities. and ecosystems. Ensure financial sustainability for effective management and enforcement. Develop • Improve data collection and analysis. To develop specific guidelines on the carrying capacity of each effective and sustainable integrated solid waste island to ensure that it is not exceeded, and data management (ISWM) policies, it is crucial for the gaps should be filled on tourism performance and GoC to conduct in-depth, sound studies on cost potential. recovery and sustainability aspects, as well as to quantify the environmental and public health • Ensure that NTB is upheld by participatory ap- footprint of waste in both rural and urban areas. proaches in the decision-making process and by Assessment of the potential impact of tourism- the establishment of benefit-sharing mechanisms sector development on waste management in with local communities. Ensure Comorians can the country is also essential. Implementing such benefit directly from the tourism activity, not only studies would be instrumental for the Comoros to through jobs and livelihood diversification op- close the gap through informed decision-making portunities but also through revenue-sharing ar- across all aspects of ISWM. rangements and improved access to public goods such as schools, roads, and health clinics. It is es- • Support the development of comprehensive legis- pecially important to involve youth and women, lation and help define the institutional framework who experience the highest unemployment rates. for solid waste management. Adopting specific laws Conduct awareness-raising and capacity-building and reforms rooted in an overall vision for solid activities on the benefits of protecting natural waste treatment is essential for the country. In addi- assets to ensure understanding and incentivize tion, it would be extremely beneficial to clarify roles participation. and responsibilities between municipalities and cen- tral government to address the gaps resulting from • Conduct assessments and data gap analyses on the incomplete decentralization process. In addi- tourism potential and performance to inform pol- tion, ANAGID should be provided with the required icies, improve tourist services, assist local com- funding and vision to implement its mandate. munities, and refine the tourism business model. Looking Ahead   | 101 | Update the 2013 Comoros Tourism Sector Review • Develop a sustainability certificate for future con- to regularly conduct assessments of the impacts struction of accommodations. Such a measure has of NBT on protected areas and conduct in-depth the potential to enhance the country’s attractiveness monitoring of the status of biodiversity in the within the international tourism market, while pro- country. viding a significant opportunity to develop the sector sustainably. • Develop safe and sustainable transportation infra- structure, ensuring that such plans are designed and • Align the draft Sustainable Tourism Master Plan with implemented within a context of socioenvironmental the National Tourism Strategy report and Strategic sustainability. Many infrastructural improvements Plan 2019–2025 to ensure the sustainable realization are required to facilitate NBT development, including of the GoC’s ambitions for the NBT sector. The im- tourist transportation on and between islands as en- pact of NBT on freshwater resources, ecosystems, visioned by the PCE 2030 flagship project “Unifying and biodiversity should be considered while the the Islands by Sea. ” country is developing the sector. 7. Conclusions T he outcomes of this country environmental foundation for the medium–long-term vision revolving analysis (CEA) call for transformative changes around the five macro recommendations described toward sustainable management of natural above. For instance, the Comoros could build on the resources to achieve long-term poverty alleviation and lessons learned from the World Bank’s Integrated resilience. In this regard, an integrated approach to Development and Competitiveness Project (PIDC) natural resource management will be key to maximize project to further enhance domestic value chains in the benefits stemming from interactions between the agriculture and livestock sectors or on the results of different core elements of the country’s natural capital. the South West Indian Ocean Fisheries Governance and Shared Growth Project (SWIOFish) to improve To support the country’s sustainable and climate- fisheries management. Successful projects such as resilient development, this CEA has identified five Enhancing Adaptive Capacity for Increased Resilience macro recommendations, as explained in chapter 6: to Climate Change in the Agricultural Sector (CRCCA) (1) strengthen environmental governance and support or the Family Farming Productivity and Resilience institutional capacity, (2) promote sustainable land, Support Project (PREFER) could also be replicated to forest, and water management through an integrated spur a transition to sustainable land use. The Comoros landscape approach, (3) promote sustainable fisheries could scale up the positive experience of Mwali and integrated marine and coastal management, (4) National Park for biodiversity and ecosystem conser- invest in integrated solid waste management (ISWM), vation and as a basis for the possible development of and (5) promote nature-based tourism (NBT). To NBT. Replicating or scaling up such successful initia- achieve these goals, the Comoros would benefit sig- tives, as well as coordinating with donors and other nificantly from adopting a co-management approach countries in the region facing similar challenges, whenever possible, increasing local inclusiveness would allow the Comoros to take some concrete and in decision-making processes, establishing benefit- actionable steps to pave the way for structural and sharing and women’s empowerment mechanisms, lasting changes in natural asset management. and raising awareness among local populations about the main environmental challenges and opportunities. For this approach to be effective, it needs to be com- In addition, this CEA made the case for strengthening bined with a corresponding effort to strengthen the decentralization agenda as envisioned under the data collection and data gap analyses. As clearly 2018 constitution by clarifying the distribution of roles emerged from this CEA, the lack of adequate data and and tasks between local and central natural resource well-designed studies in the Comoros on major nat- management institutions to avoid repetition, foster ural resource management issues often represents synergies, and ultimately improve efficiency in ful- a significant constraint for the country to develop filling their mandate. evidenced-based policies and strategies and interven- tion prioritization. For instance, it is critical that the The implementation of the recommendations artic- Comoros improve forest inventories, data collection, ulated in this CEA can benefit highly from programs and site monitoring to better understand the ecolog- and pilot projects that have already been success- ical functions of trees at the landscape scale in the fully implemented in the Comoros and, as such, could country. It is also essential to conduct a vulnerability be used as justification for the country to invest in and risk assessment for all water sources to improve these efforts from pilot to scale through an integrated water resource management, especially hydro- approach among sectors. Several existing opportun- climatic resilience, and inform island-level master ities could be leveraged in the short term to lay the plans and investment programs. Additional study of 103 | 104 |   Comoros Country Environmental Analysis the scale of illegal industrial fishing in the Comoros important, as in-depth analyses of the comparative and the degree of coastal and marine degradation is advantages of the Comoros and the potential demand also needed. Filling these existing gaps would enable for tourism are key prerequisites for the development the adoption of effective and targeted measures to halt of tourism strategies and plans. and revert these trends. The Comoros could effectively move toward achieving such objectives by leveraging The above-mentioned initiatives, if coherently planned the recently approved World Bank PROBLUE grant and agreed upon with the Government of the and the ongoing World Bank Coastal Risk Assessment Comoros, represent an opportunity to strategically from the Post-Kenneth Project. For the NBT sector, lay the groundwork in the short term and start plan- bridging the data gaps, for instance, by updating the ning the next steps to support the Comoros along its 2013 Comoros Tourism Sector Review, is particularly sustainable and climate-resilient development path. 8. References Abdou, A. Y. n.d. Scientific Information for Marine FAO/IOC. https://www.fao.org/publications/card/ Protected Areas in the Union of Comoros. https:// en/c/34ce5798-55a8-4c9f-90d7-06b3b5b0bf92/. www.cbd.int/doc/meetings/mar/ebsa-sio-01/ CEPF. 2018. Including Women in the Conservation. other/ebsa-sio-01-comoros-en.pdf. https://www.cepf.net/stories/including-women- Ahamada, S. 2021. Etude sur la Gestion durable des conservation-conversation. herbiers sous-marins aux Comores. Programme Charmoille, A. 2013. Ebauche du fonctionnement Wiocor - Composante Herbiers sous-marins. hydrogéologique de l’île d’Anjouan (Comores): Ali, A. I., Karouach, F ., Lahboubi, N., Bakraoui, M., Typologie des ressources en eau disponibles and H. El Bari. 2018. “Perception and Behavior et discussion sur l’impact de la déforestation. Analysis of Comorians Citizens on the Solid Rapport, Engagement Communautaire Pour Le Household Waste Problems. ” European Scientific Développement Durable (ECDD). Journal 14(26): 297. Commission Économique pour l’Afrique. 2017. Profil AMCC. 2019a. Carte de l’extraction de sable à Anjouan 2017: Les Comores. Nations Unies Commission et Grande Comore. https://amcc-comores.info/. Économique pour l’Afrique - Bureau sous- AMCC. 2019b. Programme d’appui à l’Union des régional pour l’Afrique de l’Est. https:// Comores pour le Renforcement de la Résilience archive.uneca.org/sites/default/files/uploaded- au Changement Climatique—Rapport de documents/SROs/EA/EA-ICE21/profil_comores_ Synthese Final. EuropeAid No. 137-180/ID/SER/ nov_2017.pdf. KM, 48. Comoros Ministry of Foreign Affairs. 2020. Rapport na- AMCOW. 2018. Water Use, Comoros, 2016, GRID- tional volontaire de l’union des Comores au forum Arendal. https://www.grida.no/resources/14262. politique de haut niveau sur le développement ASCLME. 2012. National Marine Ecosystem Diagnostic durable. https://sustainabledevelopment.un.org/ Analysis (MEDA)—Union of Comoros. content/documents/26403VNR_2020_Comoros_ https://wedocs.unep.org/xmlui/bitstream/ Report.pdf. handle/20.500.11822/25888/Comoros_MEDA. Comte, J.-C., Cassidy, R., Obando, J., Robins, N., pdf?sequence=1andisAllowed=y. Ibrahim, K., Melchioly, S., Mjemah, I., Shauri, Astudillo. 2012. Cartographie des ressources en H., Bourhane, A., Mohamed, I., Noe, C., Mwega, eau dans la forêt de Moya, problématiques et B., Makokha, M., Join, J.-L., Banton, O., and priorités d’intervention. J. Davies. 2016. “Challenges in Groundwater Bourgoin, C., Louis, P ., Martínez Valle, A. I., Mwongera, Resource Management in Coastal Aquifers of C., and P . Läderach. 2016. “A Spatially Explicit East Africa: Investigations and Lessons Learnt Assessment of Climate Change Vulnerability in the Comoros Islands, Kenya and Tanzania. ” in the Agricultural Sector of the Union of the Journal of Hydrology: Regional Studies 5, 179– Comoros. ” Working Paper. https://cgspace.cgiar. 199. https://doi.org/10.1016/j.ejrh.2015.12.065. org/handle/10568/78667. Cowburn, B., Samoilys, M. A., and D. Obura. 2018. Breuil, C. 2018. Study on the Private Sector and “The Current Status of Coral Reefs and Their Fisheries Sectors. Comoros: Current Situation, Vulnerability to Climate Change and Multiple Challenges and Prospects. Final report (in Human Stresses in the Comoros Archipelago, French). Western Indian Ocean. ” Marine Pollution Breuil, C., and D. Grima. 2014. Country Review: Comoros: Bulletin 133, 956–969. https://doi.org/10.1016/j. Fisheries in the ESA-IO Region: Profile and Trends. marpolbul.2018.04.065. 105 | 106 |   Comoros Country Environmental Analysis Dahari. 2022. Marine Resources Management. Dahari. FAO. 2008. Contribution of the Forestry Sector to https://daharicomores.org/en/marine-resources- National Economies, 1990-2006. https://www.fao. management/. org/3/k4588e/k4588e00.htm. De Groot, R., Brander, L., Van Der Ploeg, S., Costanza, FAO. 2018. “Impacts of Climate Change on Fisheries R., Bernard, F ., Braat, L., Christie, M., Crossman, and Aquaculture: Synthesis of Current N., Ghermandi, A., and L. Hein. 2012. “Global Knowledge, Adaptation and Mitigation Options. ” Estimates of the Value of Ecosystems and Their Technical Paper, 627. FAO. https://www.fao.org/3/ Services in Monetary Units. ” Ecosystem Services i9705en/i9705en.pdf. 1(1), 50–61. FAO. 2019. “FAO Fisheries and Aquaculture Report/ Deltares. 2016. Mangrove Restoration: To Plant or Not FAO Rapport sur les pêches et l’aquaculture to Plant? Deltares. https://www.deltares.nl/app/ Maputo, Mozambique. “ Report of the Ninth uploads/2016/07/Mangrove-restoration_to-plant- Session of the Scientific Committee of the or-not-to-plant.pdf. Southwest Indian Ocean Fisheries Commission. DGEME. 2014. Problematique de l’eau aux Comores. Réunion, France, 16-19 July 2019. Licence: CC https://www.pseau.org/outils/ouvrages/dgeme_ BY-NC-SA 3.0 IGO. https://www.fao.org/fi/static- ps_eau_ocean_indien_la_problematique_de_l_ media/MeetingDocuments/SWIOFC/X/Inf.5e.pdf. eau_aux_comores_2014.pdf. FAO. 2020. Comoros GLOBEFISH Profile—December DGRH. 2021a. Bulletin statistique de pêche N°4. http:// 2020. Comoros GLOBEFISH Profile. www.comorespeche.org/images/BulletinStatisti Fouqué, É., and M. Durand. 2018. “Recycler ou enfouir queN4delapcheartisanaleComores_2020.pdf. les déchets d’Anjouan (Comores)? La gestion DGRH. 2021b. Recueil des textes législatifs et des déchets en milieu insulaire. “ In Du rebut à réglementaires sur la pêche en Union des la ressource. Valorisation des déchets dans les Comores. Volume 1. villes du Sud, 195–216. Editions AFD. Doulton, H., Mohamed, M., Shepherd, G., Mohamed, Freed, S., Vessaz, F ., Ousseni, F ., Jeffers, V., Gardner, S., Ali, B., and N. Maddison. 2016. “Addressing L., and S. Rocliffe. 2018. Status Report: Marine Forest Degradation in a Small Island Developing Ecosystems, Fisheries and Socio-Economic State: A Landscape Approach in Comoros. ” Context of Anjouan, Comoros, 78. Blue Ventures. Unasylva 67(247/248), 30. h tt p s : / / b l u e v e n t u r e s . o r g / w p - c o n t e n t / u p - Dumont, E. S., Bonhomme, S., and M. Mohamed. loads/2021/03/Comoros-Status-Report-2018.pdf. 2021. Guide technique d’agroforesterie pour la GCF and UNDP . 2018a. Annex II - Feasibility Study: sélection et la gestion des arbres aux Comores Ensuring Climate Resilient Water Supplies in the – Ile d’Anjouan – version 1.2. World Agroforestry Comoros Islands. Centre. https://worldagroforestry.org/publica- GCF and UNDP . 2018b. Funding Proposal. FP094: tion/guide-technique-dagroforesterie-pour-la- Ensuring Climate Resilient Water Supplies in selection-et-la-gestion-des-arbres-aux-comores. the Comoros Islands. Comoros. United Nations EPI. 2020. Environmental Performance Index 2020. Development Programme (UNDP). Decision Country Profile Comoros. https://epi.yale.edu/ B.21/34. sites/default/files/files/COM_EPI2020_CP .pdf. GCF and UNDP . 2019a. Gender Assessment—FP094: European Commission. 2017. Fight against Illegal Ensuring Climate Resilient Water Supplies in Fishing: Commission Lists Saint Vincent the Comoros Islands. https://www.greenclimate. and the Grenadines and the Comoros as fund/sites/default/files/document/gender- Non-Cooperating, and Issues Warning for assessment-fp094-undp-comoros.pdf. Liberia. https://ec.europa.eu/newsroom/mare/ GCF and UNDP . 2019b. Ensuring Climate Resilient items/65987. Water Supplies in the Comoros Islands. Project European Commission. 2021. Comoros Forests, DOPA document. Explorer. https://dopa-explorer.jrc.ec.europa.eu/ GEF. n.d. Land Degradation. Global Environment ecoregion/30105. Facility. https://www.thegef.org/what-we-do/ FAO. 2005. AQUASTAT Country Profile Comoros. topics/land-degradation. Rome, Italy: FAO. https://www.fao.org/3/ GEF and UNDP . 2022. Stratégie d’expansion du CA2142FR/ca2142fr.pdf. système national des aires protégées aux FAO. 2006. “FAO/SWIOFC Regional Workshop on Comores 2017–2021. Safety at Sea for Small-Scale Fisheries in the General Secretary of the Presidency and General South West Indian Ocean. ” FAO Fisheries Report Planning Commission. 2017. Strategy 840, 85. FAO. https://www.fao.org/3/i0050e/ for Accelerated Growth and Sustainable i0050e.pdf. Development (SCA2D). References  | 107 | Global Forest Watch. 2022. Tree Cover Loss in Desvaux, A. Dukhan, M. Durand, B. Florin, É. Comoros. www.globalforestwatch.org. Fouqué, J. Furniss, J. Garnier, S. Gowda, S. Golub, S., and A. Varma. 2014. Fishing Exports and Jaglin, M. le Meur, R. Marciniak, L. Moretto, J. R. Economic Development of Least Developed Ngambi, … I. Salenson, eds. Editions AFD. https:// Countries: Bangladesh, Cambodia, Comoros, Sierra hal.archives-ouvertes.fr/hal-01856401. Leone and Uganda. https://www.swarthmore.edu/ Jambeck, J., Hardesty, B. D., Brooks, A. L., Friend, T., sites/default/files/assets/documents/user_profiles/ Teleki, K., Fabres, J., Beaudoin, Y., Bamba, A., sgolub1/UNCTAD.fisheries.final.pdf. Francis, J., and A. J. Ribbink. 2018. “Challenges Goodman, S. M., Weyeneth, N., Ibrahim, Y., Saïd, I., and Emerging Solutions to the Land-Based and M. Ruedi. 2010. “A Review of the Bat Fauna of Plastic Waste Issue in Africa. ” Marine Policy 96, the Comoro Archipelago. ” Acta Chiropterologica 256–263. 12(1), 117–141. Jambeck, J. R., Geyer, R., Wilcox, C., Siegler, T. R., Gray, E., Henninger, N., Reij, C., Winterbottom, R., Perryman, M., Andrady, A., Narayan, R., and K. L. and P . Agostini. 2016. Integrated Landscape Law. 2015. “Plastic Waste Inputs from Land into Approaches for Africa’s Drylands. World Bank. the Ocean. ” Science 347(6223), 768–771. https://doi.org/10.1596/978-1-4648-0826-5. “La Gazette des Comoros, ” 2022, May 23. No. 4129. Harris, R. A., Casella, E., Power, H., Canavesio, R., Collin, Lallemand, P . 2019. Study on Tuna Fisheries Direct A., Pomeroy, A., Webster, J. M., and V. Parravicini. and Indirect Contribution to GDP and Wealth 2018. “Coral Reef Structural Complexity Provides Distribution Patterns in the SWIOFC Member Important Coastal Protection from Waves under Countries. https://www.commissionoceanindien. Rising Sea Levels. ” Science Advances 4(2), org/wp-content/uploads/2021/04/Final-Report- eaao4350. Tuna-Contribution-to-GDP-in-SWIOFC-by-P.- Ibouroi, M. T., Dhurham, S. A. O., Besnard, A., and Lallemand-November-2019-1_18Feb2020.pdf. N. Lescureux. 2021. “Understanding Drivers Malterre, P ., Laratte, C., Beudard, F ., Curtet, C., and J. of Unsustainable Natural Resource Use in Peraud. 2018. Profil côtier des Comores, version the Comoro Islands. ” Tropical Conservation actualisée. Projet Biodiversite (COI/UE). Science 14, 19400829211032584. https://doi. Ministry of Agriculture, Fisheries, Environment, org/10.1177/19400829211032585. Tourism, and Handicrafts (MAPETA). 2021a. Indian Ocean Commission (IOC). 1996. Rapport na- Contribution déterminée au niveau national tional de pré-audit du programme régional (CDN actualisée), rapport de synthèse. environnement de la commission de Ministry of Agriculture, Fisheries, Environment, l’océan indien et du fonds européen pour le Tourism, and Handicrafts (MAPETA). 2021b. développement, bilan socio-économique et Politique nationale de l’environement de l’Union écologique de la zone côtière des Comores. des Comores. INSEED. 2021. Population par village. Calculation Ministry of Rural Development, Fisheries, Handicrafts document. and Environment. 2006. National Action International Association for Medical Assistance Programme of Adaptation to Climate Change to Travellers. 2020. Comoros: Air Pollution. (NAPA), 92. Union des Comoros. https://unfccc. https://www.iamat.org/country/comoros/risk/ int/resource/docs/napa/com01e.pdf. air-pollution. Morikawa, M. K., and S. R. Palumbi. 2019. “Using Indian Ocean Tuna Commission (IOTC). 2021. Status Naturally Occurring Climate Resilient Corals to Summary for Species of Tuna and Tuna-Like Construct Bleaching-Resistant Nurseries. ” PNAS Species under the IOTC Mandate, as Well as 116(21), 10586-10591. https://doi.org/10.1073/ Other Species Impacted by IOTC Fisheries. IOTC. pnas.1721415116. https://www.iotc.org/science/status-summary- Morin, J., Lavigne, F ., Bachèlery, P ., and N. V. Finizola. species-tuna-and-tuna-species-under-iotc- 2009. “Institutional and Social Responses to mandate-well-other-species-impacted-iotc. Hazards Related to Karthala Volcano, Comoros. IUU Fishing Index. 2021. IUU Fishing Index—2021 Part 2: Deep-Seated Root Causes of Comorian Country Profile Comoros Island. https:// Vulnerabilities.” Shima: The International Journal iuufishingindex.net/reports/iuu-fishing-index- of Research into Island Cultures 3(1), 54–71. country-profile-2021-comoros-isl.pdf. Moussa Sambaouma, H., Resler, M., Malik, A., Jaglin, S., Debout, L., and I. Salenson. 2018. Du rebut Murray, J., Quintal, D., and M. Lenzen. 2017. A à la ressource. Valorisation des déchets dans Vision of Ecotourism in the Comoros Islands. les villes du Sud. In M. Azaitraoui, M.-N. Carré, h tt p s : / / i s a . o r g . u s y d . e d u . a u / p u b l i c a t i o n s / J. Cavé, C. Dardy, R. de Bercegol, J. Delarue, P . ComorosEcotourismVision.pdf. | 108 |   Comoros Country Environmental Analysis Myers, N., Mittermeier, R. A., Mittermeier, C. G., Da électronique en sciences de l’environnement Fonseca, G. A., and J. Kent. 2000. “Biodiversity 10(3), 14. Hotspots for Conservation Priorities. ” Nature Sinane, K. M. 2013. “Les littoraux des Comores, 403(6772), 853–858. dynamique d’un système anthropisé: le cas de Nairobi Convention. 2021. Toward a More Sustainable l’île d’Anjouan. “Thèse de doctorat en Géographie, Fisheries Sector in Comoros. https://www. Université de la Réunion. https://tel.archives- nairobiconvention.org/toward-a-more- ouvertes.fr/tel-01237270/file/2013lare0 027_ sustainable-fisheries-sector-in-comoros/. SKamardine.pdf. Obura, D., Gudka, M., Rabi, F . A., Gian, S. B., Bijoux, SIWI. n.d. Comoros. Reviewing the Water Code and J., Freed, S., Maharavo, J., Mwaura, J., Porter, S., Strengthening of the Water Sector Regulation Sola, E., Wickel, J., Yahya, S., and S. Ahamada. in Comoros. https://www.watergovernance.org/ 2017. Coral Reef Status Report for the Western programmes/goal-waters/comoros-goal-waters/. Indian Ocean. Global Coral Reef Monitoring Soilihi, A. S. 2017. “Union des Comores rapport Network (GCRMN)/International Coral Reef national destiné au comité scientifique de la Initiative (ICRI). https://wedocs.unep.org/xmlui/ commission des thons de l’océan indien, 2017. “ handle/20.500.11822/28371. In: IOTC Proceedings. IOTC, Victoria, Seychelles, Official Inflation Data. 2022. $1 in 2007 → 2022, 30 November—04 December 2017. Inflation Calculator. https://www.in2013dollars. Sow, A. A. 2021. Rapport provisoire de l’étude diag- com/us/inflation/2007?amount=1. nostic sur les régimes fonciers et d’une étude sur Poonian, C. N. S., Tuharska, K., and M. D. Hauzer. 2016. les possibilités d’intégration des trois sources “Diversity and Distribution of Seagrasses in de droit sur le régime foncier dans l’union des the Union of the Comoros. ” African Journal of Comores. Projet de Renforcement des Capacités Marine Science 38(2), 263–268. Institutionnelles (PRCI- II). Pravettoni, R., United Nations Environment Suez, Groupehuit, Acterra, and Angalia. 2021. Programme (UNEP), and GRID-Arendal. 2012. Comores – appui à l’élaboration du schéma Estimated Costs and Benefits of Restoration d’aménagement territorial de l’ile de mohéli – Projects in Different Biomes, GRID-Arendal. GRID- rapport de diagnostic détaillé and annexe de pro- Arendal. https://www.grida.no/resources/6199. jections climatiques. Ramadhoini Ali. 2021. Etude de la biodiversité des Sutton, P . C., Anderson, S. J., Costanza, R., and I. récifs profonds, renforcer les connaissances Kubiszewski. 2016. “The Ecological Economics of pour la protection et la conservation des océans. Land Degradation: Impacts on Ecosystem Service Sachs, J., Kroll, C., Lafortune, G., Fuller, G., and Values. ” Ecological Economics 129, 182–192. F. Woelm. 2021. Sustainable Development TEEB. 2010. The Economics of Ecosystems and Report 2021. DOI: 10.1017/9781009106559. Biodiversity: Mainstreaming the Economics Cambridge University Press. https://www. of Nature—A Synthesis of the Approach, sustainabledevelopment.report. Conclusions and Recommendation of TEEB. Samoilys, M., Harris, J., Bernard, A., Woodall, L., http://teebweb.org/publications/teeb-for/ Palmer, R., Zonda, A., Schmidt, N., Toihir, I., synthesis/. Rosoanandrasana, N., Eddine, Y., and R. Ali. 2018. Trenchard, T. 2020, April 16. “‘There’s No More Water’: Expedition to Survey the Marine Biodiversity and Climate Change on a Drying Island. ” The NewYork Fish Abundance on the Mesophotic Reefs of the Times. https://www.nytimes.com/2020/04/16/ Comoros Archipelago—RV Angra Pequena Cruise world/africa/comoros-climate-change-rivers. Report, 49. Critical Ecosystem Partnership Fund. html. https://www.nairobiconvention.org/clearinghouse/ Tschora, H., and F . Cherubini. 2020. “Co-benefits and sites/default/files/Comoros_Call%20for%20 Trade-offs of Agroforestry for Climate Change Demonstration%20Projects_Component%20 Mitigation and Other Sustainability Goals in 1%20%26%202_Consolidated_Final.pdf. West Africa. ” Global Ecology and Conservation SAU. 2019. Sea Round Us: Fisheries, Ecosystems 22, e00919. https://doi.org/10.1016/j.gecco.2020. and Biodiversity. http://www.seaaroundus.org/ e00919. data/#/eez/404. Tshimanga, R. 2015. Mutusmudu Watershed Integrated Sinane, K., David, G., Pennober, G., and R. Troadec. Management Plan. United Nations Environment 2010. “Fragilisation et modification des for- Programme (UNEP) IWRM SIDS Programme. mations littorales meubles sur l’île d’Anjouan UNCTAD. 2017. “Chapter 6 Case Study: Comoros. ” In (Comores) quand l’érosion d’origine anthropique Fishery Exports and the Economic Development se conjugue au changement climatique. “ La revue of Least Developed Countries: Bangladesh, References  | 109 | Cambodia, the Comoros, Mozambique, Myanmar for the Development of the Comoros Paris 02-03 and Uganda, 67. https://unctad.org/system/files/ December 2019. official-document/aldc2017d2_en.pdf. Révision de la Code Pêche, Décision 20-051/PR Pêche UNDP . n.d. Human Development Indicators— 50. 2020. http://www.comorespeche.org/images/ Comoros. http://hdr.undp.org/en/countries/ images/documents/cadre/REVISION-CODE-DE- profiles/COM. LA-PECHE-2020.pdf. UNDP . 2012. Mohéli Marine Park, Comoros Roby, D. 2014. Projet pour le développement d’un (Equator Initiative Case Study Series). https:// système d’aires protégées terrestres et marines www.equatorinitiative.org/wp-content/up- représentatives du patrimoine naturel unique loads/2017/05/case_1348163266.pdf. des Comores et cogérées avec les communautés. UNDP. 2014. Le processus de plan national Rapport d’activités, 90. UNDP , GEF . d’adaptation aux Comores. https://www. Velis, C. A., and E. Cook. 2021. Mismanagement adaptation-undp.org/sites/default/files/down- of Plastic Waste through Open Burning with loads/draft_rapport_de_recensement_pour_les_ Emphasis on the Global South: A Systematic comores.pdf. Review of Risks to Occupational and Public UNDP . 2017. ProDoc—Strengthening Comoros Health. Environmental Science and Technology Resilience against Climate Change and Variability 55(11), 7186–7207. Related Disaster, UNDP Climate Change Winker, H., Walter, J., Cardinale, M., and D. Fu. 2019. “A Adaptation. https://www.adaptation-undp. Multivariate Lognormal Monte-Carlo Approach org/resources/prodocs/prodoc-strengthening- for Estimating Structural Uncertainty about the comoros-resilience-against-climate-change-and- Stock Status and Future Projections for Indian variability. Ocean Yellowfin Tuna. ” IOTC-2019-WPTT21-51. UNDP . 2022. Ensuring Climate Resilient Water Supplies Session 10: 12 P . in the Comoros Islands, UNDP Climate Change World Agroforestry. 2019. Trees in the Mist: Adaptation. https://www.adaptation-undp.org/ Domesticating Local Forest Trees to Restore projects/Comoros-water-GCF . the Comoros Archipelago. World Agroforestry, UNEP. 2016. Building Climate Resilience through Transforming Lives and Landscapes with Rehabilitated Watersheds, Forests and Adaptive Trees. https://www.worldagroforestry.org/ Livelihoods. Global Environment Facility. blog/2019/06/07/trees-mist-domesticating-local- https://www.thegef.org/projects-operations/ forest-trees-restore-comoros-archipelago. projects/5694. World Bank. n.d. Comoros Public Expenditure and UNESCO. 2022. Comoros Focuses on Sustainable Fiscal Management Review. Washington, DC: Tourism Management. https://www.unesco. World Bank. https://openknowledge.worldbank. org/en/articles/comoros-focuses-sustainable- org/handle/10986/28609. tourism-management. World Bank. 2013. Comoros Tourism Sector Review: UNICEF . 2016. UNICEF Annual Report 2016. Comoros. Discovering the Tourism Potential of Natural https://sites.unicef.org/about/annualreport/files/ Wonders. Washington, DC: World Bank. Comoros_2016_COAR.pdf. World Bank. 2014. Union of the Comoros: Addressing UNICEF . 2019. Comoros: Humanitarian Situation Challenges of Municipal Solid Waste Report No #2 - Cyclone Kenneth - Comoros. Management in Moroni. Washington, DC: World ReliefWeb. https://reliefweb.int/report/comoros/ Bank. comoros-humanitarian-situation-report-no-2- World Bank. 2016a. Disaster Risk Profile Comoros. cyclone-kenneth. https://www.gfdrr.org/sites/default/files/com- Union des Comores. 2018. Cadre stratégique pour une oros.pdf. politique nationale sur l’économie bleue, 34. World Bank. 2016b. People with Basic Handwashing Union des Comores. 2019a. Comoros Emergence Plan Facilities Including Soap and Water (% of popu- by 2030, Structuring Projects. lation)—Comoros, Data. https://data.worldbank. Union des Comores. 2019b. Plan Comores Emergent org/indicator/SH.STA.HYGN.ZS?locations=KM. 2030. World Bank. 2017a. Comoros Poverty Assessment Union des Comores. 2019c. Rapport sur la Stratégie (English). Washington, DC: World Bank. Nationale d’appui au développement du https://documents1.worldbank.org/curated/ tourisme, 45. en/342321528113131924/pdf/125069-WP-P156542- Union des Comores, République Française, World OUO-9-Comoros-Poverty-Assessment-revised.pdf. Bank, and UNDP . 2019. “Comoros Emergence World Bank. 2017b. Implementing Nature Based Flood Plan by 2030—Flagship Projects. ” Conference Protection—Principles and Implementation | 110 |   Comoros Country Environmental Analysis Guidance. Washington, DC: World Bank. World Bank. 2020k. Country Partnership Framework https://documents1.worldbank.org/curated/ for the Union of Comoros for the Period of FY20– en/739421509427698706/pdf/Implementing- FY24. Washington, DC: World Bank. https://doi. nature-based-flood-protection-principles-and- org/10.1596/34274. implementation-guidance.pdf. World Bank. 2020l. Tools and Resources for Nature- World Bank. 2018. Agricultural Land (Sq. Km)— Based Tourism. Washington, DC: World Bank. Comoros, Data. https://data.worldbank.org/indi- https://openknowledge.worldbank.org/ cator/AG.LND.AGRI.K2?locations=KM. handle/10986/34433 License: CC BY 3.0 IGO. World Bank. 2019a. The Union of the Comoros: World Bank. 2021a. Unemployment, Total (% of Total Jumpstarting Agricultural Transformation. Labor Force) (Modeled ILO Estimate)—Comoros, https://openknowledge.worldbank.org/ Data. https://data.worldbank.org/indicator/ handle/10986/32398. SL.UEM.TOTL.ZS?locations=KM. World Bank. 2019b. Climate Change and Marine World Bank. 2021b. World Bank Climate Fisheries in Africa: Assessing Vulnerability and Change Knowledge Portal. https:// Strengthening Adaptation Capacity. Washington, climateknowledgeportal.worldbank.org/country/ DC: World Bank. https://doi.org/10.1596/33315. comoros. World Bank. 2020a. Agriculture, Forestry, and Fishing, World Bank. 2021c. Comoros Urbanization Value Added (Constant 2015 US$)—Comoros, Review: Reimagining Urbanization in Data. https://data.worldbank.org/indicator/ Comoros. Washington, DC: World Bank. NV.AGR.TOTL.KD?locations=KM. https://openknowledge.worldbank.org/ World Bank. 2020b. Forest Area (Sq. Km)—Comoros, handle/10986/35115. Data. https://data.worldbank.org/indicator/ World Bank. 2021d. The Changing Wealth of AG.LND.FRST.K2?locations=KM. Nations 2021: Managing Assets for the Future. World Bank. 2020c. GDP (Current US$)—Comoros, Washington, DC: World Bank. https://doi. Data. https://data.worldbank.org/indicator/ org/10.1596/978-1-4648-1590-4. NY.GDP .MKTP .CD?locations=KM. World Bank. 2021e. Banking on Protected Areas. World Bank. 2020d. GDP per Capita (Current Washington, DC: World Bank. US$)—Comoros, World, Data. https:// World Bank. 2021f. Poverty and Equity Assessment d a t a . w o r l d b a n k . o r g / i n d i c a t o r / N Y. G D P. Report Comoros. Washington, DC: World Bank. P C A P. C D ? e n d = 2 0 2 0 a n d l o c a t i o n s = K M - World Bank and Deltares. 2021. An EPIC Response: 1Wandstart=1980andview=chart. Innovative Governance for Flood and Drought World Bank. 2020e. International Tourism, Number of Risk Management. Washington, DC: World Bank. Arrivals—Comoros, Data. https://data.worldbank. https://www.worldbank.org/en/topic/water/publi- org/indicator/ST.INT.ARVL?locations=KM. cation/an-epic-response-innovative-governance- World Bank. 2020f. Personal Remittances, Received for-flood-and-drought-risk-management. (% of GDP)—Comoros, Data. https://data. World Food Programme. 2019. Comoros—Logistics worldbank.org/indicator/BX.TRF.PWKR.DT.GD. Capacity Assessment. ZS?locations=KM. World Health Organization. 2013. Water, Sanitation World Bank. 2020g. Population Density (People and Hygiene Attributable DALYs (‘000). per Sq. Km of Land Area)—Comoros, Data. The Global Health Observatory. https:// https://data.worldbank.org/indicator/EN.POP. www.who.int/data/gho/data/indicator s/ DNST?locations=KM. indicator-details/GHO/water-sanitation-and- World Bank. 2020h. Rural Population—Comoros, Data. hygiene-attributable-dalys-(000). https://data.worldbank.org/indicator/SP.RUR. World Health Organization. 2018a. Ambient Air TOTL?locations=KM. Pollution Attributable DALYs (per 100 000 World Bank. 2020i. The World Bank in Seychelles. Population, Age-Standardized). https:// h tt p s : / / w w w . w o r l d b a n k . o r g / e n / c o u n t r y / www.who.int/data/gho/data/indicator s/ seychelles/overview. indicator-details/GHO/ambient-air- pollution- World Bank. 2020j. Toward a More United and attributable-dalys-(per-100-000-population-age- Prosperous Union of Comoros—Systematic standardized). Country Diagnostic. Washington, DC: World Bank. World Health Organization. 2018b. Household https://documents1.worldbank.org/curated/ Air Pollution Attributable DALYs (per 100 en/354101559590231457/pdf/Comoros-Toward- 000, Age-Standardized). https://www.who. a-More-United-and-Prosperous-Union-of- i n t / d a t a / g h o / d a t a / i n d i c a t o r s / i n d i c a t o r- Comoros-Systematic-Country-Diagnostic.pdf. d e t a i l s / G H O / h o u s e h o l d - a i r- p o l l u t i o n - References  | 111 | a t t r i b u t a b l e - d a l y s - ( p e r- 1 0 0 - 0 0 0 - a g e - 2000–2020: Five Years into the SDGs. https:// standardized). washdata.org/sites/default/files/2022-01/jmp- https://www.who.int/data/gho/data/indicator s/ 2021-wash-households_3.pdf. indicator-details/GHO/mortality-rate-attributed- WWF . n.d. Southern Africa: Island group between to-exposure-to-unsafe-wash-services-(per-100- Madagascar, Ecoregions, WWF . World Wildlife 000-population)-(sdg-3-9-2). Fund. https://www.worldwildlife.org/ecoregions/ World Health Organization. 2019a. Proportion at0105. of Population with Primary Reliance on Youssouf, A. M. 2010. Coastal Livelihoods in the Union Polluting Fuels and Technologies for Cooking of Comoros—Small-Scale Fisheries. https:// (%). https://www.who.int/data/gho/data/in- iwlearn.net/resolveuid/2128d9fc9c169971fb5181f d i c a t o r s / i n d i c a t o r- d e t a i l s / G H O / g h o - p h e - 03c3a18ba. population-with-primary-reliance-on- Zeller, D., Vianna, G., Ansell, M., Coulter, A., Derrick, B., polluting-fuels-and-technologies-for-cooking- Greer, K., Noël, S.-L., Palomares, M. L. D., Zhu, A., proportion. and D. Pauly. 2021. “Fishing Effort and Associated World Health Organization and the United Nations Catch per Unit Effort for Small-Scale Fisheries in Children’s Fund. 2021. Progress on Household the Mozambique Channel Region: 1950–2016. ” Drinking Water, Sanitation and Hygiene Frontiers in Marine Science, 1048.  nnex 1: Estimated Costs and A Benefits of Restoration Projects for Different Biomes Figure 37.  Estimated costs and benefits of restoration projects in different biomes. Thousands US dollars per hectare EsƟmated costs and benefits of restroraƟon 1200 projects in different biomes Coral reef 1000 Coastal biomes 800 600 400 Net present value benefit over 40 years Wetlands Typical cost of 200 Temperate and Tropical forest Lakes - restoraƟon boreal forest Rivers Mangroves EsƟmated annual benefit Grasslands from restoraƟon Woodlands shrublands 0 Source:  Pravettoni, UNEP, and GRID-Arendal 2012. 113  Annex 2: Calculations on the Costs of Environmental Degradation49 1. Land degradation Parameter Value Unit Source ESV Terrestrial 1,487,886,624 US$/ha/year Sutton et al., 2016 ESV Degraded 1,213,456,600 US$/ha/year Sutton et al., 2016 2. Deforestation Parameter Value Unit Source Tropical forest ecosystem service value 5,264 Int. Dollar/hectare/year De Groot et al., 2012 (total of service mean values) Forest area 2020 32,920 Hectares World Bank 2020 Forest area 1990 46,060 Hectares World Bank 2020 Agricultural GDP (including fisheries and 334,017,693 Constant 2015 USD World Bank 2020a forestry) Fishery contribution to agricultural GDP 7.5 Percent World Bank 2020k Forestry contribution to agricultural GDP 18,000,000 Constant 2006 US$ FAO 2008 Agricultural area 131,000 Hectares World Bank 2018 CPI (2007–2022) 1.34 Dollar Official Inflation Data (2022) CPI (2006–2022) 1.38 Dollar Official Inflation Data (2022) CPI (2015–2022) 1.18 Dollar Official Inflation Data (2022) The costs of deforestation are based on the deforestation rate, the ecosystem service value of forests, and the ecosystem value of new land use. The deforestation rate was calculated using World Bank data: Since the primary cause of deforestation is clearance for agricultural expansion, it is assumed that the entire deforested area is used for agriculture. The ecosystem service value (ESV) of the new land use was obtained by subtracting the CPI adjusted fisheries and forestry contribution from the agricultural GDP and dividing this by the total agricultural area. 49 Analysis by Deltares 115 | 116 |   Comoros Country Environmental Analysis 3. Health Parameter Value Unit Source Water, Sanitation and Hygiene 8,747 DALY World Health Organization (WHO) 2013 attributable DALYs Ambient Air Pollution attributable 10,965 DALY WHO 2018a DALYs Indoor Air Pollution attributable 30,466 DALY WHO 2018c DALYs Human Development Index (HDI) 0.554 - UNDP n.d. Costs per DALY averted (low HDI 998 US$/DALY Daroudi et al., 2021 score) Costs per DALY averted (Medium 6,522 US$/DALY Daroudi et al., 2021 HDI score) CPI (2011–2022) 1.24 Dollar Official Inflation Data (2022) The costs per DALY averted are different based on HDI category. The HDI of the Comoros is 0.554, barely falling into the medium category (0.55 – 0.70). To get a more fitting presentation of the actual costs per DALY averted, it was decided to take the average between the low and the medium HDI categories: Subsequently, the costs per DALY averted were multiplied with the total number of DALYs per health category and were corrected using the CPI:  nnex 3: Impacts of Environmental A Degradation on the Livelihoods of the Comorian Population Source: Created by Deltares 117  nnex 4: Overview of Fisheries A Laws and Regulations 1. Décret N°20-051/PR du 1er avril 2020, portant certains résidus et contaminants dans les produits promulgation de la loi N°19-05/AU portant révision de la pèche du Code des Pêches et de l’Aquaculture, Loi N° 07- 011 du 29 août 2007 10. Arrêté N°17-016/VP-MAPEATU-CAB du 13 avril 2017, relatif aux contrôles officiels applicables aux 2. Décret N°21-071/PR du 13 juillet 2021, portant prom- produits de la pêche ulgation de la Loi N°21-005/AU du 29 juin 2021, portant nationalisation de la Société Anonyme 11. Arrêté N’17-017/VP-MAPEATU-CAB du 13 avril « Comoros National Fishing Compagny.SA » 2017, fixant les règles d’hygiène applicables aux produits de la pêche destinés à l’exportation 3. Décret N°14-034/PR du 14 mars 2014, portant ob- ligation de publication des accords de pêche 12. Arrêté NI7-018/1/P-MAPEATU-CAB du 13 avril 2017, ou autres arrangements assimilés, de la liste relatif aux critères microbiologiques applicables des navires autorisés à pêcher ou à exercer des aux produits de la pêche activités liées à la pêche et des revenus associés 13. Arrêté N°17-019/VP-MAPEATU-CAB du 13 avril 4. Décret N°15-050/PR du 15 avril 2015, portant appli- 2017, relatif aux eaux utilisées dans ‘Industrie cation du Code des Pêches et de l’Aquaculture de de traitement des produits de la pêche et de l’Union des Comores. l’aquaculture 5. Décret N°15-051/PR du 15 avril 2015 portant 14. Arrêté N°16-005/MAPEEIA-CAB du 06 janvier 2016 Création de l’Office National de Contrôle Qualité et portant désignation de l’autorité compétente de de Certification des Produits Halieutiques en Un- contrôle et de certification d’origine de capture des ion des Comores (ONCQCPH) ressources halieutiques en Union des Comores 6. Décret N°15-052/PR du 15 avril 2015 portant Con- 15. Arrêté N°17-016/VP-MAPEATU-CAB du 13 avril statation des infractions sanitaires et les mesures 2017, relatif aux contrôles officiels applicables aux administratives prises sur la vente et la salubrité produits dé la pêche des produits halieutiques 16. Arrêté conjoint du 25 février 2021, relatif 7. Arrêté N°03-32/MDIPTTI/CAB du 26/09/2003 fixant l’immatriculation et au marquage des les attributions des Départements et le mode de embarcations de pêche locales de type artisanal Fonctionnement de la Direction Nationale des d’une longueur égale ou inférieures à 12m Ressources Halieutiques 17. Arrêté N°17-67/VP-MTPTTIC-CAB du 1er février 8. Arrêté N°17-014/VP-MAPEATU-CAB du 13 avril 2017, portant réglementation des embarcations de 2017, relatif aux méthodes d’échantillonnage à pêche d’une longueur inférieure à 12m appliquer pour l’analyse de certains contaminants dans les produits de la pêche. 18. Arrêté N°20-032/MAPE-CAB du 21 mars 2020 portant modalités et conditions de délivrance 9. Arrêté N°17-015/VP-MAPEATU-CAB du 13 avril des cartes professionnelles des revendeurs des 2017, relatif aux limites maximales autorisées pour produits de la pêche 119 | 120 |   Comoros Country Environmental Analysis 19. Arrêté N°20-033/MAPE-CAB du 21 mars 2020 National de Contrôle Qualité et de Certification portant modalités et conditions de délivrance des des produits halieutiques (ONCQCPH) cartes professionnelles de pêche Arrêté conjoint du 11 mars 2016, portant 22. 20. Arrêté N°20-034/MAPE-CAB du 21 mars 2020 création  d’un Comité de Concertation, et de portant nomination des inspecteurs de Pêche du coordination entre l’Administration chargée Centre National de Contrôle et de Surveillance des des pêches et l’Autorité chargée des Affaires Pêches (CNCSP) maritimes 21. Arrêté N°20-036/MAPE-CAB du 21 mars 2020 portant nomination des inspecteurs de l’Office Source:  DGRH 2021b Annex 5: Soil Restoration Measures Table 16.  Soil restoration measures Objective Restoration Measures Improve yield • Dispersal of high-quality seeds of crops that produce higher and faster yields (pass along to other farmers) • Training in more productive agricultural practices • Promotion of the use of organic compost • Improved access to market information and creation of a network of entrepreneurs selling agricultural inputs Increase soil fertility • Livestock management integrated with agriculture • Reduction in the overuse of chemical fertilizers and pesticides Anti-erosion • Hedges and anti-erosion bunds of fast-growing tree species • Training in agroforestry adoption • Training in planting trees across contour lines and developing ridges to protect root crops Adapted from:  Doulton et al., 2016. 121  nnex 6: Maps of Sand Extraction A in Ngazidja and Ndzuwani Figure 38.  Map of sand extraction in Ngazidja. Source:  AMCC 2019a. Note:  Red stars indicate sites where sand is extracted from beaches. The blue triangles indicate land-based extraction sites. The green penta- gons indicate sites with active crushers. The brown pentagons indicate sites with stationary crushers. 123 | 124 |   Comoros Country Environmental Analysis Figure 39.  Map of sand extraction in Ndzuwani. Source:  AMCC 2019a. Note:  Red stars indicate sites where sand is extracted from beaches.  nnex 7: Key Environmental Policy, A Legislation, and International Agreements of the Comoros Level Title Date and Legal Tool Objectives Reforestation and forest 1988: Law N°88-006/PR (1) Safeguard the local environment, (2) protect agricultural plantations, management (3) combat erosion, (4) provide fuel or construction wood or improve living conditions National Environmental Policy 1993: Decree No. 93-214/PR Ensure sustainable and rational management of natural resources and support the rational use of resources in the development of alternative solutions. Currently in the process of updating. Environmental Action Plan 1994 Identify a set of actions to fulfill the PNE (PNE) Environmental Impact Assess- 1994: Decree No. 94/100/PR Establish key elements of the EIA process ment (EIA) Framework Law of the Envi- 1994: Decree No. 94-018/AF Regulate all activities related to the sustainable management and ronment conservation of land, coastal, and marine biodiversity. Currently in the process of updating. Water Code 1994: Law No. 94-037. Implement integrated water resource management to contribute to the 2020: revised Law No. socioeconomic development of the Comoros 20-036/AU Agricultural Policy 1994, updated in 2011 and Achieve food security, create employment, and promote sustainable use 2014 of natural resources Protected species 2001: Order No. 01/033 / MPE List protected species. Currently in the process of updating. National / CAB Fishing and Aquaculture Code 2007: Law No 07-011/AU Ensure sustainable management. Updated in 2020 to include illegal un- 2015 revision, 2020 revision regulated and unreported (IUU) fishing. National Forests Policy 2010 Conduct conservation and sustainable development of the forest cover Waste 2011: Law No. 17-011/AU Production, importation of plastic bags and packaging ban Priority Action Plan for Forestry 2011–2015 Develop a reference framework to guide funding for the National Forest Policy Development (PAPDF) Forestry Management Act 2012: Law No. 12/001 AU Govern forests under the domain of public persons and the domain of private individuals, for sustainable management National Action Plan to 2014 Secure land tenure for farmers and promote sustainable land management Combat Desertification National Parks Strategy 2017 Manage more than 25 percent of the national territory with a community ap- proach for ecological and sustainable economic development National protected areas 2018 Law No. 18-005/AU National system of protected areas system 2019 Decree No. 19-129/PR Protected areas 2019: Presidential Decree No. Define the conservation and management of a protected area and clas- 19-129/PR sify its protection Access to genetic resources 2020: Law No. 20-001/AU Regulate access to genetic resources and associated traditional knowl- Decree No. 20-081/PR edge, ensuring sharing of fair and equitable benefits from their use 125 | 126 |   Comoros Country Environmental Analysis Level Title Date and Legal Tool Objectives United Nations Convention on the Law of the Sea (UNCLOS) Define the rights and responsibilities of nations concerning their use of the (1982) world’s oceans Convention on Biological Diversity (1992) Conserve biological diversity, promote the sustainable use of its components, and encourage equitable sharing of the benefits 2030 Agenda for Sustainable Development (2015) Provide a shared blueprint for peace and prosperity for people and the planet, now and into the future International The United Nations Framework Convention on Climate Change Stabilize greenhouse gas concentrations “at a level that would prevent dan- (1992) gerous anthropogenic interference with the climate system.” Stockholm Convention on Persistent Organic Pollutants (2007) Reduce or eliminate the releases resulting from intentional or unintentional persistent organic pollutants and releases from chemical wastes African Union Agenda 2063 (2015) Aim for inclusive and sustainable development through unity, self-determina- tion, freedom, progress, and collective prosperity Paris Agreement (2015) Strengthen the global response to the threat of climate change Adapted from:  Nairobi Convention 2022; PNE 2021. Annex 8: Stakeholder Consultations This annex describes the stakeholder consultation  List of stakeholders interviewed individually and Table 17. process. It consisted of four phases: in focus groups 1. Interviews with key stakeholders Name Organization Mr. Elamine Youssouf Direction Générale de l’Environnement 2. Site visit to the Comoros M’bechezi et des Forêts 3. Two-day workshop in Moroni Mrs. Hayria Mohamed Point focal adjoint, Direction Générale de l’Environnement et des Forêts 4. Final workshop in Moroni Mrs. Fatouma Abdallah Programme ANCAR2 Each phase is described below with regard to object- Dr. Anwar Maeva Université des Comores/ Faculté des Sciences et Techniques ives, stakeholders consulted, and outcome. Mr. Faissoil Mhadji DGEF Mr. Ali Mohamed Nobataine Coordinateur National PREFER Phase 1: Stakeholder interviews Mr. Mahamoudou Abidina Juriste DGRH The objectives of the semi-structured interviews Dr. Ahmed Mohamed Nadjim Biologiste marin Faculté de sciences were to: et techniques Mr. Mohamed Halifa Conseiller / AIDE 1. Assess the perception of stakeholders on the Mr. Fouady Goulam CGP main environmental challenges (related to key Mr. Abdillah Msaidie Président de la chambre de l’agriculture, sectors) in the Comoros and the gaps between pêche et l’élevage the current and desired levels of sustainability Mr. Imam Abdillah Direction General de la Coopération 2. Collect information on perceived opportunities Internationale (recent and future initiatives and measures) Dr. Andilyat Ahmed Université des Comores/ Faculté des for the development of key economic sectors Sciences et Techniques that will address environmental challenges and Mr. Soalihy Hamadi CGP align them with desired socioeconomic devel- Mrs. Kamaria Hassane INRAPE opment Mr. Elarif Abdoulkarim Agent S. Foret Some respondents were interviewed individually Mr. Samir Ali Gestion des ressources naturelles/DGEF and others in a focus group setting. Table 17 lists the Mr. Chamouine Soidri DG/DGRH respondents. Mrs. Marie Ange Chargée de programmes Délégation de l’Union Européenne Mr. Mohamed Ali Mlazahahé Chargé de programmes Délégation Phase 2: Site visit to the Comoros de l’Union Européenne The site visit to the Comoros took place March 8–13, Mr. Pouliquen Tangi AFD 2022. The objectives were as follows: Mr. Mohamed Ibrahim Diop Maire de la Commune de Gouwengé Dr. Kamal Thabiti Soudjay Direction Générale des Ressources 1. Strengthen collaboration with the local partners Halieutiques and stakeholders to enhance the quality of the Mr. Mouchtadi Mmadi Parc National de Mohéli country environmental analysis (CEA). 127 | 128 |   Comoros Country Environmental Analysis Table 17. (Continued )  List of organizations engaged during the site visit Table 18. to the Comoros Name Organization Mr. Bouchourane Aoussidine Coopérative des Pêcheurs des Comores/ Organization Category Anjouan Bureau de l’Union Européenne en Union des International Organization Mr. Mmadi Djae Direction de l’Aménagement Territoire Comores Mr. Mohamed Abdou Direction de l’Aménagement Territoire Agence Française de Développement – Union International Organization Mr. Mohamed Saindou Charge de la planification des Comores Direction Tourisme UNDP International Organization Mr. Fakridine Djambae Juriste RNAP Direction Générale de l’Environnement et des Government Mr. Houssoyini Housseni Coordinateur Projet R-POC Forêts Mr. Ahamada Mmadi DGEAT Direction Générale des Ressources Government Halieutiques/de la Pêche Mr. Ahmed Youssouf Maison des Organisations de la Société Civile (MOSC) Commissariat Général au Plan Government Mr .Zaharani Moindjié AMIE Bureau Géologique Government Mrs. Nema Ahmada Plateforme Femmes et développement Maire municipalité Ngongwe Government durable Herbier National des Comores/Université des Nongovernmental Mr. Bacar Mze ‘Ali Bureau Geologique des Comores Comores Organization (NGO)/ Mohamed Chaheire Bureau Geologique des Comores private sector Mr. Said Boina DGRH Maison des Organisations de la Société Civile NGO/private sector (MOSC) Dr. Soule Hamidi Doyen de la Faculté des Sciences et Tech- niques/Université des Comores Dahari NGO/private sector Mrs. Ramadhoini Ali Enseignante chercheur, Faculté des Le Réseau National Femmes and NOG/private sector Sciences et Techniques/Université des Développement (RNFD) Comores Union des Chambres d’Agriculture d’Elevage NGO/private sector Youssouf Mze Agence Nationale de gestion des dechets et de la Pêche Said Mmadi Expert Etudes d’Impact Environnemental Microfinance NGO/private sector DGEF Cordio (international NGO) NGO/private sector Mr. Joshua Rambahiniarison Field researcher, projet de Renforcement de la Protection des Oceans Comores Plongée NGO/private sector Mr. Hugh Doulton NGO Dahari Anjouan o Lack of appropriate legislation, organization, 2. Collect local data and information to enrich and funding were frequently mentioned as the CEA. obstacles. 3. Identify drivers, pressures, status, and impacts o Lack of training/capacity is an important obstacle of environmental challenges as well as the exist- to sustainable management of resources and de- ing policy plans for the environmental sectors; velopment of sectors. Capacity building/training discuss (identified) data and information gaps is therefore necessary at different levels, includ- as well as proposed strategic programs for the ing ministry, municipality, and community (farm- way forward. ers/fishermen). 4. Plan next steps (including technical aspects of o Lack of awareness is an obstacle; therefore, the Phase 3 workshop in Moroni). awareness raising is necessary. The organizations visited during the site visit are listed o There has been a lack of involvement of commu- in Table 18. nities in implementation of projects; The conclusions from the site visit are as follows: o It would be instrumental to involve commu- nities, NGOs, informal community organiza- o Examples exist of effective projects, but there is tions at the submunicipality level, and national a lack of continuity in efforts following project bottom-up organizations like the Chamber of completion. Agriculture. Annex 8: Stakeholder Consultations   | 129 | o One way to involve women more is to focus on Validation Workshop Agenda (Day 2) activities in which women engage and on the ca- pacity building of women. Day 2 Time Activities 08.00 Walk in Phase 3:  Validation workshop 08.30 Opening of the workshop and recap of day 1 The validation workshop was held April 7–8, 2022 in 08.40 Presentation of solutions and actions Moroni. Four objectives for participants were devel- 08.50 Plenary discussions and selection of 3–4 solutions to be developed oped for the workshop: 09.20 Group discussions: steps for realization of solutions/actions o Understand the importance, scope, and develop- 10.20 Break ment process of the CEA 10.35 Return to plenary and presentation 11.00 Synthesis, validation of selected actions and next steps Understand the project objectives and o 11.15 Acknowledgments/closing remarks preliminary results. They have ownership of 11.30 Closing of the workshop these preliminary results. o The opportunity to ask questions and provide Table 19.  Validation workshop participant list comments and input on the preliminary results o The opportunity to indicate their perceived prior- Name Organization ities for future action President of the Chamber of Agriculture, Abdillah Msaidie Fishing and Livestock The workshop agenda is presented below. Regional Directorate of Environment and Abu Mahoma Forests in Moheli Validation Workshop Agenda (Day 1) Ahamada Mmadi DGEAT Ahmed Karim Farida Ministry of Energy Day 1 University of the Comoros/Faculty of Sci- Time Activities Alhabib Said Toihir ence and Technology 08.00 Welcoming of participants, registration Ali Abdou Razar DNSAE 08.30 Opening of the workshop Ali Mohamed Nobataine PREFER National Coordinator 08.45 Introduction of participants Deputy Director General, Directorate 09.10 Introduction Ali Mohamed Youssouf General of Fishery Resources   - Presentation of the context and agenda Ameroine Mohamed DGAT   - Adoption of the agenda Athoumani Moussa ANACM/ METEO 09.20 Introduction to the workshop and stakeholder engagement  - Project objectives and process Bouchourane Aoussidine Comoros Fishermen Cooperative/Anjouan   - Previous steps (interviews, Deltares site visit to Moroni) University of the Comoros/Faculty of Sci- Dr. Ahmed Mohamed Nadjim ence and Technology 09.35 Presentation of preliminary results Dr. Ahmed Ouled NGO Ulanga Observations/questions/answers University of the Comoros/Faculty of Sci- 10.15 Break Dr. Andilyat Ahmed ence and Technology 10.45 Breakout group discussions (5 groups) University of the Comoros/Faculty of Sci- 1. Land Dr. Anwar Maeva ence and Technology 2. Fresh water and access to water National Directorate of Agricultural Dr. Fouad Mohamed Oussouf 3. Forests Strategies 4. Marine and coastal: fishing General Directorate of Fisheries Re- Dr. Kamal Thabiti Soudjay 5. Marine and coastal: ecotourism and national parks sources 12.10 Return and presentation in plenary Faissoil Mhadji DGEF 12.30 Conclusions, introduction of day 2, closing of day 1 Fakridine Djambae RNAP Lawyer 12.45 Closing of the workshop Fakridine Mohamed Representative AIDE a MOHELI | 130 |   Comoros Country Environmental Analysis Table 19. (Continued ) • The environment is of crucial importance for the Comoros. Everyone must be aware of it. Name Organization General Commissioner • There are no major differences between this Fouady Goulam CEA and the results from a 1994 diagnosis. If the for Planning Comoros is still at the same point, it is because Hachim Abderemane Lagazette Newspaper nothing has been done. Real solutions must be Hachim Abdermane ONG ULANGA NGAZIDJA found. Hafsoiti Abdou DGEF The workshop was attended by 48 individuals from Houssoyini Housseni Project Coordinator/R-POC 40 organizations (excluding Deltares, AIDE, and UniSey). A participant list is presented in Table 19. KAMARIA HASSANE INRAPE Loukoumane Moussa DGEME There are a lack of data and new measurements. •  Mariama Chabani ANGD Modern measurement tools are needed to analyze and measure pollution, for example. Mhoumadi Soihibou NGO AIPEC Mmadi Ahamada RNAP Progress has been made in environmental man- •  agement, but more efforts are required to make a Mmadi Djae Direction of the Territory Planning difference. Mohamed Abdou Direction of the Territory Planning • Build upon the efforts and progress made in past Mohamed Halifa HELP projects, as stakeholders are proud of it. Mohamed Maecha SONEDE A key challenge is integrating environmental •  Mohamed Saindou Tourism Department aspects into the missions of all institutions and Platform of Women for Sustainable De- not only the Ministry of the Environment, to whom Moinaecha Ahamada velopment responsibility is always attributed. All ministries Mouchtadi Mmadi National Park of Moheli must be concerned about the environment. Mr. Soalihy Hamadi General Planning Commission Many documents have been written, but over the •  Mr. Ali Ibrahim Maziada Directorate General of Energy years and with the passage of time, too much National Center of Documentation and copy and paste has taken place and few new Mr. Yahaya Ibrahim insights have been developed. The approach Scientific Research Ms. chadhouliati abdou of involving stakeholders is much appreciated. National Director of Water and Sanitation It is important to go to the field and conduct chakour Deputy Focal Point, General Directorate of interviews. Ms. Hayria Mohamed Environment and Forestry Sanitation and air pollution are key problems •  Said Ahamada Tony Banda Bitsi Association alongside waste pollution. This must be taken into Said Ali Antoissi World Bank account, and concrete actions need to be included in the CEA. Said Ali Antoissi Operations Manager Saifidine Mohibaco ANACM • Consider including “new” minerals such as gold, copper, oil, and gas in the CEA development. Director of the Comoros Geological Youssouf Hamadi Survey Regional Directorate of Environment and Zalhat Bacar Forests in Anjouan Phase 4: Final workshop The final workshop was held June 28, 2022, in The workshop was attended by 48 individuals from Moroni. The objective was to discuss the final 40  organizations (excluding Deltares, AIDE, and conclusions of the CEA. The workshop agenda is pre- UniSey). A participant list is presented in Table 19. sented below. The discussions with stakeholders at the workshop The workshop was attended by 34 individuals yielded the following points: (Table 20). Annex 8: Stakeholder Consultations   | 131 | Final Workshop Agenda Table 20.  Final workshop participant list Time Activity Name Organization 08.00 Welcoming of participants, registration Ali Ibrahim Maziada Directeur Général de l’Énergie et des mines 09.00 Opening remarks, introduction of participants and agenda Kamaria Hassane INRAPE 09.30 Introduction of the workshop and presentation of the main Nassur Ahamada Mroimana Expert environnementaliste PRPKR results of the ASP Nasssourdine Ahamada Chercheur au CNDRS 10.15 Break Aboubacar-Tayffa Hassanali Consultant AIDE 10.45 Discussion on waste management Ramadhoini Ali Faculté des sciences et techniques/Herbier 11.30 Discussion on freshwater des Comores 12.15 Conclusions Ismael Houda Oumilhouda PFDDSA 12.30 Closing of the workshop Dr. Kamal Thabiti DGRH 13.00 Lunch Youssouf Ben Ali Coordinateur du parc national Coelacanthe Mohamed Saindou Direction du tourisme The discussions on waste management and water Nadjouwa Mohamed DGEF resource management resulted in the following insights: Said Ahamada Bandambitsi Issiwaila Mohamed DGA/DNSAE Waste management: Mkantsilé Abd-El-malik DGA/DGEF • Support the development of comprehensive legis- Chadhouliati Abdou Directrice Nationale eau et assainissement lation and help define the institutional framework Al-Habib Said Toihir UDC/FST for solid waste management. Salim Mohamed BandaBitsi Mouctadi Madi Chargé de mission environnement marin, • Develop a comprehensive integrated solid waste PARC NATIONAL MOHELI management strategy as part of a broader cir- cular economy vision, considering interventions Poriaven Tayi AFD in waste prevention, collection, disposal, and Anrifidddine Ousseni Agence des Parks Nationaux des Comores recycling. Nassuf Humblot Conservateur PNMN Mohamed Maecha DSNEPE • Expand and improve waste collection services to Hamidou Mfawoumé Journaliste Comores Dounia news households not yet covered, minimize collection losses, and increase voluntary and community col- Ikrame Ben Said Journaliste ORTC lection points, including those for recyclable ma- Houssoyni Housseini Coordibnateur National du projet R.P.O.C/ terials (“waste banks”). WILDOCEAN Faissoili Assoumani Commune de Ngouengwe • Reduce solid waste generation by encouraging the Youssouf Hassani Facilitateur communautaire/ Projet Kenet design of reusable products and the use of alterna- Ismael Mohamed Hassane BGC tive materials. Ahmed Mohamed Nadjim FST/UDC • Promote composting to reduce the volume of Mariama Chabani ANGD residual organic waste and increase benefits to Fatoumia Abdallah DGEF farmers. Zamil Maanfou Conservateur du Parc National Mont • Raise awareness of solid waste prevention. tringui/ ANJOUAN Samir Ali Chargé de la gestion de R.N-DGEF Water resource management: Baraka Saindou Agent de conservation communautaire Parc National Cœlacanthe • Facilitate the development of water master plans at the island level. • Conduct a vulnerability and risk assessment study • Clarify roles and mandates as part of the decen- for all water sources. tralization process. • Further strengthen climate-resilient integrated • Support strategic prioritization of the water sector water resource management. at the national level, focusing on hydro-climatic risk management in particular. • Expand water, sanitation, and health programs and improve drinking water quality standards and • Strengthen the water resource monitoring system. monitoring. UNION OF THE COMOROS