The sponsor has presented plans to address these impacts to ensure that the proposed project will, upon implementation of the specific measures agreed, comply with applicable host country laws and regulations and World Bank/IFC requirements. The information about how these potential impacts will be addressed by the sponsor/project is summarized in the paragraphs that follow.
Corporate Environmental and Social Management System (ESMS) development: MTN Holdings (Pty.) Ltd. developed an ESMS for all its operations, including Cameroon. MTN has provided IFC with a copy of the EMS for MTN Cameroon, as the Cameroon operations are nearest to those in Nigeria. It contains all of the key elements that IFC would require in an ESMS, including the company''s corporate environmental policy; establishment of a Safety, Health and Environment Management Department; relevant policies and regulations to which the project must conform; and a procedure for monitoring and reporting on performance annually. IFC will be providing MTN Nigeria with comments on the Cameroon ESMS, and the company will respond to these comments, incorporating them as appropriate. MTN Nigeria has agreed to submit a draft ESMS by 30 May 2002. IFC will review this draft ESMS and provide additional comments to MTN Nigeria as necessary. Submission of a final ESMS acceptable to IFC will be made a condition of first disbursement for the A loan portion of IFC''s investment. This ESMS must include the names of the staff within MTN Nigeria who will be responsible for environmental management and coordination.
Compliance of future projects with local requirements and World Bank policies and guidelines: The ESMS for MTN Cameroon stipulates that it has been specifically developed to ensure that all activities undertaken by the company will comply with the laws and regulations of the Government of Cameroon and with all applicable World Bank policies and guidelines. The ESMS for MTN Nigeria will be developed on the same premise, to ensure full compliance with all relevant requirements of the Government of Nigeria and the World Bank Group. Specifically MTN Nigeria has reviewed IFC''s Environmental, Health and Safety Guidelines for Telecommunications and confirmed that all future activities will comply fully with these guidelines as well as with all relevant host country regulations.
Environmental and social programs at MTN''s existing holdings in South Africa: Environmental, social development, and health and safety requirements in South Africa are the most stringent and well enforced in sub-Saharan Africa. MTN has confirmed in writing that it is compliant with all relevant national laws and regulations, as well as with those of local jurisdictions in which it operates. MTN Holdings (Pty) Ltd implemented Quality, Environmental and Safety &Health Management Systems and has received ISO 9000 and ISO 14001 certification for their operations in South Africa. MTN Holdings will, where practical, implement such systems in all its operations in Africa. All expatriates working in MTN’s Africa operations have already been trained on all the MTN Holdings (Pty) Ltd systems and their work is fully compliant with these systems.
Right of way alignment: The ESMS for MTN Cameroon states that the company attempts to minimize development of new land-based infrastructure wherever possible. This is done by utilizing existing infrastructure through lease arrangements, or by siting new infrastructure e.g., (access roads, land-based transmission infrastructure) along existing right-of-way alignments. MTN Nigeria will employ the same approach, and expects to establish few if any new right-of-way alignment. MTN Nigeria has reviewed IFC''s Environmental, Health and Safety Guidelines for Telecommunications in regard to right-of-way alignment, land acquisition, tower erection and creation of access and confirmed that it will follow the requirements stipulated therein. All new rights-of-way will be aligned to take environmental factors into consideration, minimizing the need for physical alteration and the impact on sensitive natural environments, cultural resources, agricultural lands, and residential and commercial areas. Wherever possible the company avoids establishing rights-of-way through remote and environmentally sensitive areas. However, should it be necessary at any time to construct infrastructure in sensitive areas, the potential impacts on the natural environment, indigenous populations, population immigration and natural resource exploitation will be assessed and measures adopted to minimize these impacts. These principles will be stated explicitly in the ESMS. In the unlikely event that any new rights of way result in physical or economic relocation of residents, MTN Nigeria will resettle and/or provide compensation to these residents in accordance with IFC’s Involuntary Resettlement policy.
Land acquisition: MTN Nigeria estimates that, depending on demand, it expects to require between 2,000 and 2,500 base stations over the next 3 years. The company expects that most of these will be in urban areas and, as a result, a significant percent (40-50%) will be rooftop-based stations. The remaining base stations will be land-based, and most of these will have to be constructed, as there are very few existing towers in Nigeria that MTN could lease space from. Sharing, however, will become possible as more GSM towers are rolled out. The ESMS for MTN Cameroon details the company''s procedure for identifying approximate locations for base stations and then using this information to guide the process of selecting a particular site. Factors taken into account in the site selection process include topographical constraints, presence of sensitive environmental features, and current land use. MTN enters into negotiations with the landowners to either lease of purchase the property and consults with neighbors and other interested parties, as necessary. In all cases , MTN abides by host country laws and regulations regarding compensation to affected parties. MTN Nigeria is currently negotiating with other cell operators to co-locate their GSM towers as they are rolled out, an approach that will reduce costs and minimize potential environmental impacts. As above, if land acquisition results in physical or economic relocation of residents, MTN Nigeria will be required to resettle and/or provide compensation in accordance with IFC’s Involuntary Resettlement policy.
Access road construction: The ESMS for MTN Cameroon states that it is the company''s practice to site base stations and other infrastructure along main roads, wherever possible, as this minimizes the cost, construction time, and environmental and human impacts of such infrastructure. Where it has been necessary to build or upgrade access roads, MTN''s approach, wherever possible, is to use existing dirt or gravel roads, rather than to build new road alignments. The roll-out of the network completed to date has required very little construction of access roads. In the exceptional instances where construction of access roads is necessary, potential impacts on the natural environment, indigenous populations, population immigration and natural resources will be assessed, and measures adopted to minimize these impacts, in full conformance with IFC guidelines. The MTN Cameroon ESMS includes sections on minimizing soil erosion in connection with access road construction activities.
Development of previously undisturbed land: As discussed above, MTN Nigeria does not expect many, if any, of its infrastructure to be in remote areas. Consequently, the company''s current roll-out plans have not identified any potential sites that would require construction on undisturbed land. Should this situation change, MTN Nigeria has agreed to abide by IFC guidelines and host country regulations in all such cases, and to inform IFC of the particular circumstances requiring construction on previously undisturbed land. The details of these instances will be included in the annual environmental and social monitoring report (AMR) provided to IFC.
Tower site and base station selection and construction: MTN Nigeria will utilize the same procedures outlined in the MTN Cameroon ESMS for selecting and constructing the base stations required for the project. As noted above, these procedures seek to minimize environmental, social and cultural impacts and to comply fully with host country and IFC Guidelines. MTN Nigeria will utilize only pre-qualified contractors with experience in the construction of cellular telephone infrastructure. As was done during the MTN Cameroon roll-out, MTN Nigeria will ensure that possible environmental and social impacts are monitored throughout the siting, design and construction phase. The visual impact of towers and other infrastructure will be considered and mitigated as necessary, and erosion and sediment control will be monitored regularly during construction. During the construction phase in Cameroon, MTN conducted weekly site meetings to resolve any technical problems that may arise, and utilized the services of an independent Environmental Supervisor at all sites under construction. The same procedure will be employed during MTN Nigeria''s construction phase. The Environmental Supervisor will visit each site once a week, and submit weekly progress reports. These reports will be compiled and submitted monthly to both MTN Nigeria management and the construction management team. Instances of noncompliance with the environmental requirements will be recorded. If necessary, construction will be halted to ensure that the noncompliance incident is halted and corrected. In the event of a ''chance find'' of possible archeological or cultural significance, construction activities will be halted and the relevant local authorities contacted. If the authorities conclude that the find is significant, the site will be abandoned and another site selected.
PCBs and halons: MTN Nigeria has confirmed that none of its electrical installations, fire suppression systems or other equipment will utilize polychlorinated biphenyls (PCBs) or halons. The company has also stated that it will not install any air conditioning, refrigeration or other equipment that utilizes CFCs.
Solid and liquid waste treatment and disposal: The ESMS for MTN Cameroon includes development of a comprehensive waste management plan, which is disseminated to all staff online. The online documentation also covers a waste management manual for staff. These documents address the disposal of solid wastes during both the construction and operational phases of the project. MTN Nigeria will follow the same waste management plan. Construction contractors are responsible for ensuring that construction wastes are properly disposed of in accordance with the MTN waste management plan and in full compliance with Government of Nigeria regulations. Solid wastes associated with the company''s operation are minimal, with the exception of office wastes, which will be disposed of in municipal landfills in accordance with applicable local and national regulations, and small volumes of metal scrap, which are stored for recycling.
Fire prevention and emergency response: The MTN Safety and Health system includes a section specifically for fire prevention and emergency response. The system includes general information as well as information specific to each building occupied by the company in a particular country. IFC has reviewed a copy of the specific fire prevention and emergency response plans for MTN''s South Africa operations, which are comprehensive and detailed. The system being implemented at MTN Nigeria, as planned facilities are rolled out, will follow the same principles as the South African plans, but will include specific details and provisions relevant to circumstances in Nigeria.
Labor issues, occupational safety and health, and training: MTN Nigeria has provided detailed information about its Human Resources policies and programs. The company complies fully with all relevant labor laws and regulations established by the Government of Nigeria. Salaries are highly competitive and the company provides extensive training programs for all staff. Specific training includes vocational courses such as vendor products/systems, skills development, management development and education directly related to job functions, as well as semi-vocational training in areas such as productivity improvement, organizational development and broader skills development. The company recognizes that Nigeria has a large labor pool that needs targeted on-the-job training, as well as skills transfer from expatriate employees. MTN Nigeria is in the process of establishing an Employee Council in conformance with the provisions of the Wages Boards and Industrial Council act of 1990. Elections for Council representatives have been held and the first Council meeting is to be held this month (April 2002). The company has a comprehensive occupational safety and health program, modeled on the program in place at MTN South Africa. The company has developed educational programs on nutrition and fitness, and has a referral arrangement with medical specialists for employees suffering from mental disorders, alcoholism, and drug addiction. Employees involved with equipment installation, monitoring and maintenance are provided with requisite personal protective equipment that conforms to international standards for the sector.
HIV/AIDS awareness and prevention campaign: MTN South Africa has instituted an HIV/AIDS policy, awareness and prevention program for all staff. This program, known as "MTN Cares," includes a HIV/AIDS policy and commitment of senior management to the issue, the provision of written educational materials on HIV/AIDS through the company''s human resources department, training on HIV/AIDS prevention, and provision of condoms at no charge to all staff. MTN Nigeria have developed a draft HIV/AIDS Policy and will also initiate an awareness and prevention program for staff and where possible dependents which will include, education and training, promotion and provision of condoms, First Aid and protective equipment, prevention and treatment of Sexually Transmitted Diseases, and Voluntary HIV counselling and testing. Additionally MTN S.A. launched the MTN Foundation in late 2001, which is a R40 million trust with the objective of streamlining the more than 40 education, science and technology, art and culture and rural development projects currently being undertaken by MTN in South Africa and which also includes some HIV/AIDS projects.
Local disclosure: IFC requires that this Environmental Review Summary (ERS) be made available for a 30 day public disclosure. Disclosure of the ERS is done on IFC’s website and in the host country where the project is located. MTN Nigeria has agreed to make the ERS available at publicly accessible locations in Nigeria, including its own offices and the IFC office in Lagos, and to advertise in a national daily newspaper that the ERS is available for review. In addition MTN Nigeria has agreed that future environmental documents (for example, any EIA reports that may be required under Government of Nigeria regulations) also will be disclosed publicly in conformance with IFC guidelines.
