IFC requires that this document is made available through the World Bank InfoShop and to the locally affected community no less than 30 days prior to project consideration by the IFC Board of Directors. The Summary of Project Information (SPI) also provides details of where the ERS has been made available to the locally affected community. The SPI must be sent to World Bank InfoShop no less than 30 days prior to project consideration by the IFC Board of Directors.

This is a category B project according to IFC's environmental and social review procedure because a limited number of specific environmental and social impacts may result which can be avoided or mitigated by adhering to generally recognized performance standards, guidelines or design criteria. The review of this project consisted of appraising technical, environmental, and social information submitted by the project sponsor, including a fire safety audit, and the technical appraisal and site review completed by IFC staff. The following potential environment, health and safety, and social impacts of the projects were analyzed: - development and implementation of an environmental management program; - site history and land use, including potential site contamination from past environmental practices; - liquid effluent treatment and disposal; - solid waste disposal; - use of CFCs in air conditioning and refrigeration equipment; - fire protection and life safety; - labor issues and any employee training, health and safety programs during construction and project implementation.

The sponsor has presented plans to address these impacts to ensure that the proposed project will upon implementation of the specific agreed measures, comply with the environmental and social requirements - the host country laws and regulations and the World Bank/IFC environment and social safeguard policies and the environmental, health and safety guidelines. The information about how these potential impacts will be addressed by the sponsor/project is summarized in the paragraphs that follow. ENVIRONMENTAL MANAGEMENT: The sponsor will ensure that refurbishment activities and operating practices comply with industry norms, local requirements, and World Bank/IFC policies and guidelines. Once operational, the hotel commits to adopting an environmental policy and management system with appropriate management personnel responsible for implementation. The sponsor is also actively considering partnering with an internationally recognized hotel group that would require environmental management and standards. SITE HISTORY AND LAND USE: The project is located at the current Festac ‘ 77 Hotel site, within the Amuwo Odofin Housing Estate. The hotel is well situated in a busy mixed use (residential, commercial and light industrial) area of Lagos, close to the airport, the seaport, some major markets and the main road into Nigeria from the Republic of Benin. Both gas and diesel were stored in over ground tanks and sponsors note there is no evidence of contamination. In the tests and demolition work carried out to date, no evidence has so far been found of any asbestos. IFC’s technical team has confirmed that no equipment containing CFCs will be installed in the hotel. WATER USE & DISPOSAL: The project includes the installation of a water treatment plant for potable water as well as a new sewage treatment facility. The effluent treatment will meet both WHO and IFC standards, and final effluent from the treatment plant will be discharged into an adjacent canal. Storm drainage will be discharged directly into the adjacent canal as well. Water will be supplied by the city mains, supplemented by treated borehole supply, and at full capacity water usage is estimated at 510m3/day. Reuse of gray waters is being considered and the project will seek further initiatives to reduce water consumption and use, including low-flow capacity toilets. SOLID WASTE DISPOSAL: Solid waste will be sorted and collected by the municipal waste collection company and disposed of in Government-designated landfills. No hazardous waste will be generated. Refurbishment waste will be removed and disposed in designated landfill. Furniture, equipment, sanitary appliances and interior elements have already been sold to wider public for reuse. FIRE SAFETY: Fire safety and control measures include fire alarm and control systems, sprinkler systems, escape stairs and emergency evacuation procedures, including staff training. The sponsor has commissioned a fire safety audit of the existing buildings to assess compliance with IFC's fire protection and life safety guidelines. This will include preparation of a Corrective Action Plan (CAP), including preparation of an Emergency Response Plan, which the sponsor is committed to implementing. The sponsor has committed to comply with IFC's fire and life safety requirements and will prepare and submit a timetable for implementation prior to Board approval. LABOR ISSUES: Working age at the hotel will be 18 years and therefore the project will comply with IFC’s harmful child and forced labor policy. Working hours, under local law, will be 8 hours a day and local minimum wage will be used for all employees. The previous hotel has been shut-down for about 1.5 years. Laid off workers may be re-hired through a competitive hiring process. An expected total of 550 new jobs will be created from this project. The project will seek to comply with IFC’s health and safety guidelines during refurbishment and operation and local health and safety laws.

This ERS contains the full environmental and social documentation prepared for the project.

Accordingly, IFC concludes that the proposed project will meet the applicable World Bank/IFC environment and social policies and the environmental, health and safety guidelines upon successful implementation of the agreed mitigation measures.

IFC will evaluate the project's compliance with the applicable environmental and social requirements during the lifetime of the project by reviewing the annual monitoring reports (AMRs) prepared for the project covering: - the status of implementation of any measures contained in this ERS, and - the ongoing performance of project-specific environmental, health and safety and social as reflected in the results of periodic and quantitative sampling and measuring programs. Periodic site supervision visits by IFC may also be conducted.