- PS1: Environmental, Health and Safety, and Social Assessment and Management Systems
HMV has conducted limited environmental and social evaluations of the proposed Project as part of the applications for Water Concession, Forest Resource Use, and Water Course Occupation permits. Together with the Project Feasibility Studies, the documentation of these permit applications include preliminary baseline assessments and limited impact evaluations on aquatic and terrestrial biotic resources, soil and hydrologic resources (including water quality), and social and economic characteristics of the Project area of influence. HMV is currently complementing this information with a more detailed evaluation of environmental and socio-economic conditions of the Project areas and with environmental and social impact evaluations of the proposed transmissions lines, the results of which will be used to update the Environmental and Social Management Plan (ESMP) as necessary.
HMV has an established environmental and social management program which includes elements such as: policies and procedures for environment, occupational health and safety, emergency preparedness and response, internal audits and monitoring, assignment of responsibilities and resources, preparation of corrective actions, and community relations.
The implementation of HMV’s environmental and social management at the Project level during the construction phase consists of the application of project-specific ESMPs which address the prevention and control of key environmental impacts identified during the limited environmental and social assessments. The ESMPs include procedures for the management of such construction phase aspects as: soil and stream erosion; excavated spoils management; vegetation removal management; construction site access control; community engagement and information and third party compensation; labor contracting; occupational health and safety; and construction site reinstatement and revegetation.
HMV has a subcontractor control procedure which outlines subcontractor labor and health and safety requirements in the following areas:
- social security payments and documentation;
- payment of salaries;
- occupational health and safety programs;
- health and safety committees;
- occupational health monitoring and medical exams;
- occupational health statistics;
- equipment maintenance program;
- provision of personal protective equipment;
- risk commoditization requirements; and
- safety audits.
HMV will supplement the subcontractor control procedure, requiring contractors to have internal employee policies that outline the rights and responsibilities of employees consistent with HMV’s Internal Employee Policy and especially addressing the definition of the worker-employer relationship and terms of employment; non-discrimination and equal opportunity; and the right to join worker organizations.
Prior to commencing project operations, the company will prepare and implement a management program appropriate to its operations, consistent with the programs already in place for the company’s existing hydroelectric power generation assets in Colombia and according to Colombian and IFC requirements. The operational-phase management program will include procedures for implementation of environmental and social mitigation and monitoring activities applicable to civil works, electro-mechanical components, and substation/transmission line.
HMV is a company experienced in the design, construction and operation of hydroelectric and other infrastructure projects. HMV has developed environmental guidelines and social action policies and is supported by qualified environmental and social management specialists with experience in managing the environmental and social impacts of its projects. During the construction phase, HMV’s Project Coordinator will be responsible for ensuring the implementation of the projects’ ESMP. Compliance of subcontractor’s implementation of the ESMP will be ensured through the bidding documents and legal contracts which will include performance and financial incentives related to the environmental and social aspect of the project. HMV will be responsible for supervising and documenting contractors’ implementation of the ESMP.
Project implementation will be continually supervised and audited by independent Healthy, Safety and Environment (HSE) coordinator or supervisor (Inteventor) who will conduct inspections to evaluate contractor and subcontractor performance on the environmental and social contract requirements of the project. The company, the contractors, and the independent HSE coordinators will meet on a weekly to monthly basis during the construction phase to discuss the results of the evaluation and to modify the implementation program if required to address identified problems.
HMV will implement the training program outlined in its HSE Management Plan. Training requirements applicable to employees of subcontractors will be addressed through the legal agreements. New subcontractors will be required to understand the relevant aspects of the ESMP. Induction activities will include kick-off meetings to be conducted by experienced professionals responsible for HSE matters. During the operational phase of the project, the company will organize internal training on the different HSE standards which conform to the operational phase ESMP.
During the construction phase, an independent HSE coordinator, as identified in the ESMP, will conduct periodic inspections/audits and prepare periodic reports to evaluate compliance with the procedures outlined in the ESMP and HMV’s HSE Manual. During the operational phase, the company will implement the monitoring requirements outlined in the environmental permits, including specific aspects related to water quality and quantity, as well as implement an appropriate internal HSE audit program to be outlined in a project-specific operational phase EMP. The results of EMP monitoring activities will be communicated site managers, regional managers, and corporate senior management.
- PS:2 Labor and Working Conditions
HMV has an Internal Labor Policy which defines the employer and employee roles and responsibilities and defines the rights of the worker in compliance with Colombian labor law. HMV has a subcontractor control procedure which outlines subcontractor labor and health and safety requirements in the following areas:
- social security payments and documentation;
- payment of salaries;
- occupational health and safety programs;
- health and safety committees;
- occupational health monitoring and medical exams;
- occupational health statistics;
- equipment maintenance program;
- provision of personal protective equipment;
- risk communication requirements;
- safety audits; and
- grievance mechanism.
HMV will supplement the subcontractor control procedure, requiring contractors to have internal employee policies that outline the rights and responsibilities of employees consistent with HMV’s Internal Employee Policy and especially addressing the definition of the worker-employer relationship and terms of employment; non-discrimination and equal opportunity; and the right to join worker organizations.
HMV employees’ rights to freedom of association are clearly identified in HMV’s Internal Labor Policy (Reglamento Interno de Trabajo (RIT)) which indicates that the company will not interfere with employees’ efforts or activities. The company will supplement the subcontractor control procedure to ensure that construction contractors provide the same rights to the project workforce.
HMV’s RIT prohibits the discrimination of employees or potential employees based on such characteristics as race, religion, marital status, number of children, HIV status, or in the case of female candidates, pregnancy status. The company will supplement the subcontractor control procedure to ensure that construction contractors provide the same rights to the Project workforce.
HMV’s Internal Labor Policy (Reglamento Interno de Trabajo (RIT)) prohibits the hiring of persons with less than 18 years of age for work activities considered to be hazardous, consistent with Colombian labor law. Colombia law allows for hiring of persons 14 years of age and older as apprentices as long as they are enrolled in a specialized technical institute as established by law. The company will supplement the subcontractor control procedure to ensure that contractor hiring requirements comply with Colombian law.
Occupational Health and Safety:
HMV’s occupational health and safety program is primarily focused on the employees of the construction subcontractors who may be exposed to most significant occupational health and safety hazards. HMV’s Health, Safety, and Environment Manual includes a set of operating objectives based on the identification and quantification of workplace risks coupled with applicable legal and other requirements. To prevent workplace accidents and promote the health of its employees and subcontractors, HMV further has a set of documented procedures which address the continuous identification of dangerous conditions, evaluation of associated risks, and implementation of control measures. HMV will require that contractors train employees in understanding workplace risks and their prevention and control, including the use of personal protective equipment (PPE), hazardous materials handling, and emergency response. Construction phase activities will be routinely monitored, inspected, and audited by HMV. Incidents and accidents will be investigated according to a documented procedure so that steps can be taken to prevent reoccurrence. According to the ESMP, contractors will provide workers with bottled drinking water from commercial sources.
- PS3: Pollution Prevention and Abatement
During the project construction phase, HMV will implement project specific aspects of the ESMP which include procedures to prevent and control the following aspects:
Sedimentation of surface drainage networks and waterways due to soil erosion – HMV and the contractors will implement procedures to minimize soil exposed due to vegetation removal and soil movement activities, using silt screens and other methods to reduce soil runoff and sediment generation and reinstating disturbed areas with natural, locally available vegetation as soon as practicable.
Transport and disposal of excavated soil and rock materials - Negative impacts from the transport and disposal of excavated soil and rock materials will be prevented or minimized by the application of appropriate procedures such as prohibiting their disposal into streams and other waterways or within riparian areas; transporting them in properly maintained trucks (to minimize engine emissions and ensure their safe operation in the roadways); covering excavated materials during transport and reducing the transport speed to reduce dust emissions; designing and constructing the soil/rock disposal location with proper sloping so as to minimize surface runoff and subsequent erosion and with surface runoff control systems such as culverts; requiring the selection of soil/rock disposal locations based on a review of alternatives and with the final objective of reinstating the affected area.
Wastewater effluents:
During the construction phase, sanitary and food service effluents from working areas and camps will be treated via a temporary, integrated package treatment system. Treated effluents will be discharged according to local legally permitted conditions while protecting the quality of the receiving water body as described in IFC’s General EHS Guidelines (Section 1.3 – Wastewater and Ambient Water Quality). During the operational phase, sanitary wastewater will be discharged and treated via properly designed and maintained septic systems.
Non-hazardous solid waste from construction and operational activities (including waste wood from construction and vegetation removal, metal, concrete, and food service wastes) will be segregated for recycling or, if non-recyclable, disposed of in legally authorized municipal solid waste disposal sites. Hazardous wastes during construction and operational activities will be managed by licensed transport contractors and treated or disposed of in licensed facilities.
HMV and its subcontractors will follow the project ESMP procedures for the management of hazardous materials such as fuels, lubricating oils, paints and other limited quantities of hazardous materials that may be used during the construction phase. Procedures include storage in individualized containers designed for the materials stored, protected from the elements and so as to prevent accidental releases to soil and groundwater (including use of portable fueling storage tanks with secondary containment in construction areas and providing the necessary materials and training to respond to accidental release of fuels or lubricating/hydraulic oils.
HMV’s HSE Plan includes a detailed procedure for emergency preparedness and response which will be adapted to the specific Project conditions during the construction and operational phases.
During an average hydrologic year, the Project is expected to result in the avoidance of 21,100 tons per year of CO2 emissions from Caruquia and 22,545 tons per year from Guanaquitas. The company will evaluate potential carbon finance opportunities following confirmation of the estimated CO2 emissions off-set.
- PS:4 Community Health, Safety and Security
During the construction phase, the principal risk to health and safety of the community will be limited to traffic and pedestrian safety from the transport of construction materials, equipment, and workers to and from the construction sites and potential for structural damage to local housing located adjacent to transport routes. HMV has evaluated potential impacts from transport activities and will perform limited access route improvements to ensure the safety of access of transport equipment to the project sites. HMV will also prepare and implement a driver safety program requiring transport equipment operators to adhere to speed limits according to local requirements and consistent with the quality and location of local roads. HMV will communicate potential traffic safety risks to local residents and ensure access to a point of contact to communicate concerns and grievances. The project will not include the construction of labor camps. Workers will originate or be housed in space available in urban centers such as Santa Rosa de Osos or even the City of Medellin and HMV will provide daily transport from these population centers and appropriate amenities/facilities during work hours.
Each of the project’s facilities will consist of an intake diversion structure together with a desilting structure, a covered concrete channel (1.2 km long for Caruquia and 2 km long for Guanaquitas), a fiberglass penstock (575m long for Caruquia and 505m long for Guanaquitas), a power house and access roads. Construction of both Project facilities will occur in a rural area primarily used for cattle grazing. The diversion structures will be protected from public access with warning signs and fencing as feasible to discourage and prevent unauthorized access. The concrete channels will covered for almost their entire lengths and will therefore not pose a risk to safety of people or livestock. Civil works will be designed and constructed according to good international practice to address potential risks associated with natural hazards such as floods and seismic activities, as identified in the project feasibility studies. The intake structures will be designed to withstand a 100-year flood event while the power houses will be designed to withstand a 500-year flood event.
Possible risks to downstream users of the river or a passerby at both facilities may include the discharge of water in the tailrace during normal or emergency events. This will be handled by warning signs and access control (fencing) to prevent access into high risk areas. None of the project locations are high-risk due to the rural nature and low population densities; as intake and other structures are small, there is no need for expert review of the designs and emergency provisions beyond the company''s designers and the local regulator''s review. The company will prepare emergency preparedness and response plans; these are expected to be straightforward. Power plant operating staff will likely provide any needed security as no significant security risks are reported in the region of the proposed project facilities.
- PS6: Biodiversity Conservation and Sustainable Natural Resource Management
The project facility setting consists primarily of grazing land with a small percentage of secondary growth forest. Preliminary evaluation of the forest resources indicates that the Project affected areas do not include critical habitats or protected areas. A more detailed biotic survey of the project area will be performed to confirm the results of the preliminary assessment.
The construction of the Caruquia facility (including access roads, canal, and penstock) requires an area of 4.32 ha, 1.54 ha of which are forested while development of the Guanaquitas site will require an area of 6.47 ha, with approximately 2.5 ha of forest cover. The company has developed a forest resource management plan, as required by the Forest Resource Use permit, which will include a 1 to 1 replacement of removed specimens as well as protection of certain oak species (Quercus humboldtii) whose removal is prohibited under Colombian law. Location studies for the transmission line are currently underway and the route is expected to be similar in context to the hydroelectric facilities.
A baseline assessment of hydrologic resources and aquatic ecology was conducted to evaluate potential impacts from the project and to help establish the minimum ecological flow. The assessment indicates that the Guadalupe River is home to several species of aquatic plants, micro-invertebrates, and fish species although none are threatened or endangered and their migration patterns are considered to be localized. Other factors considered in the establishment of the ecology flow included: competing stream water uses; length of the stream subject to the reduction in flow; physical, chemical, and biological properties of the water and potential impacts to water quality from reduced flows; fisheries and fluvial transport potential; and landscape modification. Based on assessment results, a minimum ecological flow was established based on the observed average monthly flow regime. The project facilities will be designed, built and operated to meet the calculated minimum ecological flow which varies depending on the month of the year between approximately 3% of the multiannual mean stream flow for the driest month (February) to approximately 12% of the multiannual mean flow for the rainiest month (September). These values were evaluated and approved by the Regional Environmental Corporation, the regional environmental protection agency.
