Derba Midroc has presented plans to address the environmental and social impacts to ensure that the project will, upon implementation of the specific agreed mitigation measures, comply with Ethiopian environmental laws and regulations, IFC’s Policy and Performance Standards for Social and Environmental Sustainability and IFC’s applicable Environmental, Health and Safety Guidelines. The information about how these potential impacts will be addressed by the project is summarized in the paragraphs that follow.
- PS1: Social and Environmental Assessment and Management Systems
Derba Midroc is a new company and does therefore not currently have a fully developed Environmental and Social Management System (ESMS). The company has in its initial planning phase relied on experienced international consultants, and these consultants have prepared the needed planning and documentation to begin the project construction in accordance with good international practice. During the implementation period Derba Midroc will continue to rely on the contracted expertise, while building up its own organizational capacity.
The ESMS work carried out to date has been of high quality and has resulted in a good understanding of the basic risks and mitigation measures needed for a project of this size and complexity. This includes the development of a full Environmental and Social Impact Assessment (ESIA), an Environmental and Social Management Plan (ESMP), and a Resettlement Action Plan (RAP). These plans have been developed in consultation with a substantial number of project affected people. These plans are summarized in the following sections, according to their relevance for the specific Performance Standards.
DMC will, in accordance with the ESMP, establish an ESMS to ensure ongoing compliance with the environmental, health and safety and social measures contained in the ESMP and to meet Ethiopian and lender requirements as the project develops further. DMC will also prepare quarry reclamation plans, in accordance with IFC Environmental, Health and Safety guidelines, for new quarries (limestone, clay, basalt, gypsum, and pumice) before operations commence. IFC and the other international lenders will require that Derba Midroc’s internal organization be established to comply with the principle of good ESMS practices as reflected in ISO and OHSAS norms. A monitoring plan to ensure these commitments are fulfilled in due time will be part of the loan documentation.
- PS2: Labor and Working Conditions
DMC is developing a greenfield project and currently employs mostly senior employees as well as some Chinese contractors. Ethiopian labor laws are relatively strong and no inconsistencies were identified in relation to this Performance Standard at this early project development stage. DMC has agreed to incorporate the requirements of PS2 into its Human Resources Department once established. A monitoring plan to ensure these commitments are fulfilled in due time will be part of the loan documentation.
- PS3: Pollution Prevention and Abatement
The proposed plant is designed according to Best Practice (State-of-the-Art principles) with low energy consumption, good emission controls with continuous monitoring of key pollutant emissions (particulate, nitrogen oxides, and Sulfur dioxide), zero discharge of waste water, and no solid or hazardous production waste, except for broken cement bags, canteen, office and laboratory waste, and maintenance wastes (used refractory bricks, lubricants, etc).
The energy efficiency of the kiln operation will, despite a location approximately 2,400 meters above sea level, result in a highly efficient performance at 745 kcal/kg clinker. Furthermore pumice, a volcanic material found locally, will be used to lower the requirement of clinker in the final cement. With 70% of the cement being blended cement (67% clinker and the balance additives) and the remaining 30% being Portland cement (95% clinker and 5% additives); the final CO2 emissions from a production of up to 2.46 million tons of cement per year will be 1.51 million tons CO2. This is equivalent to 614 kg CO2 per tons of cement on average. The fuel source will initially be coal, as no other reliable fuel source is available. Later it might be possible to consider alternative fuels based on agricultural waste products, but these sources are not available at this time.
Particulate emissions will be controlled at the quarrying sites and in the general material handling systems by designs requiring minimal material drops during handling, fully enclosed conveying systems with bag filters installed at all transfer points. Water based dust suppression will be used where evacuation and filtration systems are not practical, such as crusher feeding chute and road transport within the quarry operations. At the cement plant all operations will be fully equipped with particulate emission control systems. These systems will be based on bag filters and recycling of the captured materials to the feed stock for the kiln. All filters will be designed for maximum emissions of 25 mg particulate/Nm3. This is well within the IFC guidelines of 30 mg particulate/Nm3 and the local requirements.
Sulfur dioxide emissions will be low, as the alkaline conditions in the kiln will result in the absorption of the majority of the sulfur entering the systems either through the raw materials or the fuel. The sulfur dioxide emissions will be kept below the local requirements and the IFC guidelines value of 400 mg/Nm3.
Formation of nitrogen oxides is caused by fuel burning at high temperatures in the kiln. To minimize the formation of nitrogen oxides the kiln will use advanced burning principles, including the usage of low-NOx burners, which by controlling the flame shape is able to ensure a relative low core flame temperature. By applying these techniques the NOx emissions will be kept below the 600 mg/Nm3, as stipulated in the IFC guidelines.
A sewage treatment plant will be constructed to cater for the waste water produced by the plant and the housing colony to be established to house foreign construction workers and later the senior management of DMC and other staffers not originally from the project area. This sewage treatment plant will treat the waste water to comply with IFC’s guidelines, and the water will thereafter be used for greenbelt irrigation. No waste water is foreseen to be discharged from the plant.
The solid and hazardous waste can either be sold (used refractory bricks) or handled by authorized waste handlers. It is also possible that the plant, after due approval procedure will be able to use its spent lubricants in the fuel cycle of the kiln. Ordinary domestic waste (including broken cement bags) will be disposed in approved local landfill operations based on agreement with the local authorities.
Ambient air has been intensively monitored during the ESIA preparation period, and Derba Midroc will carry out a full year monitoring to support these preliminary data. Both ambient air and local rivers fully comply with WHO standards and local Ethiopian regulations. This compliance will not be compromised due to the proposed project.
- PS4: Community Health, Safety and Security
The appropriate emission and discharge controls at the new facilities will ensure that no wastewater will leave the premises and the ambient air quality will remain well within the national and WHO limits. Transport of limestone and other mined raw materials from the valley will be carried out via fully enclosed conveyor belt systems. Hereby heavy road transport between the quarries in the valley and the processing plant has been eliminated.
To limit the community impacts of the transport of the final product (cement) Derba Midroc will construct of a new road from Derba to the plant site and upgrade, broaden, and hardtop the existing road from Derba to Chancho. Nevertheless, the trucking of construction materials, raw materials, and finished product as well as key inputs, such as coal, is expected to lead to significant increases in road traffic. This traffic increase will pose a safety risk to local people, especially the herders who utilize or cross the road network for moving their livestock. DMC has agreed to address this risk by means of community and driver education programs in conjunction with the local authorities in affected areas.
Construction of the steep mountainous access road between the plant and quarry sites – involving a vertical drop of roughly 700-800 m – poses a safety risk of falling rocks to the households living at the foot of the plateau edge. To mitigate this risk, DMC is negotiating the temporary relocation of affected households during the construction process.
Finally, the influx of outsiders, including truck drivers, Chinese contractors, and job-seekers, could lead to the spread of sexually transmitted diseases, such as HIV-AIDS, into local communities. To reduce and actively manage this risk, DMC has agreed to undertake health awareness and education initiatives to:
- sensitize their workforce in relation to disease prevention and treatment; and
- provide adequate access to health facilities.
- PS5: Land Acquisition and Involuntary Resettlement
Land either has been or will be acquired for the plant area, the various quarrying areas, several key access roads, and linear facilities, such as the conveyor belt, the water pipeline, and (possibly) the power line route. Land acquisition has been completed for two access roads, plant site, and water pipeline. Land acquisition for the conveyor belt, quarry areas, power line, and the road linking the plant to the quarry area on the valley floor is underway. The land acquisition and compensation process has been undertaken by Ethiopian Government agencies, as required by national law. Compensation had by late 2007 been paid out to 354 landowners who have lost part of their landholdings and 74 house owners who have lost their houses (some on a temporary basis due to construction activities). DMC has compiled a RAP (attached) which addresses the land acquisition and compensation process in accordance with IFC’s requirements. An IFC review has found the Ethiopian land acquisition and compensation process to be fair to those whose land and houses have been affected, although additional monitoring and evaluation is required by DMC to comply with IFC’s requirements in this regard.
- PS6: Biodiversity Conservation and Sustainable Natural Resource Management
A detailed ecological study has been carried out in the area and the vegetation composition, abundance, cover, and other relevant ecological information of the area has been collected. The ecological study covers both the plant and quarry areas, and a buffer area of 10 kilometers radius around the plant and mining area. The area is rich in biodiversity and a total of 241 floral species were recorded. Among these five are highly endangered and 10 are of least concern as per Ethiopian statutes. None of the endangered or “of least concern” species were found in the actual plant, quarry, or right-of-way areas, and none will be affected by the project development, as the project will not encroach on any area considered critical for the survival of these species.
With respect to wildlife (fauna) the area is highly impacted by deforestation, agricultural activities, and hunting. There is no record of endangered, threatened or vulnerable species in the area. It is believed that the complete deforestation could be the cause of lacking wildlife migration in the area. Derba Midroc therefore intend to establish forested greenbelts around the quarry operations, and tree planting in rehabilitated quarry areas, to provide hiding grounds for potential returning wildlife.
The following two Performance Standards were, after due screening not found relevant at this time:
- PS7: Indigenous People
The population in the affected area belongs almost entirely to the Oromo ethnic group, with Oromiffa being spoken in the area. The Oromo ethnic group is the largest such group in Ethiopia, comprising more than 30 % of the population. There are many influential Oromo personalities and Government office holders in Ethiopia and as such the Oromo are not considered to be an indigenous people according to IFC’s Performance Standard 7 on Indigenous People.
- PS8: Cultural Heritage
No archaeological remains, which have scientific, cultural, public, economic, ethnic or historic significance were found in the area. A chance-find-protocol will be prepared to ensure appropriate action, should the construction excavations or the future quarry operations reveal any historic remains.
