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Environmental & Social Review Summary
Project Number
29979
Company Name
Allana Potash Corp
Date ESRS Disclosed
Sep 9, 2013
Country
Ethiopia
Region
Africa
Last Updated Date
Dec 1, 2016
Environmental Category
B - Limited
Status
Completed
Previous Events
Approved : Apr 28, 2011
Signed : May 5, 2011
Invested : May 10, 2011
Sector
Miscellaneous and Industrial Ores (Including Magnesite, Fluorite, Sulfur, Soda Ash, Clays, Gypsum, Lime, Peat, Boron, Diatomite, Feldspar, etc.)
Industry
Metals and Mining
Department
Gbl Infrastructure & Natural Resources
Project Description
Allana Potash Corp is a publicly listed Canadian company engaged in the acquisition and development of potash assets and is currently focused on the exploration and development of the Dallol Potash project located in the Danakil Depression in northeastern Ethiopia (“the Project” or “Dallol”).
A total IFC equity investment of up to C$17 million is proposed to support the development of the Project. From this amount, C$10.0 million in equity will initially be used to acquire about 6.25 million common shares (approx. 4.6%) of the Company. The balance will be used to exercise the warrant package attached to the equity investment. IFC’s investment will support the funding of the Company’s budget and work program for the next two years which includes drilling and core sampling, and preparation of a feasibility study integrated with an Environmental and Social Impact Assessment (ESIA), at a total cost of about C$17.8 million. IFC will also support the Company in developing the Project in line with international best practice in environmental and social sustainability.
In line with similar previous investments, this Environmental and Social Review Summary (ESRS) covers Dallol’s activities at the early exploration pre-feasibility and pre-development stage.
A total IFC equity investment of up to C$17 million is proposed to support the development of the Project. From this amount, C$10.0 million in equity will initially be used to acquire about 6.25 million common shares (approx. 4.6%) of the Company. The balance will be used to exercise the warrant package attached to the equity investment. IFC’s investment will support the funding of the Company’s budget and work program for the next two years which includes drilling and core sampling, and preparation of a feasibility study integrated with an Environmental and Social Impact Assessment (ESIA), at a total cost of about C$17.8 million. IFC will also support the Company in developing the Project in line with international best practice in environmental and social sustainability.
In line with similar previous investments, this Environmental and Social Review Summary (ESRS) covers Dallol’s activities at the early exploration pre-feasibility and pre-development stage.
Overview of IFC's Scope of Review
IFC’s review of this project consisted of an appraisal visit conducted in October 2010 to the exploration site of Allana Potash Corp (“the Company”, or “Allana”), located in the Danakil Depression in the Afar State, North East of Ethiopia to assess the Company’s operations and reviewing environmental, health, safety, and social information submitted by the Company.
A meeting was also held with the community at Berhale. The meeting was requested by IFC and arranged by Allana in cooperation with the representative of the Department of Mines & Energy Resources Development for Afar National Regional State. In attendance were IFC representatives, the Afar Region representative of Mines and Energy Resources, Allana representatives, Berhale community leaders and individuals. Community views on mining exploration projects in the area were discussed as well as the overall community situation, development needs and expectations. Two meetings were held in Addis Ababa, with Federal Government Representatives, namely the head of the Mineral Operations Department of the Ministry of Mines and Energy, and the Planning & Program Management Directorate Director for the Ethiopian Roads Authority. The purpose of the meetings was to engage with the relevant authorities at an early stage of the investment and record their views on the project in particular, and understand their respective sector wide views in general.
A meeting was also held with the community at Berhale. The meeting was requested by IFC and arranged by Allana in cooperation with the representative of the Department of Mines & Energy Resources Development for Afar National Regional State. In attendance were IFC representatives, the Afar Region representative of Mines and Energy Resources, Allana representatives, Berhale community leaders and individuals. Community views on mining exploration projects in the area were discussed as well as the overall community situation, development needs and expectations. Two meetings were held in Addis Ababa, with Federal Government Representatives, namely the head of the Mineral Operations Department of the Ministry of Mines and Energy, and the Planning & Program Management Directorate Director for the Ethiopian Roads Authority. The purpose of the meetings was to engage with the relevant authorities at an early stage of the investment and record their views on the project in particular, and understand their respective sector wide views in general.
E & S Project Categorization and Applicable Standard
While all Performance Standards (PSs) are applicable to this investment, IFC’s environmental and social due diligence indicates that the project financed by IFC (exploration and feasibility studies) will have impacts which must be managed in a manner consistent with the following Performance Standards:
PS1: Social and Environmental Assessment and Management Systems
PS2: Labor and Working Conditions
PS3: Pollution Prevention and Abatement
PS4: Community Health, Safety and Security
PS5: Land Acquisition and Involuntary Resettlement
The Project is in its early stage and the only activities are exploration drilling and completion of feasibility studies. Currently it has limited impacts in the sparsely populated areas. Other Performance Standards may become applicable should any exploration sites progress to mine development, any IFC investment in such a development would be assessed as a new project.
The Danakil Depression also known as Dallol Depression, in which Allana’s exploration license is located, is a desert with some areas that are more than 100 meters below sea level. It is one of the lowest elevations globally, created when the earth’s crust collapsed and water flooded in and later evaporated leaving enormous salt flats and salt lakes. With daytime temperatures reaching 55 degrees Celsius in the summer, Dallol is considered one of the hottest places year-round anywhere on earth. Annual rainfall averages from 100 to 200 millimetres with long dry periods. Where it exists, vegetation is mostly confined to drought-resistant plants such as small trees (e.g. species of the dragon tree), shrubs, and grasses. The landscape on most portions of Allana’s license area is a salt flat and is generally desolate with no vegetation growth. Therefore, PS 6 - Biodiversity Conservation and Sustainable Resource Management is not applicable at this stage.
The Danakil Depression today is populated by the Adaemara group of the Afar people, a pastoralist nomadic group, which comprises close-knit clan communities once renowned for their hostility towards outsiders. Most of Afar residing in the Danakil Depression are nomads who herd sheep, goats, cattle, and camels or working on extraction of salt slabs from the salt flats in the Danakil Depression. The Afar constitutes a majority of the population (90%) of the Afar state and enjoys certain level of autonomy according to its status in the federal state of Ethiopia. Other ethnicities which are present in the area include Amhara, Argobba and Tigrayans who constitute majorities in other parts of Ethiopia and are not considered indigenous to the area; therefore, Performance Standard 7 is not applicable to this project.
Whilst there are currently no known sites of archaeological or cultural significance, the Danakil Depression has been home to a number of important fossil discoveries, giving clues to the earliest ancestors of humans including early hominids. A detailed archaeological study will form part of the full ESIA and a chance find procedure will need to be implemented by the Company and its contractors for construction and exploration activities, ESAP item 1. In addition, the local communities in the area customarily bury their dead in stone graves in the deserted areas of the depression, which will need to be mapped in order to avoid disturbance from potential development activities. Thus PS 8 on Cultural Heritage is not applicable at this stage but may apply in the future mine development activities.
IFC’s Environmental Health & Safety (EHS) Guidelines applicable to this investment are:
- General EHS Guidelines, April 2007; and
- Mining EHS Guidelines, December 2007.
PS1: Social and Environmental Assessment and Management Systems
PS2: Labor and Working Conditions
PS3: Pollution Prevention and Abatement
PS4: Community Health, Safety and Security
PS5: Land Acquisition and Involuntary Resettlement
The Project is in its early stage and the only activities are exploration drilling and completion of feasibility studies. Currently it has limited impacts in the sparsely populated areas. Other Performance Standards may become applicable should any exploration sites progress to mine development, any IFC investment in such a development would be assessed as a new project.
The Danakil Depression also known as Dallol Depression, in which Allana’s exploration license is located, is a desert with some areas that are more than 100 meters below sea level. It is one of the lowest elevations globally, created when the earth’s crust collapsed and water flooded in and later evaporated leaving enormous salt flats and salt lakes. With daytime temperatures reaching 55 degrees Celsius in the summer, Dallol is considered one of the hottest places year-round anywhere on earth. Annual rainfall averages from 100 to 200 millimetres with long dry periods. Where it exists, vegetation is mostly confined to drought-resistant plants such as small trees (e.g. species of the dragon tree), shrubs, and grasses. The landscape on most portions of Allana’s license area is a salt flat and is generally desolate with no vegetation growth. Therefore, PS 6 - Biodiversity Conservation and Sustainable Resource Management is not applicable at this stage.
The Danakil Depression today is populated by the Adaemara group of the Afar people, a pastoralist nomadic group, which comprises close-knit clan communities once renowned for their hostility towards outsiders. Most of Afar residing in the Danakil Depression are nomads who herd sheep, goats, cattle, and camels or working on extraction of salt slabs from the salt flats in the Danakil Depression. The Afar constitutes a majority of the population (90%) of the Afar state and enjoys certain level of autonomy according to its status in the federal state of Ethiopia. Other ethnicities which are present in the area include Amhara, Argobba and Tigrayans who constitute majorities in other parts of Ethiopia and are not considered indigenous to the area; therefore, Performance Standard 7 is not applicable to this project.
Whilst there are currently no known sites of archaeological or cultural significance, the Danakil Depression has been home to a number of important fossil discoveries, giving clues to the earliest ancestors of humans including early hominids. A detailed archaeological study will form part of the full ESIA and a chance find procedure will need to be implemented by the Company and its contractors for construction and exploration activities, ESAP item 1. In addition, the local communities in the area customarily bury their dead in stone graves in the deserted areas of the depression, which will need to be mapped in order to avoid disturbance from potential development activities. Thus PS 8 on Cultural Heritage is not applicable at this stage but may apply in the future mine development activities.
IFC’s Environmental Health & Safety (EHS) Guidelines applicable to this investment are:
- General EHS Guidelines, April 2007; and
- Mining EHS Guidelines, December 2007.
This is a category B project according to IFC’s Environmental and Social Review Procedure because the Environmental, Health & Safety, and Social (EHSS) impacts of the project are limited, site specific and therefore manageable through implementation of appropriate mitigation measures.
For the most part, the exploration area lies on a salt flat for which no road or drill pad construction is required. The limited access road construction involves roads linking the exploration camp to the salt flat whilst a few drill pads have also been constructed in the mud area lying on the periphery of the salt flat.
The key environmental and social issues associated with the exploration drilling currently ongoing in Dallol are:
- management of exploration activities - specifically rehabilitation of the few drill roads, and drill sites, safe disposal of oils and waste, dust control at the exploration camp, water and effluent management, occupational health and safety – including management of heat exhaustion and dehydration, hazardous materials (e.g. fuel) handling, public safety and emergency preparedness & response,
- potential economic displacement of artisanal salt miners and traders in the salt flats of Danakil Depression during exploration drilling activities;
- project-induced in-migration and influx of migrants and local community members seeking employment at the exploration site,
- potential negative impacts to local communities from the use of groundwater,
- ongoing public disclosure, community engagement and managing community expectations with respect to potential job opportunities.
Any IFC investment in any potential future mining development undertaken by the Company in the Dallol Depression will be assessed as a new project and its categorization would be determined after the necessary due diligence. Even without an additional investment, IFC would require any future mine development to follow the approved ESIA which will be completed as part of IFC’s current finance package, and to develop and implement a robust and auditable Environmental and Social Management System (ESMS) based on the ESIA. In addition, Allana will ensure that the ESIA will be consistent with all other relevant IFC Performance Standards and EHS Guidelines and be publicly available and consulted upon in accordance with IFC’s disclosure policy prior to the start of construction.
It is recognized that the presence of other mining industry players, including a large multi-national, may present risks related to cumulative impacts on the area should the project progress to development. These cumulative impacts will be assessed as part of the ESIA. As the most advanced project in the area the company has the opportunity to develop sustainable and socially responsible practices for resource extraction in the region that would influence other potential players.
To address the above identified issues and meet the requirements of IFC’s Performance Standards, Allana has committed to an Environmental and Social Action Plan (ESAP) covering its exploration activities, feasibility and potential future mine development.
The above issues will also be managed via the Company’s Health Safety and Loss Prevention (HSLP) Policy. The Policy, which incorporates the Standard Operating Procedures Manual, provides a general sustainability framework. Allana will review its HSLP annually to reflect the changes in the project development, and will appoint a full-time EH) officer to strengthen the Policy implementation.
For the most part, the exploration area lies on a salt flat for which no road or drill pad construction is required. The limited access road construction involves roads linking the exploration camp to the salt flat whilst a few drill pads have also been constructed in the mud area lying on the periphery of the salt flat.
The key environmental and social issues associated with the exploration drilling currently ongoing in Dallol are:
- management of exploration activities - specifically rehabilitation of the few drill roads, and drill sites, safe disposal of oils and waste, dust control at the exploration camp, water and effluent management, occupational health and safety – including management of heat exhaustion and dehydration, hazardous materials (e.g. fuel) handling, public safety and emergency preparedness & response,
- potential economic displacement of artisanal salt miners and traders in the salt flats of Danakil Depression during exploration drilling activities;
- project-induced in-migration and influx of migrants and local community members seeking employment at the exploration site,
- potential negative impacts to local communities from the use of groundwater,
- ongoing public disclosure, community engagement and managing community expectations with respect to potential job opportunities.
Any IFC investment in any potential future mining development undertaken by the Company in the Dallol Depression will be assessed as a new project and its categorization would be determined after the necessary due diligence. Even without an additional investment, IFC would require any future mine development to follow the approved ESIA which will be completed as part of IFC’s current finance package, and to develop and implement a robust and auditable Environmental and Social Management System (ESMS) based on the ESIA. In addition, Allana will ensure that the ESIA will be consistent with all other relevant IFC Performance Standards and EHS Guidelines and be publicly available and consulted upon in accordance with IFC’s disclosure policy prior to the start of construction.
It is recognized that the presence of other mining industry players, including a large multi-national, may present risks related to cumulative impacts on the area should the project progress to development. These cumulative impacts will be assessed as part of the ESIA. As the most advanced project in the area the company has the opportunity to develop sustainable and socially responsible practices for resource extraction in the region that would influence other potential players.
To address the above identified issues and meet the requirements of IFC’s Performance Standards, Allana has committed to an Environmental and Social Action Plan (ESAP) covering its exploration activities, feasibility and potential future mine development.
The above issues will also be managed via the Company’s Health Safety and Loss Prevention (HSLP) Policy. The Policy, which incorporates the Standard Operating Procedures Manual, provides a general sustainability framework. Allana will review its HSLP annually to reflect the changes in the project development, and will appoint a full-time EH) officer to strengthen the Policy implementation.
Environmental and Social Mitigation Measures
PS1: Social and Environmental Assessment and Management Systems
Environmental and Social Impact Assessment
Management of risks discussed in this ESRS consists of those associated with exploration as IFC is only financing exploration and feasibility study activities, which have limited environmental and social impacts. Allana commits to meet the IFC Policy and Performance Standards on Social and Environmental Sustainability.
The Company recognizes that maintenance of environmental quality is vital to the Company’s existence, progress, and continued development. The Company will take positive action to protect the safety of its workers, conserve natural resources, and minimize the impact of its activities on the environment through diligent application of appropriate technology and responsible conduct at all stages of exploration, mine development, mining, mineral processing, decommissioning, and reclamation. To this end, the Company has developed in consultation with and for the approval of its Senior Leadership Team (SLT), a HSLP Policy incorporating the Standard Operating Procedures Manual. Allana commits, in its HSLP Policy, to maintain and periodically review the Policy to ensure relevance, high standards, and a significant guide to practical and consistent safety applications. The procedures set out in the Manual are current for the year 2010 only and a new Manual will be issued in April 2011.
To strengthen its HSLP Policy, Allana has developed an environmental policy statement, a social responsibility policy statement, and a health and safety policy statement. These documents were reviewed by IFC and found to comply with the Health, Safety, Environment and Community Policy and Procedures (“HSEC Policy”) document, which IFC normally recommends for exploration projects.
Whilst Allana has not yet instituted any environmental or social baseline studies for the project, they recently commissioned Professor Tenelem Ayenew from Belles Engineering PLC, based out of Addis, to undertake a hydrogeology study for the area, for which findings are yet to be presented. Allana is in the process of ordering a weather station which will be installed on site to collect rainfall data, wind speed and direction, temperature, and humidity. This will form part of the environmental baseline data.
If any of the exploration prospects proceeds to the mining development phase, Allana will submit detailed ESIA documents addressing local regulatory requirements and IFC Performance Standards to IFC for review and approval four months prior to start of construction, ESAP item 2. To ensure the documents comply with IFC Performance Standards, Allana will submit the Terms of Reference (ToR) for the baseline environmental and social studies to IFC for review and comment, action item 3 of the ESAP. The baseline studies will form part of the ESIA development and documentation.
Management and Organization
Responsibility for HSLP matters is shared between Company directors’ whilst Policy development and implementation is currently the responsibility of the exploration Project Manager. Most EHS issues can be managed via the HSLP Policy at the current stage of the Project development, and no reportable E&S incidents have occurred since the start of the exploration. As highlighted above, Allana will strengthen its E&S capacity through appointment of a full-time EHS officer with responsibility for the exploration project, ESAP item 4.
Allana’s management team values a relationship with IFC in carrying out its exploration activities in line with industry good practices for mining sector governance, transparency and sustainability. The team has extensive experience in the resources industry, ranging through project acquisition, exploration, resource definition, mining, mineral processing and financing.
Monitoring
A one off sample of groundwater was collected from the water tank after passing through the water purification system and subjected to a chemical analysis. The results, which were provided to IFC, showed that the water is within WHO drinking water standards. Allana will implement a groundwater monitoring program covering its dedicated borehole and that of the migrant community of Hamadela, as part of the baseline data collection referred to above, and in line with the findings of the hydrogeology study referred to above.
Allana will also start monitoring data collected from the weather station referred to above, once the weather station is installed on site.
In addition, the Company will monitor the implementation of its HSLP Policy in compliance with the Ethiopia regulations and the IFC PSs’.
Reporting
At present, no E&S reporting is required by the Ethiopian government. According to the Mining code, Allana will be required to report every three months in relation to various operational matters once it starts mining.
For the purposes of IFC’s investment, Allana will submit an Annual Environmental & Social Monitoring Report (AMR) to IFC describing its environmental and social performance including incidents and monitoring, as appropriate. The Company will also be reporting regularly, at a minimum on a quarterly basis to the nearby local communities on progress made in drilling out the resource and at a minimum annually, to the local communities on progress made in implementing the Company’s environmental and social action plan, as part of the Stakeholder Engagement Plan (SEP), ESAP item 5.
Influx management
Effective management of project-induced in-migration will become critical for Allana going forward. Mining exploration activities will attract the attention of local community members seeking employment and the area is likely to become a target of project-induced inflow from surrounding areas as well as from the more remote regions of Ethiopia and possibly Eritrea. The early signs of potential project-induced in-migration are already evident in a small village of Hamadela in close proximity to the Company’s base camp, which has expanded with the arrival of migrant laborers seeking employment in the camp.
In order to properly manage the range of issues associated with potential in-migration, Allana will develop an Influx Management Plan as per ESAP item 6 in order to assess the social, environment, health and security aspects of the potential inflow of labor to the nearby communities. A risk analysis assessment and capacity assessment of the receiving communities, mainly the villages of Hamadela and Berhale will be conducted as well as social infrastructure development projects for mitigating negative impacts of the inflow. In developing the Plan, Allana will cooperate and consult with the local community leaders, administration of the Berhale woreda of Kilber Rasu, detachments of the Ethiopian National Defense stationed in the vicinity of Danakil Depression as well as with other mineral license holders in the area.
PS2: Labor and Working Conditions
Due to the nature of the current exploration activities, Allana currently maintains a handful of expatriate staff on the ground and relies heavily on contractors for drilling, equipment maintenance, road construction, camp management and other activities associated with pre-feasibility phase of the project. Contractors manage their labor including health and safety in accordance with their respective policies and operation procedures while complying with the requirements of Allana’s respective requirements. The Allana Project Manager undertakes overall supervision of contractors’ activities and EHS performance.
Health and safety
Allana has developed a Health and Safety Policy and conducts its activities in accordance with the policy and related operating procedures. The main contractors, Meridian Drilling and Tesla-IMC International Limited have their own Health and Safety Policies and the Tesla policy is displayed prominently around the camp. Tesla-IMC and Meridian properly manage the EHS aspects of their operations and provide adequate EHS training, equipment and supervision to its expatriate and locally hired staff. Employees wear the necessary personal protective equipment on drilling sites, seismic sites and in designated areas of the camp.
A Tesla-IMC paramedic is present on the camp to provide medical help and a helicopter is available on a standby contract for emergency evacuation. Tesla-IMC is conducting the seismic survey for Allana which is scheduled to continue until the end of the year after which Allana will need to implement an updated emergency evacuation plan. In preparation, Allana has completed the earthworks for an airstrip to handle a Cessna Caravan light utility and passenger aircraft which will replace the helicopter for emergency evacuations. Allana has registered the airstrip with the Civil Aviation Authority (CAA) and the Afar region, and is awaiting approval.
Employment and labor relations
Allana considers the provision of employment for the local Afar communities and increasing participation of the local communities in its supply chain, as a priority. Lack of skilled people nearby means that local residents are mostly employed in non-skilled roles as support staff on the drilling rigs, construction and maintenance. The Company provides appropriate cash compensation and is considered a preferred employer among the locals. However, Allana experienced some early misunderstandings (since rectified) with the local staff concerning withdrawal of the income tax from their salaries, which the Company is mandated to do according to local regulations.
Working conditions
As Danakil Depression creates a very difficult working environment due to extreme temperatures with a high risk of heat exhaustion and dehydration, working schedules for exploration drilling are adjusted accordingly. In order to maximize work during the relatively cool hours during the hottest months of the year, drilling activities during the day are shortened. Unlimited amounts of drinking water are provided free of charge to all personnel on the camp and delivered for out of camp activities.
Base camp and workers accommodation
Construction of a base camp is currently being completed. It has the necessary amenities and workers accommodation including sleeping quarters, kitchens and canteen, toilets, showers, washing facilities as well as a helipad. Camp management services are provided by a qualified contractor with a base in Mekele, all supplies for the camp and workers are brought in by road from Mekele. The further expansion of the camp will include the increase of the number of toilets and showers and additional separate space for female employees.
Training
On-the-job training for the local workers is provided by Allana and its contractors. Local workers routinely hired for drilling support positions receive the training necessary for the job. In addition, proper EHS awareness training is provided as well as awareness for working in the extreme weather conditions of the Danakil Depression.
PS3: Pollution Prevention and Abatement
Allana’s Dallol exploration camp is still under construction. It is therefore envisaged that all the issues identified below will be brought to compliance by the time the camp construction is completed in mid January 2011.
Solid Waste
Allana generates minimal amounts of waste which is all segregated appropriately. The Company responsibly manages its waste streams and the final disposal methods. The main solid waste includes domestic and sewage. Domestic waste disposal will be improved including plastics, packaging material and cafeteria waste. Allana has been burning all wastes (except batteries which are recycled in Mekele), in dugout pits but will, in future bury such non-hazardous waste in pits, compact the material and cover with soil. There is minimal recycling of waste, especially empty plastic water bottles, due to the sparse population in the area. Attempts by Allana to convince the camp dwellers to drink treated water have not been successful, and a strong preference for bottled water prevailed.
The sewerage system currently uses a combination of a sewage treatment plant connected to septic tanks catering for a maximum of 30 people, mostly senior personnel, and “long drop” toilet facilities catering for the rest of the personnel, mostly junior employees. The sewage plant is currently located in the middle of the camp next to the generators and dry food storage container. The plant will be relocated to the eastern edge of the camp and plans are underway for implementation. The long drop latrines will be closed and sealed off, and the sewage capacity will be increased to cater for the entire camp. It is expected that the number of people will average 50 at the camp, at any given time, after completion of the seismic work which is expected to be complete before the end of the year.
Liquid Waste
Wastewater (domestic) is disposed of by soak away. A vehicle wash-bay is currently under construction. Allana proposes to recycle this wash-bay water, including domestic, into a 20, 000 liter tank and use the water for dust suppression at the camp. Allana agreed with an IFC recommendation not to use sewage effluent for dust suppression especially with elevated ammonia levels as reported by Allana.
Drilling & Drilling Waste
The exploration drilling program is undertaken by Meridian Drilling Limited, a UK based drilling company with field operations in Africa and Eastern Europe. Meridian use two diamond drill rigs and one groundwater drilling rig for Allana’s exploration program. Meridian avoids spillage of used drilling media and lubricants into the surrounding environs through use of sumps. In addition, Meridian uses biodegradable foams and drilling fluids. Used oil from machinery is currently collected in drums and sent back to the supplier, National Oil Company (NOC). A dedicated drilling workshop is also under construction within the exploration camp.
Material from drilling sumps and pad stripping is stockpiled for use in the pad rehabilitation process as part of drill hole closures. As highlighted above, the exploration site lies in a desert and rehabilitation of drilled areas, which is undertaken as soon as the areas are no longer required, merely involves backfilling the sumps.
With the exception of fuel, Allana does not ordinarily handle hazardous or toxic materials at this stage of the operation.
Energy Use
Power for the camp is supplied from a 130KVA generator operated 24 hours a day, 7 days a week. The generator consumes an average of 250 liters of diesel per day. A 180KVA standby Perkins generator is yet to be installed. The Perkins generator is rated to consume an average of 300 liters of diesel per day. In addition to these gensets, Allana use a 4KVA generator with an average fuel consumption of 10 liters a day to run the borehole water pump. In future, and should the project move into development/production, it is anticipated that power will be generated either from diesel fuel generators or from geothermal heated water abundant in the area, or a combination of both. The nearest national grid is located 85km away from site
With seismic activities in full swing and drilling operations taking place at the same time, diesel fuel consumption is estimated to peak at 6000 liters a day. In order for Allana to support this consumption, two fuel tanks with 22000 liters and 17 000 liters capacity are installed on site. The two tanks are currently not enclosed in bund walls. Allana will install the appropriate bund walls as part of the camp construction exercise summarized above, ESAP item 7. Fuel use is however, expected to drop significantly when the seismic activity is completed at the end of the year.
The camp uses a combination of site generated electricity and natural gas for cooking. The gas is supplied in tanks by NOC. Electricity is used at the senior canteen whilst natural gas is used in the junior canteen where the gas tanks are housed outside of the cooking areas. Allana will secure the tanks in appropriately designed steel cage and install cut off switches for the gas supply to the cooking areas, ESAP item 7.
Water Quality and Use
Allana uses 20, 000 liters of water per day and this water is drawn from a borehole located at the Hamadela migrant settlement, approximately 300 meters from the camp. The borehole is connected to the camp by an 80 millimeter pipeline. The borehole is dedicated to Allana use whilst the community has its own dedicated borehole in the same vicinity and fitted with a pump which Allana maintains. The water drawn from the borehole is treated at the camp and stored in two 10, 000 liter plastic tanks. Treatment involves filtration using carbon blocks, and ultraviolet to remove bacteria. The water is used for all domestic needs except drinking. Bottled water is used for drinking.
There is insufficient information currently to determine if adequate water will be available for the project. However, based on a preliminary scoping study produced by the company’s consultants, a total of approximately 45000 liters per minute of water is required for injection water for solution mining and process water in the flotation plant. It is estimated from this scoping exercise that three quarters of this water is will be lost in the evaporation ponds and as bittern.
Preliminary studies indicate the existence of aquifers that could potentially provide adequate water for the project without adversely impacting the small number of camel herders who depend on this underground water. More extensive analysis of the availability of sufficient water will be undertaken during Professor Tenelem Ayenew’s groundwater study referred to above and detailed in ESAP item 8. Similarly, the company has committed to assess the sustainable use of water and availability of water to local communities as part of the ESIA and mitigate potential impacts (if any) on the availability of water for the local communities.
Allana will implement a groundwater monitoring program as described above. The groundwater monitoring program will include both quality and water level fluctuations. The results of this monitoring program will be included in the AMR which will be submitted to IFC.
There are two perennial rivers within 10km of the camp site. One of these rivers (Saba River) could be sampled for quality and flow rate as part of baseline data collection. Additional water samples could be collected from the brine pools or marsh areas, which tend to be temporary. These potential sampling points will be confirmed once the hydrogeology study referred to above is completed.
Air Quality
Due to the nature of the deposit, salt flat, and the proximity of groundwater to the surface (a few centimeters) the drilling operations release minimal dust and as there are no local communities in the vicinity of the drilling dust is not an issue. However, dust was observed to be a nuisance during the site visit within the exploration camp and along the track traversing the local migrant community of Hamadela. As part of the exploration camp construction, Allana will cover the entire ground within the camp with gravel obtained from the surrounding area. In addition, the camp site and the area around Hamadela will be watered down using recycled water as described above. Other emissions are from the drilling rig itself, the small fleet of light support vehicles and seismic equipment.
Emergency Response and Preparedness Plan
As described above and as part of the exploration camp construction completion, Allana will construct bund walls around the fuel tanks, as well as develop an emergency response and preparedness plan for the potential loss/spill of used oil in transit back to NOC in Mekele, ESAP item 9. Allana transport recycled oil in 200 liter drums back to Mekele. This has amounted to two drums since the beginning of the exploration program.
PS4: Community Health, Safety and Security
The closest community, Hamadela village, is a growing village of about 120 households, which is located less than one kilometer from the camp site. Its proximity necessitates measures for dust and noise control, safe movement of heavy equipment and project personnel as in the future will require addressing of health, safety and security aspects of anticipated project-induced in-migration of labor.
Health
According to the feedback from the community, during the meeting at Berhale, abdominal parasites are the most prevalent disease in the area. Child birth related complications were also noted due to the lack of maternity facilities in the area. Though not an issue according to the community, Allana will develop and implement an HIV/AIDs awareness program to ensure protection of both staff and local communities.
Safety
The key risk to community safety is increased vehicular traffic and the potential for accidents involving humans. To minimize risks associated with its vehicular movements, Allana adheres to stipulated speeds of 40 km/hr within the exploration site, and will also ensure that their contractors and/or suppliers follow similar requirements.
Security
The area where Allana operates has a history of a number of security problems in 1990s and early 2000s. The first was a smoldering conflict between the Afar Revolutionary Democratic Unity Front (ARDUF) and government forces. The ARDUF conducted sporadic attacks on government military forces and officials and competed for control of the salt trade. The second was the continued influx of rural Afar, primarily nomads, from Eritrea. These new arrivals claimed to be fleeing the Eritrean government’s recent enforcement of its National Service program and a parallel agenda of disarmament. Despite a lack of external assistance, these refugees were given assistance and shelter due to clan ties between them and the locals. Subsequently there is significant presence of Ethiopian National Defense in the area, with motorized detachments stationed in the vicinity of the project and protective military trenches and other installations in the area.
Kidnapping of foreign tourists has been reported in the past and currently military security escorts accompany tourists in the area. However, based on the reports from Allana, local community leaders, and government representatives in Addis-Ababa, the security situation is currently significantly improved and does not present a risk for companies operating in the area and their personnel.
Allana does not employ security guards. However, Allana has in place a robust Security Management Plan which was drafted by the Tesla-IMC embedded Field Security Advisor for Allana. The Management Plan was recently updated to conform to the Tesla-IMC Seismic crew standards.
The Security Management Plan clearly defines roles and responsibility with regards to security issues. According to the plan, Allana will arrange all security in relation to the project. This will include camp security, military security escorts from/to Mekele and military security escorts during operational activity. Allana also retains liaison with the deployed sovereign force. The plan includes details on the command control, daily coordination of security, emergency response plan, alert phases and a detailed risk assessment matrix.
PS 5: Land Acquisition and Involuntary Resettlement
Allana’s license area is located in a salt flats in the Danakil Depression with no adjacent communities. Therefore, no land acquisition or resettlement is planned or envisioned at this stage of the project. However, an economic displacement of the parts of local communities involved in artisanal salt mining in the salt flats, transportation and trade of salt slabs is possible and likely with the current and future operations of the Company.
Part of the Afar community in the Danakil Depression is traditionally involved in artisanal mining, transportation and trading of salt slabs which are extracted from the salt planes in the Depression. Traditionally salt mining and trading salt constitutes a significant part of the cash-generating activities for the local communities. Extraction of salt slabs is conducted by hand using simple wooden and iron tools. Upon extraction of ready-to-use salt in the form of crude blocks, salt blocks are loaded on camels, mules and donkeys and salt-carrying caravans are formed. These caravans loaded with salt travel to the local communities markets accompanied by the artisanal miners and traders. Reportedly, the salt is traded along the route between the salt extraction sites and larger town of Mekele about 150 km from the salt plates or six day long journey of the caravan, mainly in the market in Berhale. This generates cash income shared between artisanal miners, teams of camel herders, caravan workers, food and shelter providers and salt traders.
Concerns about the impacts of exploration activities on the livelihoods of the part of the community involved in the salt mining and transportation were raised by the local community representatives. In order to assess the impacts of Allana’s activities on this traditional source of livelihoods of the local communities, an assessment of project impacts on artisanal salt mining and trade will be conducted as a separate social impact study within ESIA as per ESAP item 10. A census of salt mining will be conducted and communities and/or community members affected will be identified and the impacts on their livelihoods will be assessed. The findings from this study will be used by Allana for assessing the best ways to compensate the communities for possible impacts on their livelihoods, provide targeted development activities, employment and/or alternative cash generation opportunities to community members. This will be developed as part of preparation of a comprehensive Community Development Plan (CDP) which Allana will prepare based on the findings of social impact assessment and in consultation with the local communities as per ESAP item 11. As a part of this process consultations with individuals and communities involved in artisanal salt trade will be conducted as part of Stakeholder Engagement Strategy (SES) developed as per ESAP item 5.
Environmental and Social Impact Assessment
Management of risks discussed in this ESRS consists of those associated with exploration as IFC is only financing exploration and feasibility study activities, which have limited environmental and social impacts. Allana commits to meet the IFC Policy and Performance Standards on Social and Environmental Sustainability.
The Company recognizes that maintenance of environmental quality is vital to the Company’s existence, progress, and continued development. The Company will take positive action to protect the safety of its workers, conserve natural resources, and minimize the impact of its activities on the environment through diligent application of appropriate technology and responsible conduct at all stages of exploration, mine development, mining, mineral processing, decommissioning, and reclamation. To this end, the Company has developed in consultation with and for the approval of its Senior Leadership Team (SLT), a HSLP Policy incorporating the Standard Operating Procedures Manual. Allana commits, in its HSLP Policy, to maintain and periodically review the Policy to ensure relevance, high standards, and a significant guide to practical and consistent safety applications. The procedures set out in the Manual are current for the year 2010 only and a new Manual will be issued in April 2011.
To strengthen its HSLP Policy, Allana has developed an environmental policy statement, a social responsibility policy statement, and a health and safety policy statement. These documents were reviewed by IFC and found to comply with the Health, Safety, Environment and Community Policy and Procedures (“HSEC Policy”) document, which IFC normally recommends for exploration projects.
Whilst Allana has not yet instituted any environmental or social baseline studies for the project, they recently commissioned Professor Tenelem Ayenew from Belles Engineering PLC, based out of Addis, to undertake a hydrogeology study for the area, for which findings are yet to be presented. Allana is in the process of ordering a weather station which will be installed on site to collect rainfall data, wind speed and direction, temperature, and humidity. This will form part of the environmental baseline data.
If any of the exploration prospects proceeds to the mining development phase, Allana will submit detailed ESIA documents addressing local regulatory requirements and IFC Performance Standards to IFC for review and approval four months prior to start of construction, ESAP item 2. To ensure the documents comply with IFC Performance Standards, Allana will submit the Terms of Reference (ToR) for the baseline environmental and social studies to IFC for review and comment, action item 3 of the ESAP. The baseline studies will form part of the ESIA development and documentation.
Management and Organization
Responsibility for HSLP matters is shared between Company directors’ whilst Policy development and implementation is currently the responsibility of the exploration Project Manager. Most EHS issues can be managed via the HSLP Policy at the current stage of the Project development, and no reportable E&S incidents have occurred since the start of the exploration. As highlighted above, Allana will strengthen its E&S capacity through appointment of a full-time EHS officer with responsibility for the exploration project, ESAP item 4.
Allana’s management team values a relationship with IFC in carrying out its exploration activities in line with industry good practices for mining sector governance, transparency and sustainability. The team has extensive experience in the resources industry, ranging through project acquisition, exploration, resource definition, mining, mineral processing and financing.
Monitoring
A one off sample of groundwater was collected from the water tank after passing through the water purification system and subjected to a chemical analysis. The results, which were provided to IFC, showed that the water is within WHO drinking water standards. Allana will implement a groundwater monitoring program covering its dedicated borehole and that of the migrant community of Hamadela, as part of the baseline data collection referred to above, and in line with the findings of the hydrogeology study referred to above.
Allana will also start monitoring data collected from the weather station referred to above, once the weather station is installed on site.
In addition, the Company will monitor the implementation of its HSLP Policy in compliance with the Ethiopia regulations and the IFC PSs’.
Reporting
At present, no E&S reporting is required by the Ethiopian government. According to the Mining code, Allana will be required to report every three months in relation to various operational matters once it starts mining.
For the purposes of IFC’s investment, Allana will submit an Annual Environmental & Social Monitoring Report (AMR) to IFC describing its environmental and social performance including incidents and monitoring, as appropriate. The Company will also be reporting regularly, at a minimum on a quarterly basis to the nearby local communities on progress made in drilling out the resource and at a minimum annually, to the local communities on progress made in implementing the Company’s environmental and social action plan, as part of the Stakeholder Engagement Plan (SEP), ESAP item 5.
Influx management
Effective management of project-induced in-migration will become critical for Allana going forward. Mining exploration activities will attract the attention of local community members seeking employment and the area is likely to become a target of project-induced inflow from surrounding areas as well as from the more remote regions of Ethiopia and possibly Eritrea. The early signs of potential project-induced in-migration are already evident in a small village of Hamadela in close proximity to the Company’s base camp, which has expanded with the arrival of migrant laborers seeking employment in the camp.
In order to properly manage the range of issues associated with potential in-migration, Allana will develop an Influx Management Plan as per ESAP item 6 in order to assess the social, environment, health and security aspects of the potential inflow of labor to the nearby communities. A risk analysis assessment and capacity assessment of the receiving communities, mainly the villages of Hamadela and Berhale will be conducted as well as social infrastructure development projects for mitigating negative impacts of the inflow. In developing the Plan, Allana will cooperate and consult with the local community leaders, administration of the Berhale woreda of Kilber Rasu, detachments of the Ethiopian National Defense stationed in the vicinity of Danakil Depression as well as with other mineral license holders in the area.
PS2: Labor and Working Conditions
Due to the nature of the current exploration activities, Allana currently maintains a handful of expatriate staff on the ground and relies heavily on contractors for drilling, equipment maintenance, road construction, camp management and other activities associated with pre-feasibility phase of the project. Contractors manage their labor including health and safety in accordance with their respective policies and operation procedures while complying with the requirements of Allana’s respective requirements. The Allana Project Manager undertakes overall supervision of contractors’ activities and EHS performance.
Health and safety
Allana has developed a Health and Safety Policy and conducts its activities in accordance with the policy and related operating procedures. The main contractors, Meridian Drilling and Tesla-IMC International Limited have their own Health and Safety Policies and the Tesla policy is displayed prominently around the camp. Tesla-IMC and Meridian properly manage the EHS aspects of their operations and provide adequate EHS training, equipment and supervision to its expatriate and locally hired staff. Employees wear the necessary personal protective equipment on drilling sites, seismic sites and in designated areas of the camp.
A Tesla-IMC paramedic is present on the camp to provide medical help and a helicopter is available on a standby contract for emergency evacuation. Tesla-IMC is conducting the seismic survey for Allana which is scheduled to continue until the end of the year after which Allana will need to implement an updated emergency evacuation plan. In preparation, Allana has completed the earthworks for an airstrip to handle a Cessna Caravan light utility and passenger aircraft which will replace the helicopter for emergency evacuations. Allana has registered the airstrip with the Civil Aviation Authority (CAA) and the Afar region, and is awaiting approval.
Employment and labor relations
Allana considers the provision of employment for the local Afar communities and increasing participation of the local communities in its supply chain, as a priority. Lack of skilled people nearby means that local residents are mostly employed in non-skilled roles as support staff on the drilling rigs, construction and maintenance. The Company provides appropriate cash compensation and is considered a preferred employer among the locals. However, Allana experienced some early misunderstandings (since rectified) with the local staff concerning withdrawal of the income tax from their salaries, which the Company is mandated to do according to local regulations.
Working conditions
As Danakil Depression creates a very difficult working environment due to extreme temperatures with a high risk of heat exhaustion and dehydration, working schedules for exploration drilling are adjusted accordingly. In order to maximize work during the relatively cool hours during the hottest months of the year, drilling activities during the day are shortened. Unlimited amounts of drinking water are provided free of charge to all personnel on the camp and delivered for out of camp activities.
Base camp and workers accommodation
Construction of a base camp is currently being completed. It has the necessary amenities and workers accommodation including sleeping quarters, kitchens and canteen, toilets, showers, washing facilities as well as a helipad. Camp management services are provided by a qualified contractor with a base in Mekele, all supplies for the camp and workers are brought in by road from Mekele. The further expansion of the camp will include the increase of the number of toilets and showers and additional separate space for female employees.
Training
On-the-job training for the local workers is provided by Allana and its contractors. Local workers routinely hired for drilling support positions receive the training necessary for the job. In addition, proper EHS awareness training is provided as well as awareness for working in the extreme weather conditions of the Danakil Depression.
PS3: Pollution Prevention and Abatement
Allana’s Dallol exploration camp is still under construction. It is therefore envisaged that all the issues identified below will be brought to compliance by the time the camp construction is completed in mid January 2011.
Solid Waste
Allana generates minimal amounts of waste which is all segregated appropriately. The Company responsibly manages its waste streams and the final disposal methods. The main solid waste includes domestic and sewage. Domestic waste disposal will be improved including plastics, packaging material and cafeteria waste. Allana has been burning all wastes (except batteries which are recycled in Mekele), in dugout pits but will, in future bury such non-hazardous waste in pits, compact the material and cover with soil. There is minimal recycling of waste, especially empty plastic water bottles, due to the sparse population in the area. Attempts by Allana to convince the camp dwellers to drink treated water have not been successful, and a strong preference for bottled water prevailed.
The sewerage system currently uses a combination of a sewage treatment plant connected to septic tanks catering for a maximum of 30 people, mostly senior personnel, and “long drop” toilet facilities catering for the rest of the personnel, mostly junior employees. The sewage plant is currently located in the middle of the camp next to the generators and dry food storage container. The plant will be relocated to the eastern edge of the camp and plans are underway for implementation. The long drop latrines will be closed and sealed off, and the sewage capacity will be increased to cater for the entire camp. It is expected that the number of people will average 50 at the camp, at any given time, after completion of the seismic work which is expected to be complete before the end of the year.
Liquid Waste
Wastewater (domestic) is disposed of by soak away. A vehicle wash-bay is currently under construction. Allana proposes to recycle this wash-bay water, including domestic, into a 20, 000 liter tank and use the water for dust suppression at the camp. Allana agreed with an IFC recommendation not to use sewage effluent for dust suppression especially with elevated ammonia levels as reported by Allana.
Drilling & Drilling Waste
The exploration drilling program is undertaken by Meridian Drilling Limited, a UK based drilling company with field operations in Africa and Eastern Europe. Meridian use two diamond drill rigs and one groundwater drilling rig for Allana’s exploration program. Meridian avoids spillage of used drilling media and lubricants into the surrounding environs through use of sumps. In addition, Meridian uses biodegradable foams and drilling fluids. Used oil from machinery is currently collected in drums and sent back to the supplier, National Oil Company (NOC). A dedicated drilling workshop is also under construction within the exploration camp.
Material from drilling sumps and pad stripping is stockpiled for use in the pad rehabilitation process as part of drill hole closures. As highlighted above, the exploration site lies in a desert and rehabilitation of drilled areas, which is undertaken as soon as the areas are no longer required, merely involves backfilling the sumps.
With the exception of fuel, Allana does not ordinarily handle hazardous or toxic materials at this stage of the operation.
Energy Use
Power for the camp is supplied from a 130KVA generator operated 24 hours a day, 7 days a week. The generator consumes an average of 250 liters of diesel per day. A 180KVA standby Perkins generator is yet to be installed. The Perkins generator is rated to consume an average of 300 liters of diesel per day. In addition to these gensets, Allana use a 4KVA generator with an average fuel consumption of 10 liters a day to run the borehole water pump. In future, and should the project move into development/production, it is anticipated that power will be generated either from diesel fuel generators or from geothermal heated water abundant in the area, or a combination of both. The nearest national grid is located 85km away from site
With seismic activities in full swing and drilling operations taking place at the same time, diesel fuel consumption is estimated to peak at 6000 liters a day. In order for Allana to support this consumption, two fuel tanks with 22000 liters and 17 000 liters capacity are installed on site. The two tanks are currently not enclosed in bund walls. Allana will install the appropriate bund walls as part of the camp construction exercise summarized above, ESAP item 7. Fuel use is however, expected to drop significantly when the seismic activity is completed at the end of the year.
The camp uses a combination of site generated electricity and natural gas for cooking. The gas is supplied in tanks by NOC. Electricity is used at the senior canteen whilst natural gas is used in the junior canteen where the gas tanks are housed outside of the cooking areas. Allana will secure the tanks in appropriately designed steel cage and install cut off switches for the gas supply to the cooking areas, ESAP item 7.
Water Quality and Use
Allana uses 20, 000 liters of water per day and this water is drawn from a borehole located at the Hamadela migrant settlement, approximately 300 meters from the camp. The borehole is connected to the camp by an 80 millimeter pipeline. The borehole is dedicated to Allana use whilst the community has its own dedicated borehole in the same vicinity and fitted with a pump which Allana maintains. The water drawn from the borehole is treated at the camp and stored in two 10, 000 liter plastic tanks. Treatment involves filtration using carbon blocks, and ultraviolet to remove bacteria. The water is used for all domestic needs except drinking. Bottled water is used for drinking.
There is insufficient information currently to determine if adequate water will be available for the project. However, based on a preliminary scoping study produced by the company’s consultants, a total of approximately 45000 liters per minute of water is required for injection water for solution mining and process water in the flotation plant. It is estimated from this scoping exercise that three quarters of this water is will be lost in the evaporation ponds and as bittern.
Preliminary studies indicate the existence of aquifers that could potentially provide adequate water for the project without adversely impacting the small number of camel herders who depend on this underground water. More extensive analysis of the availability of sufficient water will be undertaken during Professor Tenelem Ayenew’s groundwater study referred to above and detailed in ESAP item 8. Similarly, the company has committed to assess the sustainable use of water and availability of water to local communities as part of the ESIA and mitigate potential impacts (if any) on the availability of water for the local communities.
Allana will implement a groundwater monitoring program as described above. The groundwater monitoring program will include both quality and water level fluctuations. The results of this monitoring program will be included in the AMR which will be submitted to IFC.
There are two perennial rivers within 10km of the camp site. One of these rivers (Saba River) could be sampled for quality and flow rate as part of baseline data collection. Additional water samples could be collected from the brine pools or marsh areas, which tend to be temporary. These potential sampling points will be confirmed once the hydrogeology study referred to above is completed.
Air Quality
Due to the nature of the deposit, salt flat, and the proximity of groundwater to the surface (a few centimeters) the drilling operations release minimal dust and as there are no local communities in the vicinity of the drilling dust is not an issue. However, dust was observed to be a nuisance during the site visit within the exploration camp and along the track traversing the local migrant community of Hamadela. As part of the exploration camp construction, Allana will cover the entire ground within the camp with gravel obtained from the surrounding area. In addition, the camp site and the area around Hamadela will be watered down using recycled water as described above. Other emissions are from the drilling rig itself, the small fleet of light support vehicles and seismic equipment.
Emergency Response and Preparedness Plan
As described above and as part of the exploration camp construction completion, Allana will construct bund walls around the fuel tanks, as well as develop an emergency response and preparedness plan for the potential loss/spill of used oil in transit back to NOC in Mekele, ESAP item 9. Allana transport recycled oil in 200 liter drums back to Mekele. This has amounted to two drums since the beginning of the exploration program.
PS4: Community Health, Safety and Security
The closest community, Hamadela village, is a growing village of about 120 households, which is located less than one kilometer from the camp site. Its proximity necessitates measures for dust and noise control, safe movement of heavy equipment and project personnel as in the future will require addressing of health, safety and security aspects of anticipated project-induced in-migration of labor.
Health
According to the feedback from the community, during the meeting at Berhale, abdominal parasites are the most prevalent disease in the area. Child birth related complications were also noted due to the lack of maternity facilities in the area. Though not an issue according to the community, Allana will develop and implement an HIV/AIDs awareness program to ensure protection of both staff and local communities.
Safety
The key risk to community safety is increased vehicular traffic and the potential for accidents involving humans. To minimize risks associated with its vehicular movements, Allana adheres to stipulated speeds of 40 km/hr within the exploration site, and will also ensure that their contractors and/or suppliers follow similar requirements.
Security
The area where Allana operates has a history of a number of security problems in 1990s and early 2000s. The first was a smoldering conflict between the Afar Revolutionary Democratic Unity Front (ARDUF) and government forces. The ARDUF conducted sporadic attacks on government military forces and officials and competed for control of the salt trade. The second was the continued influx of rural Afar, primarily nomads, from Eritrea. These new arrivals claimed to be fleeing the Eritrean government’s recent enforcement of its National Service program and a parallel agenda of disarmament. Despite a lack of external assistance, these refugees were given assistance and shelter due to clan ties between them and the locals. Subsequently there is significant presence of Ethiopian National Defense in the area, with motorized detachments stationed in the vicinity of the project and protective military trenches and other installations in the area.
Kidnapping of foreign tourists has been reported in the past and currently military security escorts accompany tourists in the area. However, based on the reports from Allana, local community leaders, and government representatives in Addis-Ababa, the security situation is currently significantly improved and does not present a risk for companies operating in the area and their personnel.
Allana does not employ security guards. However, Allana has in place a robust Security Management Plan which was drafted by the Tesla-IMC embedded Field Security Advisor for Allana. The Management Plan was recently updated to conform to the Tesla-IMC Seismic crew standards.
The Security Management Plan clearly defines roles and responsibility with regards to security issues. According to the plan, Allana will arrange all security in relation to the project. This will include camp security, military security escorts from/to Mekele and military security escorts during operational activity. Allana also retains liaison with the deployed sovereign force. The plan includes details on the command control, daily coordination of security, emergency response plan, alert phases and a detailed risk assessment matrix.
PS 5: Land Acquisition and Involuntary Resettlement
Allana’s license area is located in a salt flats in the Danakil Depression with no adjacent communities. Therefore, no land acquisition or resettlement is planned or envisioned at this stage of the project. However, an economic displacement of the parts of local communities involved in artisanal salt mining in the salt flats, transportation and trade of salt slabs is possible and likely with the current and future operations of the Company.
Part of the Afar community in the Danakil Depression is traditionally involved in artisanal mining, transportation and trading of salt slabs which are extracted from the salt planes in the Depression. Traditionally salt mining and trading salt constitutes a significant part of the cash-generating activities for the local communities. Extraction of salt slabs is conducted by hand using simple wooden and iron tools. Upon extraction of ready-to-use salt in the form of crude blocks, salt blocks are loaded on camels, mules and donkeys and salt-carrying caravans are formed. These caravans loaded with salt travel to the local communities markets accompanied by the artisanal miners and traders. Reportedly, the salt is traded along the route between the salt extraction sites and larger town of Mekele about 150 km from the salt plates or six day long journey of the caravan, mainly in the market in Berhale. This generates cash income shared between artisanal miners, teams of camel herders, caravan workers, food and shelter providers and salt traders.
Concerns about the impacts of exploration activities on the livelihoods of the part of the community involved in the salt mining and transportation were raised by the local community representatives. In order to assess the impacts of Allana’s activities on this traditional source of livelihoods of the local communities, an assessment of project impacts on artisanal salt mining and trade will be conducted as a separate social impact study within ESIA as per ESAP item 10. A census of salt mining will be conducted and communities and/or community members affected will be identified and the impacts on their livelihoods will be assessed. The findings from this study will be used by Allana for assessing the best ways to compensate the communities for possible impacts on their livelihoods, provide targeted development activities, employment and/or alternative cash generation opportunities to community members. This will be developed as part of preparation of a comprehensive Community Development Plan (CDP) which Allana will prepare based on the findings of social impact assessment and in consultation with the local communities as per ESAP item 11. As a part of this process consultations with individuals and communities involved in artisanal salt trade will be conducted as part of Stakeholder Engagement Strategy (SES) developed as per ESAP item 5.
Stakeholder Engagement
Allana has developed a Social Responsibility Policy which outlines the main principles of engagement with affected communities and the Company’s contribution to local economic development. Allana is actively engaged in consultations with local communities in the Dallol Depression and other stakeholders on day to day project operations and future project plans. The Company employs a Community Liaison Officer (CLO), who resides in the village of Hamadela, the closest settlement to the base camp. The CLO is in constant communication with community members, receives grievances and facilitates information flows between the Company and local community and is involved in employment recommendations from among the local community members. In the village of Berhale, a center of the Berhale woreda, Allana is in ongoing contact with the elected representatives and elders of the woreda. Allana also employs a liaison officer in Semera, the center of the Afar region, who is engaged with the administrative bodies of the Afar region on project issues and development plan. In addition, the Company is in ongoing contact with representatives of Ethiopian government in Addis-Ababa.
The local community in Berhale and Hamadela have high expectations of the Company’s development impacts on the local communities. During the above mentioned meeting with IFC representatives, community leaders emphasized inadequate public services, notably education and health services as well as the lack of employment opportunities and low incomes from agricultural activities in the area. Allana will need to manage community expectations from its project and coordinate carefully its targeted development contributions to the region with local stakeholders. During the development of the ESIA the Company will conduct public consultations in order to incorporate the community’s feedback and concerns into future project design and activities. The Company will develop and update as needed its Stakeholder Engagement Strategy (SES) and Community Development Plan (CDP) as per ESAP items 5 and 11 respectively. It will also engage local communities in the preparation of Social Impacts Assessment (SIA) and the Influx Management Plan (IMP) as per ESAP items 10 and 6.
The local community in Berhale and Hamadela have high expectations of the Company’s development impacts on the local communities. During the above mentioned meeting with IFC representatives, community leaders emphasized inadequate public services, notably education and health services as well as the lack of employment opportunities and low incomes from agricultural activities in the area. Allana will need to manage community expectations from its project and coordinate carefully its targeted development contributions to the region with local stakeholders. During the development of the ESIA the Company will conduct public consultations in order to incorporate the community’s feedback and concerns into future project design and activities. The Company will develop and update as needed its Stakeholder Engagement Strategy (SES) and Community Development Plan (CDP) as per ESAP items 5 and 11 respectively. It will also engage local communities in the preparation of Social Impacts Assessment (SIA) and the Influx Management Plan (IMP) as per ESAP items 10 and 6.
The following documents will be disclosed locally at the locations listed below:
- Summary of Proposed Investment (SPI)
- Environment and Social Action Plan (ESAP)
Allana Potash Corp
65 Queen Street West
Suite 805, P.O. Box 75
Toronto, ON M5H 2M5
Canada.
Tel: 416-861-2267
Email: info@allanapotash.com
Allana Potash Corp
(Ethio Gibe Canada Mining)
6th Floor, Robel Plaza
Sub City: Bole
Kabele: 05
Addis Ababa
Ethiopia
Tel: +251 116 630 870
Inquiries and comments about the project can be made through the contact details provided below.
Jason Wilkinson
Project Manager
251 912 92 5708 (mobile)
jason@allanapotash.com; jason.b.wilikinson@gmail.com
Yonas Bekele
Senior Geologist
251 911 16 0900 (mobile)
Yonas@allanapotash.com; yonasbekele@yahoo.com
Yerom Derbe
Secretary
251 911 662 6766 (office)
Yeromallanapotash.com.
- Summary of Proposed Investment (SPI)
- Environment and Social Action Plan (ESAP)
Allana Potash Corp
65 Queen Street West
Suite 805, P.O. Box 75
Toronto, ON M5H 2M5
Canada.
Tel: 416-861-2267
Email: info@allanapotash.com
Allana Potash Corp
(Ethio Gibe Canada Mining)
6th Floor, Robel Plaza
Sub City: Bole
Kabele: 05
Addis Ababa
Ethiopia
Tel: +251 116 630 870
Inquiries and comments about the project can be made through the contact details provided below.
Jason Wilkinson
Project Manager
251 912 92 5708 (mobile)
jason@allanapotash.com; jason.b.wilikinson@gmail.com
Yonas Bekele
Senior Geologist
251 911 16 0900 (mobile)
Yonas@allanapotash.com; yonasbekele@yahoo.com
Yerom Derbe
Secretary
251 911 662 6766 (office)
Yeromallanapotash.com.
**Information on IFC's Policy and Performance Standards on Environmental and Social Sustainability can be found at www.ifc.org/sustainability
IFC supports its clients in addressing environmental and social issues arising from their business activities by requiring its real sector clients to set up and administer appropriate grievance mechanisms and/or procedures to address complaints from Affected Communities in relation to environmental and social issues arising from IFC's clients' business activities. Since 2012, IFC's Financial Intermediary clients applying the Performance Standards are required to develop External Communications Mechanisms to receive and review inquiries or complaints from any interested party regarding the E&S risks and impacts of their operations.
For IFC projects that are active or under consideration, individual(s), or their authorized representative(s), who allege they have been or will be adversely affected by E&S risks or impacts arising from IFC's clients' business activities, may submit a complaint to IFC directly for consideration. When receiving an E&S complaint, IFC engages with complainants and works with its clients to find solutions to E&S concerns as quickly and efficiently as possible.
Complaints can be submitted to IFC online at www.ifc.org/escomplaints or by email to EScomplaints@ifc.org.
IFC complaint response is separate from and complementary to IFC’s clients’ project level grievance mechanisms and IFC’s Independent Accountability Mechanism (CAO). Lodging a complaint directly with IFC does not, at any time, restrict access to CAO.
Affected communities have unrestricted access to the Compliance Advisor Ombudsman (CAO), the independent accountability mechanism for IFC and MIGA. CAO facilitates the resolution of complaints related to IFC and MIGA projects and sub-projects, undertakes reviews of IFC’s and MIGA’s environmental and social compliance, fosters public accountability for their commitments, and enhances the environmental and social performance of IFC and MIGA.
Independent of IFC and MIGA management and reporting directly to the IFC and MIGA Boards of Executive Directors, CAO helps resolve issues raised about the environmental and social impacts of projects through a neutral, collaborative, problem-solving approach via its Dispute Resolution function. It also reviews IFC’s and MIGA’s compliance with environmental and social policies, assesses related harm, and recommends remedial actions through its Compliance function. Additionally, CAO provides advice to IFC, MIGA, and their Boards to enhance environmental and social sustainability performance and minimize the risk of harm.
Complaints may relate to environmental and social harm regarding any aspect of the planning, implementation, or impact of a project or sub-project, and can be made by any individual, group, community, entity, or other party affected or likely to be affected by the environmental or social impacts of an IFC- or MIGA-financed business activity.
Complaints can be submitted by any of the following methods:
CAO receives and addresses complaints in accordance with the CAO Policy, which can be accessed at: https://www.cao-ombudsman.org/policies-guidelines.
IFC supports its clients in addressing environmental and social issues arising from their business activities by requiring its real sector clients to set up and administer appropriate grievance mechanisms and/or procedures to address complaints from Affected Communities in relation to environmental and social issues arising from IFC's clients' business activities. Since 2012, IFC's Financial Intermediary clients applying the Performance Standards are required to develop External Communications Mechanisms to receive and review inquiries or complaints from any interested party regarding the E&S risks and impacts of their operations.
For IFC projects that are active or under consideration, individual(s), or their authorized representative(s), who allege they have been or will be adversely affected by E&S risks or impacts arising from IFC's clients' business activities, may submit a complaint to IFC directly for consideration. When receiving an E&S complaint, IFC engages with complainants and works with its clients to find solutions to E&S concerns as quickly and efficiently as possible.
Complaints can be submitted to IFC online at www.ifc.org/escomplaints or by email to EScomplaints@ifc.org.
IFC complaint response is separate from and complementary to IFC’s clients’ project level grievance mechanisms and IFC’s Independent Accountability Mechanism (CAO). Lodging a complaint directly with IFC does not, at any time, restrict access to CAO.
Affected communities have unrestricted access to the Compliance Advisor Ombudsman (CAO), the independent accountability mechanism for IFC and MIGA. CAO facilitates the resolution of complaints related to IFC and MIGA projects and sub-projects, undertakes reviews of IFC’s and MIGA’s environmental and social compliance, fosters public accountability for their commitments, and enhances the environmental and social performance of IFC and MIGA.
Independent of IFC and MIGA management and reporting directly to the IFC and MIGA Boards of Executive Directors, CAO helps resolve issues raised about the environmental and social impacts of projects through a neutral, collaborative, problem-solving approach via its Dispute Resolution function. It also reviews IFC’s and MIGA’s compliance with environmental and social policies, assesses related harm, and recommends remedial actions through its Compliance function. Additionally, CAO provides advice to IFC, MIGA, and their Boards to enhance environmental and social sustainability performance and minimize the risk of harm.
Complaints may relate to environmental and social harm regarding any aspect of the planning, implementation, or impact of a project or sub-project, and can be made by any individual, group, community, entity, or other party affected or likely to be affected by the environmental or social impacts of an IFC- or MIGA-financed business activity.
Complaints can be submitted by any of the following methods:
- Online form: available at https://www.cao-ombudsman.org/
- Mail/Hand Delivery to: 2121 Pennsylvania Avenue, NW, Washington, DC 20433, USA
- Voice mail: +1 202 458 1973
- Email: cao@worldbankgroup.org
- SMS, WhatsApp, Telegram, and Signal: +1 202 650 2627
CAO receives and addresses complaints in accordance with the CAO Policy, which can be accessed at: https://www.cao-ombudsman.org/policies-guidelines.
This Environmental and Social Review Summary (ESRS) is prepared by IFC to disclose its findings and recommendations related to environmental and social considerations regarding potential investments. Its purpose is to enhance the transparency of IFC's activities. For any project documentation or data included or attached herein, whether prepared by the project sponsor or otherwise, authorization has been given for public release by the project sponsor. IFC considers that this ESRS is of adequate quality for release to the public, but has not necessarily independently verified all of the project information therein.
It is distributed in advance of IFC Board of Directors' consideration and may be periodically updated thereafter. Board dates are estimates only and this document should not be construed as presuming the outcome of the Board Directors’ decision. The following ESRS is disclosed in accordance with IFC's Access to Information Policy (AIP).
The map is for illustrative purposes and does not imply the expression of any opinion on the part of the World Bank, concerning the legal status of any country or territory or concerning the delimitation of frontiers or boundaries. Country borders or names do not necessarily reflect the World Bank Group's official position. In some cases, available project location information is limited to the country of the project's activities. Locations are approximate.
It is distributed in advance of IFC Board of Directors' consideration and may be periodically updated thereafter. Board dates are estimates only and this document should not be construed as presuming the outcome of the Board Directors’ decision. The following ESRS is disclosed in accordance with IFC's Access to Information Policy (AIP).
The map is for illustrative purposes and does not imply the expression of any opinion on the part of the World Bank, concerning the legal status of any country or territory or concerning the delimitation of frontiers or boundaries. Country borders or names do not necessarily reflect the World Bank Group's official position. In some cases, available project location information is limited to the country of the project's activities. Locations are approximate.