The company has presented plans to address the potential environmental and social impacts to ensure that the project will, upon implementation of the specific agreed mitigation measures, comply with policies and standards internal to AEL, applicable national laws and regulations, IFC’s Performance Standards on Social and Environmental Sustainability and applicable World Bank Group (WBG) Environmental, Health and Safety (EHS) Guidelines. The information about how these potential impacts will be addressed by the project is summarized in the paragraphs that follow, and in the ESAP which is disclosed with this document.
Social and Environmental Assessment and Management Systems
An Indenture of Assignment between the prior lease holder and AEL and the consent to this assignment by the Western Regional Lands Commission confirmed the lease agreement for the site. The development required an environmental impact assessment (EIA) as per national environmental assessment regulations; the company has met these requirements, and subsequently been granted an environmental permit, issued to ‘Protea-Select Hotel, Takoradi.’ The permit contained requirements related to waste management, traffic management, occupational health and safety, compliance with Ghana National Fire Service Regulations, landscaping and compliance with Ghana Tourism Board Regulations. An Environmental Certificate will be required to be obtained within two years of the date of permit issuance.
The project has also received approval from the Town and Country Planning Department of the Sekondi Takoradi Metropolitan Assembly (STMA) for the rezoning from residential to commercial use. The project has received approval from the municipal Work Engineer’s Department for a building permit and has the right to demolish the existing structure on site.
As noted above, WSP have been retained for pre-construction, construction and post-construction phases and also to advise on employment conditions, hiring and contracting of sub-consultants, geotechnical investigations, feasibility studies, progress payment approvals, financial reports and final accounting. Aside from overseeing these technical aspects, a full-time project manager representing CAPIC and the Mohinani Group will be ultimately responsible for project delivery.
The aforementioned Environmental Permit requires the company to submit an Annual Environmental Report. In addition, the STMA will require environmental and social information about the project to be reported. An in-house inspector will audit environmental issues (such as monitoring of energy use and waste generation). AEL was specifically formed for the purpose of delivering this project; as such it has no previous projects on which it has publicly provided environmental and social information. AEL will follow the established procedures of its shareholders, however, with respect to E&S management in general and also that of reporting.
The AEL project site is an approximately 8000m2 site located in a low density residential area of Takoradi, Ghana. AEL has commissioned a recognized architectural firm and hired a globally recognized project management company (WSP Developments Nigeria Ltd., a subsidiary of WSP Group Africa WSP) for the structural, mechanical and electrical and project management activities so as to design and build the hotel to recognized international standards. Protea, a multi-national specialized hotel management company will operate the hotel and their internal management policies and procedures typically comply with IFC’s requirements.
Protea will ensure that is has the necessary capacity to manage the E&S issues associated with operating the hotel, and that it complies with any and all permit and other regulatory requirements. Specific actions have been defined in the project Environmental and Social Action Plan (ESAP) to enhance environmental and social performance during construction and operation and the company, directly or through its contractors and/or management entities, will have the capacity to ensure compliance.
Labor and Working Conditions
The project manager is currently the only staff member employed by AEL. The project is to be delivered by a team of external consultants and subcontractors. Audits of plan requirements will be undertaken by an inspector from the project’s shareholders. The H&S plan and associated actions as managed under the Environmental and Social Management System (ESMS) is addressed in the ESAP.
Protea has extensive experience in hotel management and will be responsible, under the Management and Marketing Agreement/Contract, to assist AEL in managing the facility during the operational phase. Protea has standard operating policies and procedures that apply to all operations. Topics covered include human resources, operation of equipment and the management of life and fire safety, amongst others. Protea has a Corporate Code of Conduct that applies to all employees which includes a non-discrimination policy and guidelines in respect of harassment and victimization at work. The company also has a generic Employee Handbook that is applicable to all operations. This defines conditions of employment including leave benefits (vacation, sick and maternity leave), access to medical aid which is inclusive of an employee’s immediate family, and the company’s approach to training and development of employees. Provisions in the handbook are supplemented at the local level to reflect and comply with local and national laws and regulations.
In Ghana all employees are allowed to join unions and the Commercial and Industrial Union generally represents employees in the tourism industry. As per the project ESAP, AEL will be required to confirm compliance with PS 2 requirements and those stemming from Ghana legislation/regulation. Ghana is a member of the International Labor Organization and has ratified 47 Conventions including those related to minimum wage, weekly rest, child labor and discrimination.
The minimum age for employment in Ghana is 18 years and AEL will screen/review personnel records to ensure workers are above the legal age.
At the time of appraisal the exact staff compliment to be employed during operations was not known. It is, however, estimated to be of the order of 130 (based on a development of approximately 132 rooms and suites) and will include approximately 50 women.
AEL is ultimately responsible for occupational health and safety (OHS) on-site, however their contract with WSP requires the construction company to comply with national requirements and appoint personnel to manage this component. Equally, subcontractors’ agreements with WSP will require compliance with national standards and WSP’s internal requirements. Best practice will be followed with regards to OHS on site. For example, safety will be featured at project meetings and all activities will require a method statement to be developed prior to actions being initiated. These method statements will include safety procedures, particularly where high risk activities are to be undertaken e.g., hot work, or working at heights. All construction workers will be provided with personal protective equipment in order to carry out their jobs in a safe manner. All workers will also be subject to appropriate training, along with reminders that will cover relevant topics. A site Manager will be responsible to ensure safe practices are adhered to and, as necessary, safety officers, or their equivalent, will support this role, conduct inspections of work areas, etc. Trained supervisors will be assigned to high risk practices such as hot work for the duration of the task. Safety reports will be required, which will be consolidated into weekly and monthly reports to enable assessment of performance. In the event of an incident, the cause will be reported upon and corrective actions defined and implemented; such documentation and activities will inform management actions to ensure worker’s health is protected and their safety provided for during work-related activities. Development and management of OHS on site is addressed in the ESAP.
Typical OHS risks during the operational phase are expected to be low; however, as noted above Protea will ensure that it provides for the health and safety of its employees. AEL will confirm that appropriate measures that meet regulatory and IFC requirements will be in place prior to the commencement of hotel operations. This is addressed in the ESAP.
Pollution Prevention and Abatement
Permit application requirements included development of an Environmental Management Plan for the construction phase of the project that includes elements related to pollution prevention and abatement; this forms part of AEL’s contractual agreement with WSP. Specific actions are described such as the demolition of existing building and the use of this rubble for backfill, etc. Standard requirements for ablution facilities will be implemented and their management conducted in accordance with local regulations and/or specific permit requirements. Solid waste will be collected and disposed of appropriately; the company will promote reuse and recycling where possible. Storm water will be managed through the use of drainage channels so as to minimize the impact upon the construction site and will be disposed of in accordance with local and/or permit requirements. Dust control will be managed by watering exposed surfaces. Specific measures as included in the environmental management plan are transcribed into Method Statements as agreed to between the project management consultants and relevant sub-contractors.
Once constructed, the hotel will receive power from the national grid. Annual electricity consumption is estimated to be in the range of 250 – 280 kWh/m2 which is considered satisfactory for a property of this kind when compared with IFC’s EH&S Guideline figures. Air-conditioning and lighting will account for two-thirds of the power to be consumed.
An 800kVA diesel-powered back-up generator will be on-site in the event of a power failure. Double skinned Underground Storage Tanks (USTs) with leak detection installed and associated stock reconciliation management programs, will be used to store diesel on-site to fuel back-up generators. Storage tanks will comply with local and/or national requirements such as pressure testing prior to use and be subject to annual pressure testing to assist in leak prevention. These requirements are addressed in the ESAP. In addition to electricity, LPG will be used for cooking; biogas from the effluent treatment digester will supplement and may replace the consumption of LPG. Options for air conditioning were still being considered at the time of appraisal; options include either water-cooled central chillers or variable refrigerant volume and flow systems. Hot water will be preheated by heat recovery from air conditioning systems, with electrical supplementary heating.
Annual greenhouse gas emissions of the project are estimated at 2,567 tons of CO2-equivalent during construction and approximately 950 tons of CO2-equivalent per annum thereafter.
IFC has conducted a preliminary energy and water efficiency review of the proposed building design. This study concluded that whereas there are several energy saving practices already included in the building design, there are further options for the company to consider; discussions with the company are currently ongoing as to the possibilities for implementing such additional efficiency measures. Currently proposed practices call for room keys/cards to be required in order for guests to use electrical appliances in rooms. Pre-cooled fresh air will be blown into rooms prior to occupancy in place of constantly running in-room air-conditioners in order to prepare rooms in a cost- and energy-efficient manner. Windows will be limited in size to aid in energy management and will be double glazed; compact fluorescent bulbs and LEDs will be used in exit signs. In-room toilets will be dual flush systems and the flush systems for urinals in public areas will be activated via infrared so as to minimize water usage.
Related to the above, following one year of operations, an efficiency review will be undertaken of the hotel. This review will look at energy efficiency enhancements that were implemented and also to determine whether additional opportunities in matters such as water and electrical usage may exist. Digital, multi-functional meters will be used to measure incoming supply.
Raw water for operations will be provided from both the mains (Ghanaian Water Board) and two boreholes. Drinking water will be treated prior to being used in the hotel so as to meet WHO potable water standards; the treatment process has yet to be determined. As included in the ESAP, the potable water quality monitoring program will be in compliance with IFC’s requirements. A total daily requirement of 35m3 of water (12,775 m3 a year) is estimated for the hotel.
Sanitary wastewater will be directed to a proposed bio-digester system and then to a filtration unit consisting of stones, sand and activated carbon; grey wastewater will be sent directly to the filtration unit. Residual sludge will be further circulated back into the digester to produce methane. Some gas produced will be used for cooking and excess gas will be flared. Final effluent is expected to comply with IFC’s effluent limits; regardless, the discharge will be monitored to ensure compliance with both IFC and Ghana EPA limits and the company will be required to comply with any permit and/or other regulatory requirements associated with the flaring of excess biogas. These issues are addressed in the ESAP. The kitchens will be fitted with grease traps; there will lint traps on the discharge line from the laundry and an oil water separator on the discharge point from the building housing the generators.
Specific chemicals and/or processes that will be used to maintain water quality in the swimming pool had not been determined at the time of the appraisal. AEL will ensure appropriate practices regarding storage, mixing, use/application and disposal of spent or waste chemicals associated with swimming pool management and that of the pool water itself will meet IFC’s and regulatory or permit requirements. This is addressed in the ESAP.
Future maintenance of the hotel gardens/landscaping will require the use of pesticides on occasion and the hotel once built will also be fumigated according to a predefined schedule. As defined in the ESAP, the company will be required to compile and implement a pesticide management plan at the hotel that is consistent with IFC’s General EHS Guidelines and applicable local and/or national law and regulation.
Community Health, Safety and Security
The construction phase presents a variety of potential impacts upon the surrounding community. Traffic may create dust problems and heavy equipment accessing the site may present safety issues as will the delivery of building materials and removal of debris. The need for the safe disposal of waste, the management of construction chemicals, solvents, fuels and lubricants will also be required. Operational impacts will be less in size and severity; specific management of all such impacts throughout the life of the project is addressed in the ESAP under the auspices of the ESMS.
The WSP Fire Strategy Report stated the applicable legislation and codes of practice to be used with respect to life and fire safety were based upon British Standards. These standards cover fire protection, detection, suppression and operation of fire protection measures. For aspects not adequately addressed by the above, relevant NFPA standards will provide the reference. Specific measures will be adopted for the kitchen, the generator rooms and the diesel storage locations. The requirement to have the life and fire safety systems audited to ensure they are built to the above standards, and can be operated as designed, and that they also meet applicable local requirements prior to hotel occupancy, is addressed in the ESAP.
The client will implement a legionella management program in hot water systems and condensers and cooling towers and will extend this to pool water quality management in the swimming pool. This is addressed in the ESAP.
An accredited food safety program will be designed and implemented to cover the food and beverage service at the hotel (along the lines of the HACCP program). This is addressed in the ESAP.
