While all Performance Standards are applicable to this investment, IFCs environmental and social due diligence indicates that the investment will have impacts which must be managed in a manner consistent with the following Performance Standards. If IFC's investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards.

PS 1 – Assessment and Management of Environmental and Social Risks and Impacts
PS 2 - Labor and working conditions
PS 6 – Biodiversity Conservation and Sustainable Management of Living Natural Resources

Issues are not expected to arise with regard to PS3 on Resource Efficiency and Pollution Prevention, PS4 on Community Health, Safety and Security, PS5 on Land Acquisition and Involuntary Resettlement, PS7 on Indigenous Peoples, or PS8 on Cultural Heritage.

The main E&S risks and impacts in this project will unfold during cable-laying, and those risks and impacts are expected to be limited, with no major adverse environmental or social impacts expected to result. Therefore, the project has been classified as Category B according to IFC’s Procedure for Environmental and Social Review of Projects.

IFC's appraisal considered the environmental and social management planning process and documentation for the project and gaps, if any, between these and IFCs requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable period of time, are summarized in the paragraphs that follow and (if applicable) in an agreed Environmental and Social Action Plan (ESAP). Through the implementation of these measures, the project is expected to be designed and operated in accordance with Performance Standards objectives.

E&S feasibility studies and relevant marine surveys have been completed for obtaining initial permits in the United States and in Brazil. Those E&S studies included consultations with local authorities and local community members. The results of those E&S studies and relevant marine surveys were reviewed by Seaborn, and as a result, E&S considerations played a role in selecting a route for the Company’s undersea cable through international waters and through territorial waters of Brazil and the United States, as well as in the selection of all three cable landing points. Further necessary E&S assessment remains to be performed for developing and maintaining the chosen route, and for the two specific cable landing station sites in Brazil.



In most areas, cable burial is expected to be performed by a ship. Burial disturbs the seabed along the narrow path of the cable, and mitigative measures are required. Advance E&S assessment determines specific mitigative measures to be taken. In general, the ship performing the cable burial will use satellite-based global positioning to perform constant monitoring, along with precision echo-sounders, seabed mapping systems, and a rotometer, while an onboard engineer constantly refers to a route plan and makes adjustments as needed. There may also be computerized tracking that includes detection of external factors such as winds and ocean currents, and means to correct for such influences.



Generally, when cable burial is performed in areas where a ship cannot perform the necessary functions, remotely operated vehicles are used, fitted with trenching and burial tools, as well as video and navigational aids. Once laid, the cable comes ashore and is connected to the terminal or cable station. Later on, damage to the cable may result from technical faults, human activities or natural events. If needed, the cable will be retrieved from the seabed for repair, replacement or removal. Recovery generally entails location of the cable, identification of any faulted section; retrieval of the cable with specially designed grapnels deployed from the repair vessel; and lifting to the surface for removal or repair.



E&S studies for undersea cables are normally limited to territorial seas, and are not required for international waters, considering their depth and deployment on top of the seabed, and the resulting low level of E&S risk. The key E&S studies (the “Studies”) performed so far by Seaborn examined mainly actions required to obtain permits from relevant federal, state and local authorities in the United States and in Brazil. In each country, permits to be granted include a specified and identified list of Permits in Principle, Operational Permits, and Third Party Approvals.



The Studies identified oil block concession holders in Brazil who will need to be notified to avoid potential conflicts. The Studies recommended that Seaborn avoid a local area in Brazil where the presence of the Bryde’s whale h
as been identified. The Studies recommended informing Brazil’s Instituto Brasileiro do Meio Ambiente e dos Recursos Naturais Renováveis (IBAMA) about the penetration of seismic survey equipment for a cable route survey, to verify if any mitigation is required in those restricted areas. The Studies identified the potential for occasional sea turtle nesting near one of the landing sites for Seaborn’s cable.



Under IFC’s investment, Seaborn will implement where necessary the Studies’ recommendations, and such other actions as needed to comply with IFC Performance Standards. Seaborn will undertake further E&S assessment, as noted below, including assessment of any risks/impacts on a population of threatened franciscana dolphins (Pontoporiablainvillei), near the proposed landing site at Praia Grande. Seaborn will undertake all required public consultations as part of the next stages of E&S assessment, and the Company will compensate as needed for any temporary demonstrable loss of livelihoods in local fishery or other impacted livelihoods. Seaborn is also expected to develop and implement an E&S action plan that will result from recommendations to be made at the conclusion of further E&S assessment.



Further E&S assessment to be undertaken by Seaborn will cover E&S issues in laying and maintenance of cable, and in the maintenance of landing stations. For such further E&S assessment, terms of reference will be reviewed with the Company, with input from IFC. Such further assessment should cover both environmental and social issues, and should be developed with reference to IFC Performance Standards and IFC EHS Guidelines. Such assessment should rank each risk/impact according to its probability, magnitude, duration, severity, and significance, and should include an E&S action plan to manage E&S risks and impacts, including development and implementation of necessary E&S policies and procedures.



Further assessment should include analysis of issues related to congestion at Seaborn’s planned landing sites. Such analysis should examine the number and status of existing in-service and out-of-service cables, the number and separation of existing beach manholes, terrestrial and maritime regulatory parameters, and offshore hazards, obstructions and available routing. It should include a geophysical survey, or other suitable means to identify any in-service cables along the route of the new cable, and a check with owners or applicable regulatory authorities of any such in-service cables as to whether the proposed crossing methodology is appropriate, and whether those owners’ systems might reasonably be expected to be compromised by Seaborn’s installation.



Further assessment should also identify risks/impacts on aquatic life during installation and maintenance, and make recommendations on avoiding adverse impacts on coral, sea grass, dolphins and whales, turtle nesting areas, and any critical natural habitat, and on avoiding harmful activit
y during spawning or reproduction cycles. A baseline study may be needed to explore any sensitive marine habitat along the proposed route.



Primary data should be gathered as needed from a diver survey, a side-scan radar survey, and a project-specific survey to collect baseline data on benthic communities and marine habitats along the proposed route. Assessment should review any issues related to protected areas, and should detect and confirm any anomalies, such as man-made debris or rock outcrops, and prescribe ways to avoid areas with anomalies. It should identify any heavy vessel traffic across the proposed cable route, and review the fault history of in-service cables in the area to ascertain risk. It should cover domestic waste management at the terminal stations, and include a list of pending environmental and related permits and an estimated timetable for obtaining them.



Further social assessment will cover topics including any adverse impact on cultural property in the project’s area of influence, and any need to compensate for adverse impacts on livelihoods in the area of influence, including the known traditional artisanal fishing communities near the Praia Grande landing site. It will also assess issues involving the health and safety of workers involved in cable installation and maintenance, and will include public disclosure and consultations consistent with IFC Performance Standards.



If Seaborn acquires land to construct one or more landing stations, then it will comply with all applicable requirements of PS5 on Land Acquisition and Involuntary Resettlement.



Further E&S assessment and recommended action items will be subject to review by IFC. Seaborn will be expected to maintain as necessary an organizational structure that defines roles, responsibilities, and authority to manage E&S issues. Specific personnel, including management representative(s), with clear lines of responsibility and authority should be designated. Key E&S responsibilities should be well defined and communicated to the relevant personnel. Sufficient management sponsorship and human and financial resources will be provided on an ongoing basis to achieve effective and continuous E&S performance.



Seaborn will include E&S terms in agreements with contractors for core functions, and will develop and implement policies/procedures to monitor compliance with those terms. If a decision is made by Seaborn to develop further infrastructure under IFC’s investment, such as an additional landing site, then Seaborn would be required to notify IFC in advance, and then, if needed, to submit an E&S management plan to IFC for review and approval prior to development. Seaborn will be expected to monitor and report on E&S issues on a regular basis, and to monitor and report separately on incidents.

Seaborn has at present approximately 80 individuals involved directly or indirectly in the Seabras-1 project, and once the project is fully funded, there are expected to be more than 240 individuals involved directly or indirectly in the project, including the manufacture and laying of its submarine cable and installation of facilities on land. Due to time-bound, labor-intensive specific tasks taken on by contractors at various times, the number of indirect employees can vary from month to month.



Seaborn’s human resources policies and procedures will ensure compliance with IFC Performance Standards. For all Seaborn offices and operational sites, appropriate measures for life and fire safety will be implemented.



Seaborn will develop and implement policies and procedures to ensure that its own employees who perform core functions are provided with appropriate personal protective equipment and health and safety training for the type of work in which they are engaged. Seaborn will make commercially reasonable efforts to ensure that contractors who perform core functions for Seaborn shall provide a safe and healthy work environment, including appropriate training, protective clothing and equipment, and that none are below the legal employment age. This will be done by inclusion of appropriate terms in contracts and monitoring by Seaborn of compliance with those terms.

The Company will ensure that local biodiversity and natural habitat will be preserved, and any temporary disruption will be managed in compliance with IFC Performance Standard 6.



When Seaborn’s E&S assessment is completed, it is expected to confirm that the project will not affect any sensitive marine habitats including coral, sea grass, dolphins and whales, and turtle nesting areas. Supporting data may include the results of a side-scan radar survey and targeted dives to confirm the results of the side-scan survey. Additional due diligence investigation may also be needed to confirm that no sensitive marine habitats such as coral or sea grass exist along the proposed route. In case any impact on sensitive marine habitats does occur in spite of Seaborn’s prior assessment, Seaborn will put policies and procedures in place in advance in order to manage those impacts in compliance with IFC Performance Standards.

Seaborn recognizes the importance of community engagement. Assessment information and other relevant information will be disclosed by Seaborn to local community members according to IFC’s Policy on Disclosure of Information. The Company will consult with relevant local community members, including people who can reasonably be expected to suffer any temporary demonstrable loss of livelihoodas a result of Seaborn’s project. Such consultations will provide an opportunity for expression of concerns before any relevant activity is begun, and Seaborn will work to address concerns, according to IFC’s Performance Standards.

Seaborn is committed to following up on and resolving any complaints from community members for the duration of this project. If a substantial number of community members complain about the same issue, and circumstances indicate that a meeting for Seaborn to engage with community members may be useful, then Seaborn will organize such a meeting. A Seaborn operational director will oversee Seaborn’s community engagement.

Seaborn Networks Group, Inc.
100 Cummings Center, Suite 435-P
Beverly, Massachusetts 01915, U.S.A.
Telephone +1 978 377 8366
Email mailto:info@seabornnetworks.com

Broad Community Support is not applicable for this project

Current client performance is aligned with applicable Performance Standards and EHS Guideline requirements. No ESAP is required.