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 IFCs 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 3 - Resource Efficiency and Pollution Prevention
PS 4 – Community Health, Safety and Security
PS 5 – Land Acquisition and Involuntary Resettlement
PS 8 – Cultural Heritage
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards

This is a category A Project owing to the following potentially significant impacts: air quality (pollutant and greenhouse gas emissions), physical and economic displacement involving three communities, cultural heritage, and construction worker influx and health and safety impacts.

Environmental and Social Assessment

A draft EIA (January 2013), a RAP (January 2013), a RAP addendum (May 2013), and Stakeholder Engagement Plan were prepared for the proposed Azura-Edo IPP. The EIA was undertaken in accordance with the Nigerian Environmental Impact Assessment Act (Act No. 86 of 1992), World Bank requirements, World Bank Group (WBG) General Environmental, Health and Safety (EHS) Guidelines and EHS Guidelines for Thermal Power Plants and IFC’s Performance Standards. The RAPs were prepared in accordance with WB OP 4.12 and IFC’s 2012 Performance Standards. The EIA provides details of the impact assessment, mitigations measures, stakeholder consultation process and outcomes, cumulative impacts for each identified impact, reporting and disclosure modalities as well as an environmental and social management plan (ESMP) that outlines the mitigations measures to be put in place by Azura to manage identified potential risks and impacts. As explosion risks from the pipeline laying operation has not been addressed in the EIA, an additional risk assessment for this specific activity will be commissioned prior to start of this activity. The EIA includes a consideration of alternatives by providing a comparative analysis of the no Project alternative as well as location, design/ technology and fuel alternatives. The Project site was chosen because it has good road access, and it is in a relatively peaceful area and within Edo State, as per Azura Power’s partnership with the Edo State Government. In compliance with EIA guidelines, the Project EIA was publicly disclosed for comments from The Federal Ministry of Environment (FMEnv) as well as other stakeholders; an approval of the EIA was granted on February 27, 2013.



Organizational Capacity and Management Programs

Prior to the commencement of construction, Azura will appoint an Environmental, Health and Safety (EHS) professional and a community liaison officer both of whom will report to Azura’s General Manager. The EHS professional and the community liaison officer will have the responsibility for overseeing the development and implementation of the ESMP. Azura will establish an overarching policy defining the environmental and social objectives and principles that will guide the Project to achieve sound EHS and Social performance and as such the ESMP and IFC’s ESAP will be the basis of developing the thematic points of detailed management programs to support the policy objectives. Key management programs to be developed in collaboration with the Engineering, Procurement, Construction (EPC) and Operations and Management (O&M) contractors include: (i) construction management plan; (ii) health and safety management plans to manage risks relating to occupational health and safety, and community health and safety and ensure compliance with IFC PS2 and PS4; (iii) construction spoil and waste management plan; (iv) traffic control management plan; (v) spill response plan; (vi) unplanned
events and emergency response plan; (vii) biodiversity management plan; (viii) local employment strategy; (ix) local employment and procurement policy; (x) employment and workforce management plan to include (a) third party workers’ labor and working conditions screening mechanism (b) worker access to Azura’s grievance mechanism and (c) workers’ accommodation; (xi) influx management plan; (xii) grievance mechanism for workers, community and other stakeholders; (xiii) RAP implementation plan; (xiv) stakeholder engagement plan; (xv) comprehensive community investment plan; (xvi) physical cultural resources management plan; (xvii) contractors ESMP implementation auditing plan; (xviii) monitoring plan/manual setting out the air, noise and water monitoring programs; (xix) and site closure and restoration plan. These management programs will be compliant with IFC Performance Standards, WBG General and Thermal Power Plant EHS Guidelines, WHO standards, and Nigerian standards.



As indicated in the ESMP, the EHS professional will ensure that proper document control and record keeping procedures are in place for the management programs.



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Emergency Preparedness and Response

Storage, handling and use of hazardous material on site and the presence of a natural gas can present potential hazard in relation to accidental spills/leak, fire and explosion. The proposed specification for the fire-fighting system includes fitting gas turbines with self-contained fire detection and protection system, as well as a fire water system; it appears appropriate for an installation of this type. Both the EPC contractor and the Company will develop an emergency response plan (ERP) for the construction, the operation phase ERP will be developed by Azura and O&M contractor. The Plan will describe the procedures to follow for the connecting pipeline and power plant when handling an emergency situation such as fire, explosion, hazardous material or waste spills, injuries, natural disasters. This will include establishment of a communication network between the EPC contractor, Azura and emergency services such as fire departments, the communities, local medical services, and NIPP. The system will be tested as per good industry practices through a mock drill to confirm effectiveness of the system or rectify any identified oversight.



Monitoring and ReportingDuring the construction phase, Azura EHS professional will liaise with the EPC Contractors’ EHS supervisor or equivalent, and ensure that construction phase management programs are adhered to. These respective supervisor and manager will ensure proper training of respective employees, contractors and subcontractors, implementation of occupational health and safety (“OHS”) standards on the construction site, have joint meetings on OHS and share lessons learned, as well as jointly investigate any incidents/accidents related to the Project.



Azura will put in place an EHS monitoring program which includes periodic
monitoring of solid and liquid waste generated, air emissions, noise, energy and water consumption, incidents and accidents during construction and operation, job creation within the local communities, livelihood restoration of affected communities etc. Specific indicators are included in the ESMP to enable tracking, monitoring, analysis of EHS and Social performance. The outcome of the monitoring activities will be reported internally. The Federal Ministry of Environment guidelines require an environmental monitoring plan as part of an EIA, and as such Azura will prepare and submit annual report on E&S performance to the Federal Ministry of Environment. As a legal requirement, Azura Power will liaise with the Edo State Government’s Ministry of Employment, Labor and Productivity to report any health and safety incidents. Furthermore, Azura will retain a qualified third party independent consultant to verify its monitoring data.

Human Resources (HR) Policy

Azura will put in place HR policies and procedures to meet Nigerian Labor laws and this Performance Standard requirement. The requirement of this performance standard with exception for paragraphs 18–19, and 27–29 will apply to the EPC contractor as well as the O&M contractor and their employees. Azura will ensure that it has a mechanism in place to verify their compliance with the relevant sections of PS2. An HR manual will be accessible to employees and will reference workers’ rights under national labor and employment laws, any applicable collective bargaining agreement, employment benefits, disciplinary action, grievance mechanism, and a performance evaluation system.



Non-Discrimination, Equal Opportunities and Protection of the WorkforceThere are restrictions on discrimination, child labor, and forced labor in the Nigerian labor and employment law. In order to ensure that there is no recruitment of underage workers, Azura will require from potential candidates birth certificate or other valid identification. Azura will be required to articulate an HR policy that sets out its approach to managing labor consistent with this Performance Standard.



Freedom of Association and Grievance Mechanism

While Nigeria has ratified all eight core International Labor Organization conventions, and enacted laws to enforce the provisions, there are indications of restrictions on the trade union rights of workers in Nigeria. As such Azura will not restrict workers from developing alternative mechanisms to protect their rights and express grievance regarding working conditions and terms of employment. Alternative mechanism could be workers’ representatives that will serve as liaisons between management and staff.

The grievance mechanism will also allow for anonymous complaints to be raised and addressed. The mechanism will not impede access to other judicial or administrative remedies that might be available under the law or through existing arbitration procedures, or substitute for grievance mechanisms provided through collective agreements. In the event that contracted workers do not have access to a grievance mechanism, Azura will extend its own to them and communicate its existence and accessibility.



Occupational Health and Safety

Approximately 500 workers will be employed during the construction phase and up to 70 percent of the construction workers can be sourced locally, from within 30 km of the site. Approximately 50 permanent site employees will be employed during the operational phase, including plant management staff, maintenance staff, skilled technicians, drivers, cleaning staff and a number of semi-skilled operators. As per the ESMP, Azura Power will develop an Employment and Workforce Management Plan. As defined in the ESMP, the Contractor is required to develop and implement a plan for the management of workers that complies with Nigerian law and this Performance Standard. The guiding principles as def
ined in ESMP include, adherence to international standards, a commitment to transparency and non-discrimination and equality, optimization of local content and a commitment to health and safety. The Occupational Health and Safety (OHS) plan within the ESMP provides the overarching framework for OHS management during construction such as the potential for accidents in the workplace, contracting infectious diseases etc. Submission of management programs documentation confirming compliance with the Employment and Workforce Management Plan and OHS Plan will be a requirement. All employees, and contracted workers are expected to adhere to all OHS related programs and requirements adopted by Azura. Personal protective equipment such as steel toe boots, uniforms, hard hats, goggles, ear plugs, harness, etc. will be provided to staff as relevant to their jobs. Azura is committed to providing resources essential to the implementation and control of the ESMP.



As indicated in the ESMP, Azura Power will identify, plan, monitor, and record training needs for personnel whose work may have a significant adverse impact upon the environment, health, safety and/ or social conditions. The Project recognizes that it is important that employees at each relevant function and level are aware of the Project’s environmental and social policy; potential impacts of their activities; and roles and responsibilities in achieving conformance with the policy and procedures. This will be achieved through a formal training process.



A temporary construction camp will be constructed on the north western portion of the Project site. The exact nature of the accommodation will be determined in discussion with the EPC contractor but will likely include accommodation, cooking and sanitary facilities for construction workers, lay down areas and vehicle parking areas. The construction camp will be fenced and access will be controlled and restricted to employees. The EPC will develop and implement policies and procedures for the management of this camp in a manner consistent with this PS and IFC/EBRD Best Practice Notes on Workers’ Accommodation.

Air emissions: the key point sources of emissions from the power plant will originate from the three gas turbine stacks, and the black start diesel engine stacks estimated to run for less than 100 hours a year. The gas turbines will be fitted with dry low nitrogen oxides (NOx) burners which will ensure NOx emissions meet WBG EHS Guidelines. Sulfur emissions will be negligible. A construction management plan and traffic management plan have been developed to minimize and control dust emissions from site clearing and earth works, mobile machinery and vehicles.



An ambient air quality survey was conducted during the wet and dry seasons for the study area (defined as an area within 2 km of the Project site). Ambient air quality was assessed using US EPA air emission model AIRMOD and assuming stack heights of 35m. Furthermore, five years of hourly sequential meteorological data were obtained and processed through the USEPA AERMET program. The results show a relatively clean air shed with low values of key pollutants well within Nigerian Ambient Air Quality standards.



The main source of carbon dioxide (CO2) emissions during operation is the combustion of natural gas. The EIA estimated greenhouse gas (GHG) emissions of 2,718,000 tons of CO2 equivalent per year.



Supply of water during construction and operation phase will be sourced from boreholes. Water will be stored in raw water storage tank with a capacity of 1,600 cubic meters (m3). It is estimated that the power plant will require approximately 10 m3 of water from the boreholes per day. A water treatment plant will be in place for the production of demineralized water and domestic use.



Increase ambient noise levels are anticipated due to mobile machinery, influx of traffic, construction and operations activities. The gas turbines will be emplaced within a noise barrier. Noise modeling indicated that operational noise level will be within the WBG General EHS Guidelines during day and night at all receptors. A revised noise modeling is being conducted given the anticipated change in plant configuration.



The increase of workers during the construction phase will require availability of toilets. Azura will ensure that sanitary waste generated during the construction phase is adequately disposed of. Domestic sanitary waste will be treated to acceptable standard.



Wastewaters such as oily effluents and chemical liquid waste from pressure filters, regeneration effluent from demineralization plant, chemical laboratory wastes, gas compressor wash water will be collected and treated before settling into a central wastewater monitoring basin; and finally pass through an oil and water separator. Treated effluent meeting the Nigerian and WBG General EHS Guidelines discharge criteria will be discharged through the power plant effluent drainage system to a dead end trench. The drainage mechanism will either be by natural evaporation or soak away Non-contaminated water will be directed into t
he storm water network and discharged to the stream.





Solid waste generated during construction will include excavated soil, excess concrete, used timber, domestic waste, various packaging, containers, waste oil, batteries etc. Azura will utilize licensed contractors to dispose of waste and require a chain of custody documentation to final destination.



Hazardous material will mainly consist of diesel that will be stored in 40 m3 tank with secondary containment. Small amount of hazardous waste such as used lubricating and hydraulic oils, air and oil filters, batteries, sludge will be generated by the power plant. Hazardous waste will also be disposed of in a licensed facility by a licensed third party contractor who will be required to deliver chain custody documentation.



As per the waste management plan, Azura will include the requirements for separation, handling, and disposal of waste including the production of sludge.

Azura as well as the EPC and O&M Contractors will include in their environmental management plans procedures to minimize health, safety and security impacts to surrounding communities from construction and operation phases. These procedures will focus on managing ambient air quality, increased traffic, explosion risk from gas pipeline, control of safe delivery of construction materials, accident management, roadside spill response system, defensive driving and drugs and alcohol testing for truck drivers, health management including HIV/AIDS awareness and prevention program including voluntary testing campaigns for site workers as well as local communities.



Security forces

Azura will require that security personnel have undertaken necessary screening and training in accordance with good industry practices. Azura will put in place a system to investigate any credible allegations of unlawful or abusive acts of security personnel, take action or urge appropriate parties to take action to prevent recurrence, and report unlawful and abusive acts to public authorities when appropriate.

There are several sacred sites located in small patches of forests, and other places within the communities, including on the Project site. As such, the Project will require the displacement of several shrines/sacred sites, and a few tombs from the Project site. Although the removal of these shrines/sacred sites could temporarily disrupt local worship practices; however, community members indicated during consultation that it is possible to move these shrines/sacred sites to accommodate the Project. Azura will ensure that a thorough inventory of shrines/sacred sites is conducted again closer to commencement of site clearing activities in close consultation with religious leaders within the affected communities and possibly involve a witness NGO to oversee the displacement process.



Benin moats run through the Project site, they are among the largest ancient earthworks in the world and scattered throughout the Benin State. These earthworks are a complex linear system of 16,000 km of moats and ramparts (some up to 18 meters high) spread over some 6,500 square kilometers. To date, there are no conservation plans elaborated for the moats despite the fact that they have been protected by national legislation since 1961 and are listed on the UNESCO website as one of Nigeria tentative World Heritage Sites. Discussions with communities’ leaders indicated preservation of the functionality of the Benin moats as a drainage system should be preserved.



The moats on the Project site are not in good condition; Azura plans to rehabilitate them to prevent further damage as at this stage it is not clear if they can be restored. An assessment of the moats is underway. Based on the outcome of the assessment, Azura might channel storm water through the moats as it is currently done by the neighboring NIPP site. As indicated in the ESMP, the Physical Cultural Resources Management Plan to be developed will include the shrines/sacred sites and the Benin Moats.

The EIA includes a detailed socio-economic assessment, stakeholder engagement and disclosure process. The RAP includes a detailed stakeholder engagement plan. A significant number of meetings took place between May 2010 and February 2012 such as preliminary community engagement exercise prior to socio-economic and valuation survey; valuation methodology; review of data collection; consultation with vulnerable groups, youth groups, and local traders; and address of grievances. Furthermore, Affected People and communities had the opportunity for informed participation in key phases of resettlement planning, as such, a series of meetings were held with community leaders, appointed community valuers, and the State Government to discuss entitlement matrix and gain feedback which were taken into account in finalizing the draft RAP for disclosure. Key issues identified by stakeholders included compensation for affected communities; NIPP related community issues such as compensation and project benefits; social infrastructure, health and safety; local employment opportunities; and provision of electricity. Details of all the issues raised and interactions with the various stakeholders are included in the EIA and RAP. The extent of the information provided about the Project was considered to be adequate and the stakeholder comments were considered to be free in their expression. The issues identified have been/will be addressed in the respective assessments undertaken and management plans such as: (i) Local Employment and Procurement Policy; (ii) Local Employment Strategy; (iii) Comprehensive Community Investment Plan; (iv) Traffic Management Plan; and (v) Physical Cultural Resources Management Plan. There were no specific objections to the Project which is generally perceived as an opportunity to bring further development in the areas

As per its Stakeholder Engagement Plan, Azura Power will maintain a formal procedure for communications with the regulatory authorities and communities. The community liaison officer will be responsible for disseminating information, handling grievances and coordinating community communications through the course of the Project.

Azura Edo IPP
Contact: Nick Abolo-Tedi
Email: na@azurawa.com
Website: http://www.azurawa.com

Task Description	Anticipated Completion Date
1.  Azura will provide IFC with a copy of the EPC and O&M Contractors’ E&S management system for comments prior to start of relevant activity.	No later than one month prior to commencement of the site clearing activities, construction or operation phase. For activities taking place in the first three months after the Notice to Proceed is issued, no later than two weeks prior to commencement of either site clearing or construction phase.
2.       Azura will provide a copy of its E&S management programs as described in the ESRS and ESMP prior to start of relevant activity	No later than one month prior to commencement of the site clearing activities, construction or operation phase. For activities taking place in the first three months after the Notice to Proceed is issued, no later than two weeks prior to commencement of either site clearing or construction phase.
3.       Azura will provide a copy of the risk assessment for explosion risks from the pipeline operation.	Prior to start of pipeline laying activities.
4. Azura will commission an external completion audit of the RAP and RAP addendum implementation once the mitigation measures have been substantially completed in order to verify livelihood restoration outcome.	Within three years from start of construction phase.
5. Azura will articulate a Human Resource Policy and develop a manual outlining workers’ rights under national employment law and the requirement of Performance Standard 2	3 months prior to start of operation.
6.    Azura will conduct: (a) point source air emission monitoring on a continuous or indicative basis and annual stack emission testing for NOx ; and (b) ambient air quality monitoring by either passive samplers (monthly average) or by seasonal manual sampling for parameters consistent with relevant air quality standards.	During operation phase