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
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards

This is a Category B project according to IFC’s Environmental and Social Review Procedure because of the limited number of specific impacts that may occur are generally site specific, and those impacts can be avoided or mitigated by adhering to generally recognized performance standards, procedures, guidelines or design criteria.

Key issues relate to; i) effective integration of environmental and social issues when planning projects; ii) occupational health and safety during construction and operations, including public health and safety; iii) management of environmental issues – solid and liquid waste, disturbance to fauna and flora – during construction and operations; and iv) management of social issues notably resettlement and livelihood restoration during construction.

GRIDCo has various defined procedures and plans to address the identified issues and these will be further supported by implementation of the project ESAP as presented below.

No specific public health, safety or security-related risks have been identified with respect to GRIDCo’s activities, including the new substation and transmission line project, and there have been no related incidents recorded in the past three years. As a result, PS 4 is not considered applicable to this investment. General corporate precautions and staffing in relation to community safety and security matters is described under PS 1 below.

As described above, economic displacement and resettlement associated with the Kpone power plant and the transmission line has already occurred (in 2009) and was the responsibility of VRA. Thus PS 5 is not considered applicable to the substation. While GRIDCo as a corporate entity endeavors to avoid the need for resettlement and economic displacement, future GRIDCo activities may result in impacts related to PS5: Land Acquisition and Involuntary Resettlement; as such, corporate management system procedural requirements related to this are discussed below under PS1. In addition, the Environmental Impact Assessment undertaken for the power plant identified no biodiversity issues and the land was already disturbed, thus PS6 is not applicable to the substation either. At the corporate level PS6: Biodiversity Conservation and Sustainable Management of Living Resources could apply to projects in the future; as with PS 5, related procedural requirements are discussed under PS1. Likewise PS7: Cultural Heritage is not applicable though the company will develop and implement a chance find protocol. There are no indigenous people in Ghana thus PS8: Indigenous Peoples will not apply to any of GRIDCo’s activities.

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.

In determining which projects require an EIA in accordance with national legislation, GRIDCo consults the national Environmental Protection Agency (EPA) though typically all new transmissions lines require such an assessment. Preliminary environmental assessments may also be requested for projects though this applies only to new substations and upgrade of existing transmissions lines spanning limited distances; such assessments may also be undertaken internally by GRIDCo, though EIA’s are undertaken by external consultants.



In accordance with the national Environmental Impact Assessment (EIA) Regulations promulgated under the Environmental Protection Agency Act, an EIA was required for the Kpone power station. This assessment included the substation and transmission lines required to link the plant into the broader transmission network. The EIA was undertaken by environmental specialists in the employ of VRA, however key specialist studies such as those associated with noise and air quality were undertaken by experienced independent consultants. Specific information on stakeholder engagement and key assessment findings are detailed below, however overall the assessment is considered sufficiently detailed and aligned with IFC’s requirements. This latter comment is stated in the context that the power station is considered an associated facility under this Performance Standard. The EIA has been approved by the national Environmental Protection Authority (EPA) with issuance of an Environmental Permit in November 2012. The permit has a detailed list of conditions of approval for all the respective phase of the operation associated with the power station, substation and ancillary transmission lines.



GRIDCo has an environmental policy signed off by the company CEO dated May 2010. This policy commits the organization to continual environmental improvements, compliance with national and international environmental protection regulations, pollution prevention, protection of biodiversity and waste reduction and ongoing assessment of environmental impacts associated with activities. VRA similarly has a detailed environmental policy and a well-staffed environmental department to ensure compliance with the policy.



The company’s approach to environmental management as articulated through the environmental policy is documented in the “Framework for Environmental and Social Management of Bulk Transmission Line Projects in Ghana”. This Framework has been modeled along the requirements of the ISO 14001 environmental management system and includes information and procedures related to; i) undertaking EIA’s, ii) developing and implementing Environmental Management Plans; iii) undertaking environmental audits, iv) approach to land acquisition and resettlement; and v) reporting amongst others aspects. Overall and given the nature of the company activities the Framework is considered adequate though needs to be strengthened in specific areas s
uch as that related to solid and liquid waste management and a common approach to the management of environmental impacts during the construction phase of all projects; further detail is provided in this document and where applicable appropriate actions are defined in the project ESAP.



Specific detail on GRIDCo’s approach to stakeholder engagement as a result of activities is defined below, including that related to development of the power station, substation and transmissions lines. However, the company has no formalized defined approach to stakeholder engagement including mechanisms for facilitating and resolving grievances raised by communities. Thus as defined in the ESAP, GRIDCo will develop and implement a Stakeholder Engagement Plan inclusive of a grievance mechanism.



GRIDCo attempts to avoid land acquisition and resettlement by constructing on Government owned land, or within road servitudes. Further, the company undertakes a search at the Lands Commission to ascertain ownership and thus negotiate with land owner so as to obtain land on a willing buyer willing seller basis where possible. However, some linear projects do require resettlement and/or compensation and GRIDCo’s Environment, Survey, Land Acquisition and Compensation section of the Engineering Department are responsible for this. The actual approach to resettlement and compensation is defined in the procedures included in GRIDCo’s Framework for Environmental and Social Management of Bulk Transmission Line Projects in Ghana. The focus of the approach is to ensure compliance with national legislation, notably the Lands Act. To ensure alignment with IFC’s requirements, GRIDCo will revise the current procedure related to resettlement and compensation to ensure compliance with this Performance Standard as defined in the ESAP.



Potential impacts on biodiversity for new capital projects are identified via the EIA process. GRIDCo’s objective is to avoid impacts on sensitive areas, though this may be unavoidable in some instances. To ensure alignment of future projects with Performance Standard 6, GRIDCo will include the requirement for screening of all projects to identify impacts on biodiversity; this will be included in the company’s Framework for Environmental and Social Management of Bulk Transmission Line Projects in Ghana.



GRIDCo is separated into various departments including the Engineering Department, Human Resources and Services, Finance Department, Network Performance Department and the Legal Department. There are also sections handling Planning, Lands Management, Design and Standards Section, Project and Contract Management and Environment, Survey, Land Acquisition and Compensation Department. The latter includes a dedicated Environmental Coordinator who is assisted by two personnel. GRIDCo also has staff dedicated to the management of OHS and a clear, well defined set of procedures that apply to this component; further information is provided in the
subsequent section. Training is provided to all drivers via internal activities and external specialized companies. In addition all vehicles are regularly serviced according to a predefined service schedule.



Most security activities are provided by the GRIDCo security Human Resources and Services Department with contractors providing support on the more low risk activities / operations. The head of security is an experienced previous military officer with security in the individual regions falling under the respective operational departments. All security guards are screened to verify if they have criminal records or not and there are specific guidelines that apply to the provision of security. No armed guards are used and if necessary guards may call on the police for support. Given the size of the transmission lines GRIDCo is responsible for, day to day risks to the public relative to the activities associated with electricity distribution companies who supply electricity to customers are limited. In the last 3 years there have been no public fatalities associated with GRIDCo’s operations and where projects are undertaken in proximity to communities, awareness and sensitivity programs are initiated to inform individuals about the dangers of electricity.



As per the permit issued for individual projects by the EPA, they are all audited by the agency annually and then 18 months following commencement of operations. Thereafter, Environmental Management Plans for projects need to be updated every 3 years.



The company has a dedicated Fire Officer who is supported by 2 firemen who are all trained in fire safety. All facilities, buildings, houses including substations, are taken into consideration when assessing GRIDCo’s needs relative to fire safety. There are first aid boxes provided at all locations along with fire-fighting equipment. The latter is inspected annually and fire drills are undertaken at least once annually at all locations. Aside from support to existing operations, the Fire Officer also reviews all new drawings to ensure life and fire safety is adequately addressed in the design and the British Standard is applied to all developments.



Emergency response at all locations is addressed via a “Fire Procedure” that defines the plan to be applied in such an event. In addition, there is a Fire Protection and Supervision Equipment Procedure that defines the approach to the acquisition of fire equipment and the fire suppression standards for all locations. Some facilities such as the national control center, server rooms and the like have automatic fire detection equipment and sprinkler systems are currently being designed for the warehouses. In addition, the potential to construct a water storage facility for headquarters is being considered; in the event of a fire this would allow fire-fighting to proceed independent of the municipal water supply. To date the company has only experienced two fires whereby transformers
were struck by lightning.

GRIDCo employs 801 people of whom 768 are permanent staff and the remaining are on contract. Of the total staff complement, 95 are female. The HR Department is overseen by a Director and is also responsible for managing security and general services such as fleet management and the workshops. Aside from administrative staff, there are three dedicated HR managers supported by an additional staff dedicated to specific functions such as recruitment, industrial relations, training, compensation and benefits allied to other associated tasks.



GRIDCo’s HR policies and procedures are applicable to all employees, permanent staff and contractors alike, and made available at the time of employment. HR management is further supported by a collective bargaining agreement which provides additional information such as benefits, disciplinary procedures, shift duties and others. There are also service conditions that apply specifically to senior staff and include information on training and development, conferences and allowances, wages and welfare, amongst other topics.



There is a defined grievance procedure whereby an employee has recourse to various levels of management including the company CEO if necessary; ultimately if a grievance is unable to be addressed internally, it may be referred to the National Labor Commission, or the courts. However, there is no mechanism whereby employees may raise an anonymous grievance and no defined policy on equal opportunity and non-discrimination exists. Thus as per the ESAP, GRIDCo will develop and implement policies and procedures related to these matters and communicate them to employees.



In accordance with national legislation employees are free to join unions and, as noted above, there is a signed collective bargaining agreement with the Public Service Workers Union valid for two years. Of the total staff compliment at GRIDCo, 353 are unionized and Senior Staff are represented via the Senior Staff Association. The minimum age for employment in Ghana is 18 years and personal records are checked at the time of employment to ensure candidates comply with this criterion.



Outsourced activities by the company include cleaning services, clearing of vegetation around transmission line towers and security at less sensitive locations. Ghana is a member of the International Labor Organization and has ratified 46 Conventions including those related to minimum wage, weekly rest, child labor and discrimination. While these largely ensure compliance with this Performance Standard, GRIDCo will require contractors as defined above and those that may be employed in the future undertaking activities core to the company’s activities, to comply with the requirements of this Performance Standard where applicable. Similarly, GRIDCo will also amend its HR documentation such that contractors undertaking construction activities on behalf of the company also comply with the applicable requirements of this PS; these ac
tions are defined in the project ESAP.



There is an OHS Manager responsible for all areas supported by 2 dedicated safety officers and an assistant. This manager is also responsible for emergency response including the safety officer and 2 firemen. GRIDCo has a comprehensive set of documentation focused on managing OHS for all activities. There is a Safety Handbook which defines the Safety Policy, approach to administration of safety and safety committees, and accident reporting and the provision of first aid. Affiliated to this are Corporate Safety Rules and include safety requirements related to the following areas and activities: i) General Rules for all Employees; ii) General Rules for all Employees Engaged in Construction, Operation or Maintenance; iii) Tools and Safety Requirements; iv) Equipment, Motor Vehicles and Transportation of Personnel and Equipment; v) General Shop Work; vi) Forestry Work; vii) Line Work, Operating and Station Work, viii) Materials Handling, Storage and Disposal and; ix) Water Ways. Finally, there is a Standard Protection Code which applies to the protection of personnel at work associated with live installations. This includes detailed information and procedures for working with live apparatus.



GRIDCo has a Safety Advisory Committee on which the CEO is represented along with the Directors of all departments and the OHS Manager is the committee secretary; the committee meets twice annually to review safety performance and make recommendations as to improvements. GRIDCo separates the country into two geographical areas i.e., the northern and southern region, and within each of these there are three operational areas respectively and each area has differing sections depending on the type of work undertaken. Each operational area has a weekly safety meeting with one person from each section nominated as the safety representative. Safety representatives are appointed for a period of 3 years and upon appointment undergo a 2 week intensive training course on OHS management. Supervisors also undertake regular toolbox talks during shifts and there are monthly safety inspections of areas where work is occurring. In addition, all operational areas are subject to an internal safety audit twice a year.



The company uses the VRA training facility for staff and this includes simulation exercises. While the nature of the training varies according to the job description, typically it involves 1-2 months training and then a return to work followed by another period of training and so on; training periods for staff involved in live installations take up to two years. All staff are subject to ongoing training depending on their tasks and a schedule is defined by the HR department annually. All staff are trained in first aid with safety representatives undergoing more intensive training. In the event of an incident requiring treatment, staff are transferred to the nearest hospital; all staff including contract
ors are afforded medical aid. So as to inculcate a culture of safety at work, GRIDCo initiates a week long safety week every October to raise awareness among staff. Information on lost time injuries made available for the last 3 years indicates that there have been 6 such injuries associated with GRIDCo and 4 with contractors over this time period; no fatalities have occurred within the company, though there has been 1 associated with a contractor.



Personal Protective Equipment (PPE) is supplied to all staff and the requirements thereof are defined according to a risk assessment undertaken for each job description. When purchasing equipment, specific standards are defined in the tender documentation for the quality of PPE and testing of equipment is undertaken upon receipt to confirm quality specifications are adhered to e.g., whether insulation is effective.



In accordance with the Labour Act (2003) there are specific requirements contractors need to comply with. Equally, all tenders issued by GRIDCo require compliance to the company safety requirements if working on an existing operation e.g., transmission line or substation. In the case of the latter, the construction contractor needs to submit their OHS plan to GRIDCo for review and this applies similarly where there are tenders for new works. Further, in accordance with the Labour Act, GRIDCo appoints a Project Manager for each every project where a contractor is appointed who monitors contractor OHS performance. During the appraisal a site visit was undertaken to a new substation under construction and the observed use of PPE on site was excellent; this also applied to the site where the VRA power station was being constructed. GRIDCo is currently developing a specific contractor OHS manual that is to be applied to new and existing operations.

An environmental monitoring plan and EMP is included in the EIA for the power station and the Environmental Permit issued by the EPA includes specific requirements to manage impacts related to dust, vehicular traffic, noise and soil erosion and the use of hazardous materials. GRIDCo will be responsible for constructing the substation and transmission lines, however will need to comply with conditions as defined in the Environmental Permit for the construction phase. In accordance with the environmental permit there is ongoing monitoring of the project and the EPA also undertakes an annual audit of the activities.



To ensure a standardized approach to the management of environmental impacts during construction of this project and future activities, GRIDCo will develop and implement a generic EMP. This will negate the need to have individual EMP’s for each project and rather the generic EMP can be applied and then amended depending on the project under consideration; this is defined in the project ESAP.



New transformers and general equipment required for operations are stored in 4 designated warehouses. There is no dedicated transformer workshop / storage area and all repairs are undertaken in the field and if transformer oil needs to be cleaned or changed, this is undertaken by a mobile unit. All transformers are fitted with bunded oil sumps located below the transformer which can accommodate 110% of the total oil capacity of the transformers. To formalize the management of refilling and maintenance operations and the cleanup of oil or fuel should it be required, GRIDCo will develop a procedure for these activities taking into account the need for the safe disposal of contaminated material; this is defined in the project ESAP.



According to management there are no PCB’s in any transformer oil and prior to GRIDCo being established, the EPA formed a task team to identify transformers with oil containing PCB’s so as to eliminate these. Used transformer oil along with that generated by workshops is disposed of in a method that is agreed upon at the time with the EPA, though typically involve destruction. Aside from used paint containers, oily cloths and the like no other hazardous materials are generated by the company. Used equipment and materials such as scrap is disposed of in accordance with the Ghana Procurement Act. This requires agreement from the CEO that the materials may be disposed of and then agreement via an internal Board of Survey (inclusive of an environmental representative) on the approach to disposal which could be sale, donation or destruction. There is no clearly defined approach / procedure to the management of solid and liquid wastes and thus as defined in the project ESAP, GRIDCo will develop and implement a waste management plan to be applied to all activities associated with operations and decommissioning.



The company has 3 vehicle workshops located in Tema, Takoradi and Kumasi respectively. The company ha
s a total of 314 vehicles comprising light and heavy vehicles. Vehicles outside of their warranty period are serviced at the workshops. New oil is stored in drums at the workshops and used oil within bunded storage areas with disposal of the latter defined as above. All the company’s refueling requirements are currently undertaken by Total at existing fuel filling stations and there are no fuel storage tanks at any facilities.



Water is supplied via the Ghana Water Company in the differing areas in which operations exist and water dispensers are at all locations and available to all personnel. In areas such as Tema and Takoradi sewerage is disposed of via the municipal sewerage system and in areas where such systems do not exist, via septic tanks.



The average total consumption of fuel is 928, 000 liters per annum and the total kW/h consumed by all the differing facilities is 5,564,000 per annum. Based on these figures the total CO2 emissions generated by GRIDCo per annum is 3,390 tons.



Air modeling undertaken for the power plant indicates compliance of ambient air quality with the national requirements and those of the World Bank Group (WBG) Environmental, Health and Safety (EHS) Guidelines. A noise assessment was also undertaken for the power plant and while the predicted noise levels are below that defined for industrial areas in the national requirements and WBG EHS Guideless (70 dBA), the impact on communities has not been well been defined. As per the permit conditions though the noise levels in adjacent communities needs to be 55 dBA during the day and 48 dBA during the evening which is generally aligned with the requirements of the WBG EHS Guidelines for such areas.



For the most part all vegetation clearing required for the right of way associated with transmission lines and in the vicinity of the substations of applicable is undertaken manually. Thus limited pesticides and herbicides are utilized. However, GRIDCo will compile and implement a plan to ensure all pesticides and the like used in any operations are aligned with the requirements of the WBG EHS Guidelines; this is defined in the project ESAP.

Stakeholder engagement by GRIDCo is typically limited to the development phase of projects including construction. Further, aside from relevant authorities, the focus is on communities potentially affected by the project. All new transmission lines require an EIA undertaken by external consultants and consultation on projects is undertaken within this context and takes the form of one-one meetings, focus group meetings and public meetings. In accordance with national legislation EIA documentation is made available for a period of 30 days prior to the relevant department taking a decision on the project. In addition, a public hearing may also be convened. However as defined above there is no clearly defined and consistent approach to stakeholder engagement including a grievance mechanism and thus the company will develop and a Stakeholder Engagement Plan inclusive of a grievance mechanism.

Stakeholder engagement for the Kpone power plant inclusive of the sub-station and transmission line section was conducted by VRA and their consultants as part of the EIA process. This involved identification and consultation with various interested and affected parties including local and national authorities, land users and representatives from adjacent properties. This consultation took the form of one-on-one meetings with stakeholders and there was a public hearing on 29 April 2010 which was advertised in national newspapers. As part of this process the EIA documentation was also made available for comment for a period of 30 days. The latter process was repeated on 30 May 2012 when there was a subsequent public meeting as the project was being registered as a Cleaner Development Mechanism project; this also required the EIA documentation to be disclosed. Both the public hearing and the public meeting were attended by authorities, community members residing in the area and the traditional authorities.

This ESRS document and companion ESAP, the EIA documentation and Environmental Permit will be available at GRIDCo’s offices located in Tema as per the contact details below and the information will be posted on the World Bank Infoshop.


Contact person: Rev. S.F. Kwofie
Physical address: GRIDCo Engineering Office, Tema
Postal address P.O Box CS 7979 Tema, Ghana
Phone: +233-30-3304818
Facsimile: +233-302-676180
Email mailto:sfkwofie@gridcogh.com

Broad Community Support is not applicable for this project

No	Description of the Action Item	Anticipated Completion Date
Performance Standard 1: Assessment and Management of Environmental and Social Risks and Impacts
1	Develop and implement a generic Environmental Management Plan to be applied to all construction activities managed by GRIDCo or its contractors.	1 March 2014
2	Develop and implement procedures for inclusion into the GRIDCo Framework for Environmental and Social Management of Bulk Transmission Line Projects in Ghana related to the following; i) refilling of transformers with oil and maintenance of the transformers to ensure appropriate handling and disposal of hazardous materials and, cleanup of spilled hazardous materials; ii) solid waste management during operations and decommissioning; iii) the management of pesticides and insecticides aligned with the requirements of this Performance Standard; and iv) chance find of cultural artifacts during construction or operations.	1 March 2014
3	Align the existing procedure related to land acquisition and involuntary resettlement with IFC Performance Standard 5 objectives.	1 March 2014
4	Develop and implement a procedure to ensure screening of all new projects against the requirements of this Performance Standard 6.	1 March 2014
5	Develop and implement a Stakeholder Engagement Plan inclusive of a grievance mechanism to be applied during construction, operations and decommissioning.	1 March 2014
Performance Standard 2: Labor and Working Conditions
6	Develop and implement a mechanism whereby employees may raise grievances anonymously and communicate this to employees.	1 March 2014
7	Develop and implement a procedure inclusive of monitoring requiring; i) contractors providing ongoing services to GRIDCo; and ii) contractors involved in construction of GRIDCo activities, to comply with the relevant requirements of this Performance Standard.	1 March 2014