IFC's appraisal considered the environmental and social management planning process and documentation for the project gaps, if any, between these and IFC 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 implementation of these measures, the project is expected to be designed and operated in accordance with Performance Standards objectives.

Environmental and Social Management System

 Scatec Solar, as the main Sponsor of the Project and EPC and Operation and Maintenance (O&M) contractor, has a sustainability framework that incorporates among others local development, stakeholder engagement, environment, health and safety, and labor conditions. The corporate Environment, Health, and Safety Policy (2009) describes the company’s commitment to the protection of the environment and people, and the safety of its employees. The policy requires compliance with applicable laws and relevant health, safety and environmental standards. The corporate policy applies to all aspects of its operations: construction, operation and maintenance; and is communicated to employees and other stakeholders. An Environmental and Social Impact Assessment (ESIA) was prepared by a consulting firm in 2016, and an Environmental and Social Management System (ESMS) framework is presented in the ESIA. As indicated in the ESAP (action #1a), Segou Solaire will develop a project-specific ESMS that will include the followings: (i) an overarching E&S policy that will indicate who within the client’s organization will ensure implementation and maintenance of E&S programs and be responsible for their execution; (ii) identification of risks and impacts; (iii) management programs/procedures for environmental and social aspects, including occupational health and safety; (iv) organizational capacity; (v) emergency preparedness and response; (vi) monitoring and review; and (vii) stakeholder engagement.

Identification of Risks and Impacts

According to the ESIA, during the preparation and construction phases, anticipated negative impacts are as follows: deterioration of air quality, noise and vibration, vegetation removal (about 100 trees will be removed and compensated), increased risks of traffic accidents, OHS, influx of workers and job-seekers with associated risks of HIV/AIDs and other illnesses, inflation of prices of basic goods, economic displacement of 74 people who will lose farmland and residential land  (55 within the footprint of the plant; and 19 within the transmission line area); and loss of access to pasture and medicinal plants. During the operation phase, negative impacts will include: noise and vibrations caused by maintenance, potential impacts on groundwater due to panel cleaning operations, and traffic safety. Positive impacts during both phases of the project include employment opportunities, stimulation of economy, improvement of life quality, public infrastructures and services, electricity production, development of new businesses, and reduction of GHG emissions.

Management Programs

Organizational Capacity and Competency

As indicated in the ESAP (action #1c), during the preparation and construction phases, Ségou Solaire will have an Environment, Health, and Safety (EHS) Manager and a Community Liaison Manager on site. These positions will be supported by the EPC contractor’s own EHS Officer and Community Liaison Officer. During operations, only the sponsors’s EHS Manager and the Community Liaison Manager will be on site. The EHS Manager will develop the ESMS and will ensure its implementation in compliance with requirements of IFC’s environmental and social performance standards, and management programs identified in the ESMP, and ESMS. The EHS Manager will also make sure that the EPC’s ESMS is in line with this Performance Standard. The EPC contractor’s EHS Officer will support the EHS Manager and will ensure that sub-contractors comply with EHS requirements as defined in IFC’s PSs, the ESMP, and the overall ESMS. The Community Liaison Manager will coordinate and supervise interactions with local communities. He will ensure that all social related management programs of the ARAP, ESMP and ESMS are fully implemented. This position will be supported by the EPC contractor’s Community Liaison Officer who will be responsible to coordinate and facilitate local employment, build rapport with the communities, and implement the communication program.

Emergency Preparedness and Response

As set forth in the ESAP (action # 1a), Scatec Solar will prepare an Emergency Preparedness and Response Plan. The plan will include the following elements: procedures for shutting down equipment; and production and evacuations procedures, including a designated meeting place outside the plant. It will also include specific training and practice (simulations and drills with periodicity), schedules and equipment requirements for employees who are responsible for rescue operations, medical duties, threats and incident responses. As part of the plant’s EHS inspection, the fire-fighting system will be inspected on a regular basis. In coordination with local fire brigades, neighboring farmers and surrounding companies, the assigned company’s security team will undertake periodic fire drills.

Monitoring and Review

Human Resources Policy and Procedures

During the construction phase, the EPC company, Scatec Solar, will employ between 150 and 200 people, including contractors and those responsible to build the transmission line and the road. During the operational phase, about 100 people are expected to be employed (7 permanent technicians and engineers, 15 permanent non-armed guards, and about 80 temporary workers for cleaning and maintenance).  Local workers will be hired and trained for non-technical jobs. In Mali, the legal age for work is 14 years (Law no 92-020). Scatec Solar will ensure that no person under the age of 18 years is employed during construction or operations of this project. In line with the Malian labor law, Ségou Solaire and Scatec Solar will develop Internal Regulations and each worker will be entitled to work insurance through the National Security Bureau (“Institut national de prévoyance sociale’’).

As set forth in the ESAP (action # 2a), Scatec Solar as EPC and O&M contractor will develop a Human Resources (HR) Policy and procedures for the construction and operations phases that will cover all type of workers, including direct workers and contracted workers. At a minimum, the HR Policy will include the following provisions: working relationship; working conditions; terms of employment; workers’ organizations; non-discrimination and equal opportunity; grievance mechanism; prohibition of child and forced labor in its direct operations; and occupational health and safety. The HR Policy will be communicated to all new employees during the induction process. Scatec Solar will also ensure that sub-contractors maintain an HR Policy and that each employee has a written contract in line with IFC’s requirements.

Occupational Health and Safety

The ESIA includes a detailed description of OHS risks and impacts during construction, operations, and decommissioning, with a series of preventive measures. The main risks and impacts will include heat exposure, traffic safety, exposure to welding light and fumes, risks of HIV/AIDS and other illnesses. As referenced earlier under PS 1, Scatec Solar will develop and implement the ESMPs for the different phases of the project. As required by the Malian labor law, Scatec Solar will also set up a Health and Safety Committee. According to national regulations, this Committee is responsible to notify the Ministry of Labor in case of fatalities, severe work accident, or occurrence of hazardous working conditions; investigate all accidents; implement work space inspections and propose preventive measures; and conduct awareness raising among employees related to OHS issues. Two key members of this OHS Committee will include both the developer’s and the contractor’s EHS Managers.

Scatec Solar does not intend to provide workers accommodations, and all workers will be lodged in the neighboring communities of Pélengana Were and Bougouni. Provided that Scatec Solar decides to offer accommodations, it will ensure that standards for workers’ accommodations will be compliant with the IFC and the European Bank for Reconstruction and Development Guidance Note on Worker Accommodation Process and Standards (2009).

GHG Emissions

 The project is expected to have a positive environmental impact in terms of GHG emissions as it will provide a renewable source of electric power and reduce the potential growth in fossil-based electric power generation and related local air pollutants and greenhouse gases. The project is expected to avoid about 45,000 t CO2 equivalent per annum.

Water and Energy Consumption

Water will be sourced from ground aquifers via a borehole during construction and operations. Water will be used for sanitary purposes and to clean the panels during operations. It is estimated that about 20,000 L/month will be used during construction, and about 24,000 L/month during operations. As indicated in the ESAP (action #3a), the quantity of water required by the company shall be fully assessed as well as the potential impacts on other users. Should water testing show that groundwater is not of potable quality, then treatment or alternative source of potable water will need to be identified and shown to be sustainable. Following the assessment, a water management program will be developed and implemented. During construction, there will be a generator on site and the electricity needs are estimated at 35 kWh/day.

Wastes

During construction, waste will consist mostly of wood residues (about 4,000 pallets) and packaging material (about 4 m3 plastic and 10 m3 cardboard), metal (about 500 kg), domestic waste (about 7,000 kg), and used oil. During operations, waste will be mostly generated at the office, along with mineral oil from transformers, and sanitary effluents. During decommissioning, waste will consist of used panels, metals, wood residues, used oil, and concrete. As set forth in ESAP, as part of the ESMS (action #1a), a waste management procedure will be developed and implemented by the EPC contractor Scatec Solar. The procedure will include characterization of waste by type, quantities, and potential use/disposition establishment of priorities based on a risk analysis that takes into account the potential EHS risks during the waste cycle and the availability of infrastructure to manage the waste in an environmentally sound manner; opportunities for source reduction, as well as reuse and recycling; procedures and operational controls for onsite storage; and final disposal.

Only sanitary wastewater will be generated. As there is no sewage collection network, a septic system will be used, designed and installed in accordance with local regulations to prevent any hazard to public health or contamination of land, surface or groundwater.

Hazardous Materials Management

Petroleum products will be the main source of hazardous material. Mineral insulating oils will be used to cool transformers. These oils will be handled by trained personnel to ensure that manufacturers’ recommendations are strictly followed. Provision of secondary containment, drip trays or other overflow and spill containment measures will be implemented in designated areas. Vegetation control will be carried out manually without any pesticide use. The waste management system described above will include used hazardous materials and will address issues linked to waste minimization, generation, transport, disposal, and monitoring.

Community Health and Safety

 The plant will be located in a rural area in the vicinity of two small communities. As such, potential adverse impacts from construction will be increased traffic, which may represent a risk for the local population. This risk may exacerbate existing traffic risks. Transport employees and sub-contractors will be required to produce a valid driver license. As set forth in the ESAP (action # 4a), Scatec Solar will develop and implement safe driver and transport safety vehicle procedures, including training sessions for its own and third party haulage contractors, especially during construction.

Security Personnel

At the moment of appraisal security arrangements had not been made but it had been confirmed that security will be provided by a private firm. Armed guards may be posted on site. Before hiring security personnel, Scatec Solar will make reasonable inquiries to investigate the employment statement and other available information, including any criminal record, of individuals or firms and will not employ or use any individuals or companies that have abused or violated human rights in the past. PS 4 requirements will be strictly enforced.

 As set forth in the ESAP (action #4b), Segou Solaire will assess the security risks and develop appropriate policies and procedures for managing the project’s use and relationship with security personnel, whether public or private (including either an in-house or third-party guard force), in light of IFC Performance Standard 4. If any armed guards are envisioned in providing security for Company personnel, assets, and/or installations, the risk assessment and resulting procedures should reflect appropriate measures (e.g., vetting of personnel, a written code of conduct, training, procedures in the event of any incident or alleged violation) to ensure effective oversight and accountability for the guard force.

Stakeholder Analysis

The environment in which the project is located is a semi-urban environment presenting similar social characteristics and demographics to those of medium-sized towns in Mali. However, the power plant itself is positioned in a semi-rural environment where the land is primarily used for agriculture. The total population of the Pélengana commune in 2005 was 68,497 inhabitants, of which 34,405 women and 34,092 men, living on a territory of almost 200 km². The ESIA and ARAP process identified key stakeholders that may be affected or interested in the project, including vulnerable groups. Directly affected people (see list of impacts under PS 1) include local communities of Pélengana Were and Bougouni, among which farmers, cattle herders, women’s groups, youth, and local authorities (e.g. mayor, village chiefs), as well as potential host communities (Fahira, Tiguini, Kitiola, and Douga). Other interested stakeholders include population of Soro Wèrè and Nioroko Wèrè, staff from community health and education facilities, and representatives of the different Ministries, including the ‘’Office du Niger’’.

Stakeholder Engagement Plan

Ségou Solaire drafted a Stakeholder Engagement Plan in line with IFC’s requirements. Ségou Solaire will coordinate stakeholder engagement activities with the EPC contractor and a local relay committee made up of local authorities and other interested parties. These activities will be directed towards the local population, workers and job-seekers associated with the project, etc., and will emphasize such key themes as: recruitment and job training, resettlement options, support for vulnerable people, health, safety, grievance redress, etc. These activities will be managed from an office located a short distance from the project site. Ségou Solaire will maintain and adapt their stakeholder engagement activities over the entire life of the project (action #1a).  

Consultation

Several consultations were conducted during project’s ESIA. During these events, from October 10th to 15th, 2015 and on November 27th, 2015, the project impacts, including those related to resettlement, were discussed. The broad consensus among stakeholders is that the project impacts are likely to be positive, including: (i) increased electricity production, which could improve the development of industry in the Ségou region; (ii) promotion of employment and a wider range of taxes to refill the town hall coffers for the local electorate; (iii) promotion of village development and employment of young people and women, and multiple potential support points for traditional authorities.

Grievance Mechanism

Ségou Solaire’s Stakeholder Engagement Plan includes a grievance mechanism for individuals, communities and companies who have concerns, complaints or claims. The key aspects of this mechanism are the immediate receipt of acknowledgment, and the maximum 30 working days response time. A grievance form will be available in all affected communities, at the plant and at the nearby company-sponsored recruitment office and will contain all information that would be required for such a grievance mechanism and stakeholders will be made aware of this form. The Community Liaison Manager and Officer will also be available to discuss any grievances verbally and record it if necessary. This Grievance Mechanism will be fully explained to PAPs at the outset.

Contact Person: Mr Ibrahim Togola

Company Name: c/o Scatec Solar WA

Address: Banankabougou Sema, Logement BH/13, BP E 3550 Bamako

Email: ibrahim.togola@gmail.com

Phone: +223 66 74 26 09