Environmental and Social Assessment and Management System
The sponsor has developed a corporate Integrated Management System (“IMS”) that has been certified ISO 9001:2015 (Quality), ISO 14001:2015 (Environment) and ISO 45001:2018 (OHS) in April 2021. It has further developed a set of corporate policies applying to social sustainability, anticorruption, anti-money laundering, a corporate quality health safety and environmental manual that apply to all AMEA projects, including Zina Solaire. The social sustainability policy expresses the company’s commitment to building up a responsible and sustainable business and to aligning with Good International Industry Practice (GIIP). The policies are further articulated in the project QHSE manual, ‘the Quality Health Safety and Environmental (QHSE) Employers Requirements’, which forms the basis for its ESMS. The manual details processes and standards to be implemented during construction and operation to provide adequate management and supervision of all E&S issues.
The project has established a ‘services contract’ with the EPC and O&M Contractor which requires them to abide by its corporate and project specific requirements including Zina Solaire’s ESMS. The QHSE Employer Requirements has subsequently been developed into E&S processes, requirements, and commitments. This manual is an integral part of the services and supply agreement with the Contractor and shall in turn be cascaded down to Subcontractors. It provides that the Contractor is to develop and maintain its own project-specific quality, health, safety, environmental, social and security (QHSE) management system at all times. The document further provides that the Contractor’s ESMS will be composed at a minimum of an ESMS manual, QHSE policies, a legal register, records of permits, licenses and assurances. As per ESAP #1a, specific plans are to be developed by the Contractor and subcontractors for proper planning, implementing, monitoring and improving their quality, health and safety, social and environmental management.
Identification of Risks and Impacts
An Environmental and Social Impact Assessment (ESIA) was prepared for the project by a local consultant in 2011. As IFC got involved in 2015, an international firm updated the documents to meet its Environmental and Social Performance Standards requirements and GIIP (for the transmission line and for the plant respectively). During construction, environmental and social risks and impacts will include air emissions and noise; OHS; community safety; vegetation removal (approximately 1,200 trees and shrubs will be removed for the plant and transmission line); economic displacement of about 80 people who will lose farmland (59 PAPs for the transmission line and 21 PAPs for the plant); and loss of access to pastureland, to medicinal plants, and hunting grounds. During operations, risks and impacts are expected to include increased water consumption; erosion and dust generation resulting from vegetation removal; hazardous waste management (e.g. used oils); vegetation clearing operations that may disturb local communities; and OHS risk of electrocution.
To ensure risk is assessed for individual activities carried out by Contractors, the Sponsor has included a provision in the ‘QHSE Employer requirements’ document for Zina Solaire, to develop and maintain a written Risk Assessments & Method Statements to identify, evaluate and decide on precautions required for the mitigation of hazards and risks in the workplace during the construction phase. These assessments are reviewed by the Company EHS Director or his delegate for compliance with all legal requirements.
Management Programs
The Sponsor has documented policies on Sustainability, Health, Safety and Corporate Social Responsibility which will be extended to the Zina Solaire project. The ESIA presents in further details the E&S management framework, monitoring requirements and mitigation measures applicable to the construction (which starts by a site preparation phase) and operations phases of the project for both the plant and transmission line.
During the site preparation phase, the Environmental and Social Management Plan (ESMP) aims to minimize negative impacts related to land expropriation, cover degradation and air pollution. This period is characterized by the preparation of the site and compensation for agricultural land losses and will end after the clearing and opening of the main access road and the site installation. The Company has finalized the resettlement action plan and paid out compensations to the persons affected by the project (PAPs) for total or partial loss of property, assets and income in a fair way and prior to expropriation or damage caused by construction activities. The Stakeholder Engagement Plan supported by the livelihood restoration plan are designed to facilitate the involvement of local populations and organizations in the implementation of compensation and give special attention to the needs of the most vulnerable among the displaced. The project will develop a waste management system for its different waste streams (ESAP #1a). During the 12 to 16 months of the power plant construction phase, the ESMP which is constantly being updated, will aim to enforce environmental protection measures, to reduce air pollution and the risk of occupational accidents, particularly eye and lung diseases, to reduce the risk of water pollution from accidental hydrocarbon spills; to fight erosion, degradation and possible soil pollution; to minimize the impact of the project on terrestrial fauna, avifauna and vegetation and again, to facilitate the involvement of local people and organizations in the implementation of the project. During the operations phase, the specific objective of the ESMP will be to further strengthen these environmental protection measures to enhance the positive impacts of the plant's operations as mentioned under ESAP #1a. In the closure and decommissioning phase, the ESMP will focus on enhancing the positive impacts of plant decommissioning and ensuring proper disposal of waste and materials resulting from site closure.
The health & safety system will include a site mobilization plan, an occupational health & safety management plan, an emergency preparedness and response plan, a hazardous material management plan, community H&S and worker influx plan, a traffic management plan and a training management plan. The environmental management system shall include at a minimum a noise management plan, an air quality and dust management plan, a soil and groundwater management plan, a water management plan, a waste and wastewater management plan, a biodiversity management plan. The social management component will include a human resources management plan and a code of conduct, a gender equality/Gender Based Violence (GBV) plan, a worker grievance mechanism, a stakeholder engagement plan including a community grievance mechanism, employment and procurement management plans and an accommodation plan. The employee and community GMs shall be sensitive to issues around GBV and will include clearly articulated disciplinary measures (related to the Code of Conduct) and a training for community and Human Resources staff on handling GBV.
Throughout the different phases of the project, the sponsor requires the Contractor to develop and maintain a project specific QHSE management system in place. Minimum plans required as part of this system include an ESMS manual, QHSE policies, a legal and a permit register. These main documents will be supported by environmental management plans (water, air quality, noise, waste, biodiversity and soil management), social management plans (Contractor’s human resources management plan, gender equality plan, workers’ grievance system, community grievance and accommodation plan); Health and safety management plans (site mobilization plan, occupational health & safety management plan, emergency preparedness and response plan, hazardous material management plan, community health and safety and workers influx plan, traffic management plan and training management plan). For this purpose, the Contractor has appointed a specialized E&S consultancy firm for the preparation of the management plans as per agreement. In relation to the Limited Notice to Proceed (LNTP), the consultant helped develop the HSE Management Plan for the LNTP works in compliance with the services contract. The plan sets out all environmental and safety precautions to be taken by the Contractor’s crews involved in the site preparation works. Key management measures outlined in this plan include general environmental and safety induction for the workers during earthworks or trees grubbing and felling, good practices during chain sawing, waste management, incidents reporting and emergency preparedness.
All management plans shall be project-specific and in full compliance with the requirement of IFC PSs and as included in the legal register. They shall be reviewed at regular intervals as agreed between the Company and each of the Contractors throughout the contract to ensure that it remains current and relevant to the works. The Contractors’ management plans shall also form the basis by which its management systems may be audited by the Company and by the lenders. The Company shall review and approve the management plans prior to the commencement of the works.
Organizational Capacity and Competency
At the sponsor’s level, the E&S structure is overseen by the corporate Head of QHSE, reporting to the Board. He has overall responsibility for the project Environmental, Social, Health and Safety risk and management programs. He is assisted by a corporate Social Specialist who is responsible for the social aspects of the project. This senior team has good capabilities to manage project sustainability issues and experience working with IFC and international best practices provisions and standards based on their experience working on other IFC projects.
At the project level, the Company E&S team is composed of the Health, Safety and Environmental (HSE) Manager, and the Social Specialist supervising a team of two Community Liaison Officers (CLOs). The HSE Manager oversees the implementation of environmental management plans as well as occupational and security management plans. He is also responsible for Contractors’ compliance audits. The Social Specialist with the two CLOs are responsible for the implementation of social programs including the Resettlement Action Plan, the Stakeholders Engagement Plan, the Livelihood Restoration Plan and the external grievance mechanism. The project E&S team has adequate qualifications, is familiar with local regulations and has experience working with international requirements and good practices. It is further supported at the corporate level by the group Head of QHSE and the group Social Specialist.
The EPC Contractor on its part will hire a qualified Environmental, Health & Safety (EHS) Officer before commencement of construction as per ESAP #1a, who will be responsible for the implementation of the ESMPs for the different phases of the project, in accordance with requirements of national laws and regulations and IFC E&S Performance Standards. This provision is underpinned in the QHSE Employer Requirements that during all project phases the EPC Contractor will have an EHS Officer on site. This Officer will serve as the primary contact for Contractor’s E&S matters, he/she will supervise and coordinate all EHS activities of the Contractor and ensure that subcontractors adhere to the same level of requirements.
Emergency Preparedness and Response
As set forth in the ESAP action # 1b, to be in line with requirements of IFC’s PS 1, Zina Solaire 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
The purpose of the environmental and social monitoring plan as outlined in the ESIA is twofold: monitor the project activities to ensure that all recommended mitigation and enhancement measures are implemented by the Company as well as its contractors and subcontractors; and follow-up on impacts caused to the most sensitive environmental and social components in order to evaluate the effectiveness of the measures. As part of its ESMS, the Company will adopt a structured EHS monitoring and reporting system on environmental, OHS and social impacts of its operations. The Company, through its E&S structure, will be responsible for monitoring the overall project E&S compliance. The Company is in the process of establishing specific procedures and will allocate resources based on corporate E&S policies and framework and project ESMS (ESAP#1a). Monitoring frequencies and methodology will be reflective of the risks and impacts identified by the ESIA and incorporated into the ESMS; monitoring data will be stored in a centralized database for monthly and annual reports.
The Contractor is responsible for monitoring compliance for their own activities and that of their subcontractors. Specific procedures with roles and responsibilities will be defined in the associated management plans (ESAP #1a) and approved at the sponsor’s level by the Head of QHSE prior to implementation. The project HSE Manager and the social team will be closely monitoring compliance of project activities and approved standards during construction and during future phases.
As stipulated in the Services contract and guided by the ESIA and ESMPs, the Contractor has the responsibility to collect environmental quality, health, safety, social and human resources statistics (including all types of training delivered to communities and incident records) on a monthly basis and report to the Company. Key Performance Indicators (“KPIs”) will be developed in view of the reporting and will include at a minimum a) Safety – Lost Time Injury Frequency Rate, Accident-Free Days; b) Resource Efficiency – Water Usage, Energy Usage; c) Staff - Retention and training days. The Company will report annually to IFC and will provide feedback to affected communities on at least an annual basis in relation to any impacts affecting them and associated mitigation measures.