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 6 – Biodiversity Conservation and Sustainable Management of Living Natural Resources
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards
PS7: Indigenous Peoples is not applicable as no communities in the project area are considered Indigenous Peoples according to the PS7 definition.

PS8: Cultural Habitat is not applicable as no known or recognized cultural heritage sites are located in proximity of Ivato airport. According to the ESIA two sites considered sacred by the communities are located at 150m and 400m away from Fascene airport but they will not be affected by the project construction and operations. As part of the construction management plans, the concessionaire has prepared and will implement a Chance Find Procedure.

As discussed above, the proceeds of this proposed investment will be directed to an expansion of capacity of Ivato airport within the existing airport footprint located in urbanized surroundings and to refurbishment work at Fascene airport. All project activities will be within the existing footprint of the two airports and will generally help improve the airport operations through the introduction of modern, low environmental impact facilities with improved management and operational procedures. While Fascene airport is located within Nosy Be and Satellite Islands Important Bird Area (IBA) and Key Biodiversity Area (KBA), which contains globally threatened and endemic species, the project will not result in any additional measurable adverse impacts on the biodiversity values of the IBA/KBA, as discussed under Performance Standard 6 section below. As such there will be limited E&S risks and impacts directly associated with IFC’s investment at the two airports. However, based on IFC’s assessment of the risks associated with the resettlement of approximately 70 households at the informal settlement of Fascene, to meet the government’s obligation under the concession agreement to hand over the concession free of settlements, the proposed investment is a Category A project according to IFC Policy on Environmental and Social Sustainability.

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.

Environmental and Social Assessment and Management System



Ravinala Airports is composed of world-renowned companies that have know-how and qualified human resources to manage the environmental and social aspects of the project. BBI and Colas Madagascar (Parent companies of the EPC contractor and members of the consortium) are experienced in managing EHS risks and impacts of their construction activities. The two companies have integrated management systems based on ISO 9000:2008 (certified), ISO 14001 and OHSAS 18001:2007 (certified). The consortium has adequate capacity to manage project related EHS aspects, and a full-time Quality, Health, Safety, Environment (QHSE) engineer will be assigned to the project.



With respect to the operations of the airports, the environmental and social management system of ADPM is consistent with the one of Aéroports de Paris, its parent company. As such, it is expected that Ravinala Airports will have the needed capacity to manage risks and impacts associated with the project operations for which the concessionaire will introduce and operationalize good industry practice, including monitoring of noise, air and water quality, airport safety (including risk of bird strikes), and energy efficiency.



Prior to the construction phase, the concessionaire will develop an Environmental and Social Management System (ESMS) for the two airports to manage EHS aspects during the construction and operational phase. It will be based on the certified ESMS structure of the individual partners of the consortium (ESAP item # 2).



Identification of Risks and Impacts



The concessionaire commissioned Egis, a French consultancy firm, to prepare, as per applicable national legislation, the environmental impact assessment documents including an environmental audit of the existing terminals facilities; these have been approved by the national environmental authorities (ONE) and environmental licenses were obtained in July 2016.



To complement the studies required by the national law and to meet Performance Standard requirements, IFC requested the concessionaire to prepare two additional ESIA studies for the construction and improvements at the two airports. The ESIAs, drafted by Egis, addressed both Phase 1 and Phase 2 works. As Phase 1 (the project) will take place entirely within existing footprint, the ESIAs identified limited E&S impacts related to the refurbishment of the operational runways and other landside facilities, including construction material transport from local quarries, and to the airport operations. A quarry (Louria) will be reopened to supply construction material needed for the works at Fascene airport. As an associated facility to the project the quarry has to go through a separate ESIA process and obtain an environmental permit. The quarry will be operated by Colas Madagascar.

Risks and impacts will be readily addressed through mitigations and implementation of good international industry practic
e.



Management Programs



The ESIAs have presented a framework E&S management plan (ESMP). In addition to implementation of good practice construction EHS requirements, and in consideration of the location of the two airports, relevant measures of the framework ESMP include (i) the preparation of an invasive species management plan, and (ii) the development of emergency plans.



The concessionaire will develop and implement, as per ESAP item #3, relevant management plans for the construction phase including: (i) contractor’s management plan (including HSE and labor management); (ii) Construction Environmental Management Plan, Site Management Plan and Emergency Plan; (iii) Site Waste Management Plan; (iv) Hazardous Waste Management Plan; (v) Spill Preparedness and Response Plan; (vi) Dust Management Plan; (vii) Traffic Management Plan; (viii) Construction Noise Management Plan; and (ix) Effluent Management Plan. Six months prior to completion of refurbishment work, the concessionaire will develop Operational Environmental and Safety Management Plan.



Organizational Capacity and Competency



The EPC contractor has the needed EHS organization and capacity to comply with Performance Standards. An EPC Project Director in charge of managing the construction will be appointed at least one month before the concession will be handed over to the concessionaire. The EPC Project Director will be assisted by a team, including the Quality, Health, Safety & Environment Manager, Contracts Manager, Construction Manager, Technical Manager, and Administrative and Cost Control Manager.

Ravinala Airports will recruit an environmental health safety community liaison (EHSC) Manager who will report directly to the CEO of Ravinala Airports and will have sufficient human and financial resources to implement the E&S management programs for the concessionaire. The consortium will appoint a community liaison officer (CLO) for Ivato and will do the same for Fascene (ESAP item # 1); the CLO at Fascene will be responsible for liaising with the affected community and the government on the resettlement process and for implementing the Supplemental Resettlement Plan as described under Performance Standard 5 below.



Emergency Preparedness and Response



There is an emergency plan at Ivato airport defining the protocol for decisions and communications between ADEMA, the current public operator, and external parties, and emergency response procedures in the event of an airplane crash, bomb threat, act of unlawful interference, fire, handling of dangerous goods, contagious diseases and natural disasters. There is currently no emergency plan for Fascene airport, although the operator of the fuel tank farm (Total) has developed a specific emergency preparedness and response plan (EPRP) for its facility. The existing emergency plan for Ivato will be reviewed against good international industry practice and updated as needed, and an EPRP for Fascene airport will be develo
ped by Ravinala Airports. Both plans will include procedures for dissemination of relevant information on emergency preparedness and response and to assist and collaborate with the affected communities and the relevant government agencies in their preparations to respond effectively to emergency situations, as indicated in ESAP item #4.



Monitoring and Review



The concessionaire will develop a monitoring program for the operations at the two airports including (i) effluent quality, (ii) noise levels at sensitive receptors, (iii) encroachment within the security areas, (iv) water and energy consumption, (v) spills and leakages of fuels and waste oils, and (vi) biodiversity as further discussed under Performance Standard 6 below. During the construction, it will be the responsibility of the EPC contractor to carry out the monitoring program regarding the construction activities on the work sites in coordination with the EHSC Manager and it will be the responsibility of Ravinala Airports through the EHSC Manager to carry out the monitoring program regarding the airport operation activities. The EHSC Manager of the Concession will produce a consolidated monitoring report for the airport operations and the work sites, and the Quality, Health, Safety & Environment Manager of the EPC contractor will coordinate with the EHSC Manager for this purpose. Once the Phase 1 construction activities are completed, it will be the sole responsibility of Ravinala Airports through its EHSC Manager to carry out the monitoring program.



Results of the monitoring program will be reported to senior management and inform the review and update of the management and mitigation measures described in the management plans.

Employment and Working Conditions



Ravinala Airports will recruit part of their staff from the airport staff currently working for ADEMA. All 126 employees working at Ivato and 24 out of the 44 employees at Fascene will be offered the option of transferring from ADEMA to Ravinala Airports. The remaining staff at Fascene will continue working for ADEMA and be in charge of air navigation, lighting maintenance and fire brigade. In addition 45 out of 151 staff currently working at the central level of ADEMA will be offered to transfer based on a competitive process. Terms and tenure of contracts as well as responsibilities and job titles will at least be maintained at the same level, as required by the Madagascan labor law (article 12). According to the collective bargaining agreement, it is optional for ADEMA’s employees to accept the transfer. In the event that an employee does not accept the transfer, he/she will be offered by ADEMA another position within the organization.



ADEMA is currently establishing 40 new positions in addition to the positions that will be transferred to Ravinala which will create more options for those who are not interested in transferring to Ravinala Airports. The transfer of the concession will therefore not lead to any retrenchment. The concessionaire will document the transfer process and the allocation of all staff and report to IFC upon finalization of the transfer (ESAP item #6).



The collective bargaining agreement signed between the worker’s representative and ADEMA on April 2015 will also govern the employment relationships at Ravinala Airports. The workers’ representatives have been involved in the transfer process and will continue representing the workers after the transfer until the next election which will take place at end of 2016.



The current employment and working conditions at ADEMA are aligned with the national labor standards. The consortium is in the process of developing its Human Resource (HR) policies and procedures and a grievance mechanism for employees. The grievance mechanism will be developed and implemented to ensure that employees are able to submit grievances including anonymous grievances without repercussion. A grievance mechanism will also be provided for employees of the EPC contractor and its subcontractors, through a grievance mechanism provided by the EPC contractor and the individual subcontractors. HR policies and procedures, including the grievance mechanism, will be fully aligned with Performance Standard 2 (ESAP items #7 and #8).



Contractors’ Management



At peak of construction there will be approximately 180 workers at Fascene and 600 workers at Ivato. The employment conditions of the construction workforce will largely be governed by the standards of Colas Madagascar and BBI and will be consistent with the requirement of Performance Standard 2 and specified by the HR policies and procedures (ESAP item #8).



Service companies are used for embarkation /
disembarkation, maintenance and repair of aircraft, cargo services, aviation, aviation security and the border administrative services. At Ivato there are 82 service companies, while 9 service companies are under contract at Fascene. All the contracts with these companies are to be maintained. When these service companies act as subcontractors for Ravinala Airports, as part of the HR policies and procedures required under ESAP item #8, the concessionaire will do its best effort to ensure that the employment and working conditions are aligned with Performance Standard 2 for the existing contracts and ensure that all new contracts commits the service providers to comply with the standards of Performance Standard 2.



Occupational Health and Safety



The development of a site management plan, a safety & health plan, including emergency response, and hazardous material/waste management plans is obligatory under national law and will be part of the project EHS plan. Consistent with the legislative requirements, an Environmental Health Safety (HSE) Plan has been developed for Ivato and the concessionaire will prepare a similar plan for Fascene airport (ESAP item #3).



BBI is OHSAS 18001 certified and implements its health and safety standards on every construction work site they manage worldwide. EPC Contractor will put in place on the work site occupational safety and health procedures, including use of personal protective equipment and working procedures for various types of construction work and equipment operations. All construction workers will be provided with the necessary EHS training and personal protective equipment as required for their respective responsibilities and duties. The EPC contractor requires, as part of the subcontractor bidding process that bidders provide adequate proof of implementation of good OHS practices in order to be shortlisted for the work. Sub-contractors will be required to develop relevant work method statements, specifying measures to eliminate or reduce health and safety risks. All contracts with subcontractors will include a clause requiring compliance with the project EHS plan and Performance Standard 2. Safety induction meetings will be required, and incident statistics maintained. The concessionaire will ensure that health and safety will be addressed by each subcontractor and that health and safety staff will be present on site during working hours. A requirement to provide on-site first aid and emergency response capacity will be included.



The concessionaire will have the primary responsibility for all matters relating to occupational health and safety during the routine operations of the airports, including provision of personal protection equipment, fire and life safety equipment, potable and drinking water and sanitation, and periodic medical examinations for all employees according to their occupational exposure.

The electricity supplied by JIRAMA, a water service and electric utility company, is the main energy source of the two airports. At Ivato, the average consumption during the last 5 years has been 61,271 kWh per month.



JIRAMA also supplies water to Ivato airport and in the past 5 years, annual consumption fluctuated between a minimum of 17,266 m3 and a maximum of 33,301 m3.

Fascene airport uses ground water (approximately 5 m3 per day) from a 100m deep well and no interferences with community water wells are expected.



The EPC contractor will maximize the use of existing quarries for the supply of construction materials. The opening of new quarries will be considered only if the available reserves are insufficient, and will require the preparation of an ESIA, to comply with national legislation and meet IFC requirements. The ESIA will contain a rehabilitation plan. Reopening of an existing Louria quarry (exploited in the past) is currently planned for the construction material needed at Fascene airport.



Pollution Prevention



Investigations carried out by Egis to identify potential presence of contaminated soils at both sites detected the presence of some metals at a number of locations at Fascene airport, likely to be associated with the volcanic nature of the soils and possibly with the use of fertilizers. The concessionaire will ensure that soil and sediment testing will be included in the monitoring plan to allow for early detection of eventual changes in the baseline conditions.

The Government of Madagascar and the concessionaire will address the remediation of any legacy contamination which may be discovered during the construction phase, as defined by the Concession Agreement.



Air Emissions and Ambient Air Quality



The main air emission sources at the airports are: (i) aircraft operations during landing and take-off, emitting fuel combustion gases (carbon dioxide, nitrogen oxides, carbon monoxide, and to a lesser extent, sulfur dioxide and hydrocarbons); (ii) fuel handling and refueling of aircrafts (fuel vapors); (iii) ground support vehicles (exhaust gases); and (iv) waste incinerators. An ambient air quality measurement campaign was carried out in August 2015 to measure the concentrations of atmospheric pollutants (nitrogen dioxide, sulfur dioxide, particulate matter, and benzene, toluene, ethylbenzene and xylenes (BTEX)) at both sites. Concentrations of nitrogen dioxide and sulfur dioxide were detected within IFC guidelines. The only exceedances observed within the study area at Ivato and Fascene airports are those relating to particulate matter (PM10) which, as indicated in the ESIA, appear not to be attributable to the airport activities but associated with an airshed degraded by domestic combustion sources (cooking fires) and vehicular traffic, in addition to wind-borne particulate.



Noise and Vibration



Noise baseline levels were measured at several receptor locations in the surroundings of the two project s
ites in 2013 and in August 2015 to assess impacts of airport operations. Ivato airport currently receives around 20 flights per day, excluding general aviation, while Fascene airport receives only an average of two flights per day with no night time airplane movements. The results of the measurements at Ivato in 2015 showed noise levels in terms of Lden (day-evening-night equivalent level) slightly above the daytime guideline of 55 dB (A) at 4 out of 9 measurement points (position-0, close to runway 57.2 dB LAeq(06h-22h); position-1, group of houses on peninsula to the east with 57.2 dB LAeq(1h) - one aircraft noise event; position-3, residential area to the south with 61.2 dB LAeq(1h) - one aircraft noise event; position-8, residential area to the west with 60.0 dB LAeq(1h) – one aircraft noise event). Results for Fascene airport showed noise levels slightly above the daytime guidelines at 3 out of 5 locations (position-0, close to runway with 63.7 dB LAeq(06h-22h); position-3, Fascene village with 57.4 dB LAeq(1h); position-4 scattered houses south-west of position 1, which marks a group of houses close to the north-west edge of the runway).



The noise baseline measurements were supplemented by modeling to simulate and map noise levels due to airport operations. Modeling showed that for Ivato, areas where Lden was calculated as above 55dB (A) are limited to the airport surroundings. Simulations for Fascene airport estimated that daytime noise levels between 55 and 60 dB (A) could be reached at the informal settlement of Fascene, with only one house where noise impact may reach levels between 60 and 65 dB (A). It can be concluded that the project will not contribute significantly to any additional adverse impacts; the concessionaire has the needed technical capacity to assess and reduce noise impact due to airport operations, through optimization of ground operations and operational procedures according to good industry practice.



Wastewater Treatment



There is a combined wastewater collection and treatment system at Ivato airport to collect both sewage and industrial wastewater from the airport facilities. The wastewater treatment plant (WWTP) is not operational, resulting in the discharge of untreated sewage into the surrounding areas where cropland / rice pads are present. As part of the project, the concessionaire will build a new WWTP that will be designed and operated to satisfy national standards and IFC guidelines. To inform the design of the WWTP, the concessionaire will carry out a detailed assessment of all wastewater streams of the airport.



The sanitary sewer collecting sewage at Fascene airport is connected to sumps and septic tanks, while other wastewater streams from equipment maintenance and washing facilities are discharged directly into the ground or collected by the stormwater drainage that discharges into the environment with no treatment; recent testing of water samples collected from Fascene stream, a permanen
t stream which flows to the east of the airport, showed traces of hydrocarbons potentially associated with airport discharges. As part of the project, a new wastewater treatment plant will be installed at the airport to meet international standards.



Hazardous and Solid Waste Management



Although some waste streams are collected for recycling and reuse (for example, used oil and tires) and for composting, solid waste management practices at the two airports need improvement. In addition to solid waste disposal at external dump sites, basic waste incinerators are in use at each airport and they will need to be fully overhauled. As part of Phase 1 activities, the concessionaire is committed to upgrade the two incinerators and their operations to meet industry standards. Ravinala Airports will also develop and implement a solid waste management system that will focus on separation at source, composting of organic waste, and recycling, so that only a limited fraction of waste will need to be routed to the incinerators and waste disposal to external dump sites will be minimized.



Limited amount of hazardous waste such as waste oil, medical waste from a clinic that will be removed from within Ivato airport perimeter, and used batteries will be generated. Although it was not found during the environmental audits carried out, eventual asbestos containing material identified during demolition of existing structures will be handled, stored and disposed of in accordance with national requirement and good international practice. The concessionaire will ensure that other hazardous substances potentially present, such as transformer oil containing PCB, will be identified, handled and disposed of according to good international practice.



Hazardous waste generated during construction will be collected and stored at the sites prior to disposal to licensed facilities. Industrial non-hazardous and hazardous waste generated by airport operations including WWTP sludge, used oil, grease, tires, used batteries will also be adequately handled, stored and disposed of in licensed third party facilities. Concept of “duty of care” for hazardous /waste will be part of the ESMP.



Pesticide Use and Management



The concessionaire will develop and implement a procedure for the use of pesticides and agricultural chemicals for the maintenance of airport green areas, and will follow ICAO’s guidance on the use of mechanical operations (cutting and shearing).

Life and Fire Safety



A Life and Fire Safety (L&FS) audit for Ivato and Fascene terminals was carried out by a specialized consultancy, Exova Warringtonfire, in August 2015 and was used to identify compliance and areas of improvement. The concessionaire will design the new airport terminals and other facilities in Ivato in accordance with the life and fire safety code of Madagascar and an internationally accepted life and fire safety standard, consistent with relevant IFC guidelines. As part of the refurbishment of the existing terminals and other buildings with public access, the concessionaire will also ensure that the L&FS system at both terminals complies with the same IFC requirements. A suitably qualified professional will conduct a life and fire safety audit at work completion, as per the ESAP item #11.



During operations, the concessionaire will implement mandatory regular maintenance and testing of the life and fire safety systems to ensure that mechanical, electrical, and civil structures and systems are at all times in conformance with life and fire safety design criteria and required operational readiness. The systems will periodically undergo audits by the relevant government agencies. A Fire Safety and Evacuation Plan will form part of the Airport Emergency Plan.



Traffic Safety



For the Phase 1 works at Ivato airport the construction materials will be sourced from two existing quarries (Ambotimasina and PK13), located 3 km north and 20 km south of the airport, respectively. Relevant traffic, estimated at about one hundred 14.5-ton trucks per day over a period of 12 non-consecutive days, will use national roads 7 and 4 and Antananarivo main road intersections.



The construction material needed for Phase 1 works of Fascene will be sourced from quarry site (Louria), located about 3 kilometers south east of the airport. Traffic will use existing public roads, and is estimated at maximum about one hundred 14.5-ton trucks per day over a period of 30 non-consecutive days.



As construction related traffic with heavy-duty vehicles will use public roads and pass through villages, the EPC contractor will make sure that its subcontractor operates a tracking system for its vehicles and will conduct training in defense driving for project drivers, including sub-contractors. The EPC contractor will develop a Traffic Management Plan that all subcontractors will be obliged to follow (ESAP item #3).



Hazardous Materials Management and Community Safety



Airport operations include the storage and handling of fuels primarily associated with aircraft fueling activities as well as with ground support vehicles. Fuels at the two airports are stored in two aboveground tank farms. The main fuel storage area at Fascene is operated by Total and is used to store kerosene type-fuel Jet A-1 and AVGAS 100LL, a gasoline fuel for piston engine aircrafts, with maximum storage capacity of 190 m3 and 27.2 m3 respectively. At Ivato, the fuel tank f
arm, again operated by Total, has a storage capacity of 1000 m3 Jet A-1 and 40 m3 AVGAS 100LL; in addition there are three service stations for fuel distribution inside the airport. Both tank farms at Ivato and Fascene are located inside the airport land perimeter, but outside the scope of the concession. As per the local technical regulation, which are based on the French technical specification for fuel farms, there is a fixed exclusion zone of 15 m from the fuel tanks within which no occupant and public building are allowed.



Due to the location of the tank farms and the nearest residential houses, quantitative risk assessment and modeling were undertaken by the concessionaire to quantify likelihoods and impact areas associated with accidental scenarios involving pool fire and explosion. At Ivato, the nearest house is located approximately 70 m away from the fuel tanks and a public road runs next to the tank farm. At Fascene the nearest house is located at a distance of 25 m from the tank farm. The safety setback distances from the fuel tanks calculated by the model are 25m for an accidental scenario involving pool fires and 200m for a scenario involving an explosion at Fascene, while the same distances at Ivato are 30m and 345m, respectively.



The risk assessment concluded that at Fascene airport there are four buildings within the risk zone for pool fire which should be relocated to mitigate the risk. Of these four buildings only one is used for residential purpose. For the fuel farm at Ivato, there are no residential housing within the risk zone. The concessionaire will ensure that no new buildings will be built within the security zone.



The risk assessment also recommended mitigation measures for the potential explosion risk which includes: i) ensuring that the fuel tanks have adequate vent and pressure relief valves in place, ii) ensuring a review and potential upgrade of the EPRP of Total and integrate it into the overall emergency response plan of each airport; iii) disseminating the emergency and evacuation plans to the population potentially affected by explosion risk; iv) assessing the capacity of the existing structure in charge of emergency response including the airports’ dedicated fire brigade (“Service de Sauvetage et de Lutte contre l’Incendie des Aéronefs” (SSLIA)); v) developing measures to ensure public awareness near the perimeter of the tank farm. The concessionaire will ensure that the recommendations of the risk assessment are fully implemented, as needed in coordination with Total (ESAP item #4 and #10).



The concessionaire is currently reviewing an option for the construction of a new fuel farm at Ivato that would be built by the local fuel distribution industry to the East of the future international terminal. The nearest households are expected to be located 220 meters away from the proposed location. The concessionaire will ensure that the design will follow GIIP on hazardous fuel storage and relevant
safety measures, and an update of emergency preparedness and response procedures will be developed in collaboration with the selected fuel farm operator and SSLIA. The concessionaire will report to IFC on any decision relevant to the installation and safety measures of fuel farms.



Security Personnel



Security related to airport passengers and protecting the airport perimeter at Ivato and Fascene airports is under the responsibility of the Aviation Civile De Madagascar (ACM) and managed by a security firm contracted directly by ACM. Managing security is not within the scope of responsibility of Ravinala Airports. The concessionaire has appointed a Risk Manager who will participate in the coordination of civilian and military operation related to airport safety and security and to emergency situations, assess risks related to the interface with public authorities and provide recommendations on how such risks can be managed. The Risk Manager will ensure that the risk assessment will include considerations of risks of the presence of public and private security forces at the airports (ESAP item #9).

The Fascene Airport is located to the northeast of Nosy Be island. Nosy Be is part of the Sambirano region within the Madagascar Subhumid Forest Ecoregion. The forest type characteristic of this ecoregion is not present in Nosy Be where the natural vegetation cover is dense humid lowland evergreen forest. Most of the natural vegetation has been cleared or fragmented by human activity and associated pressures (agriculture, collection of natural resources, introduction of invasive species) and it is mainly restricted to Lokobe Reserve, a IUCN Category 1a (Strict Nature Reserve) legally protected area located 5 km away from the airport, and around the crater lakes of the island. There are mangroves along the north and east coasts of the island and sea grasses and corals along the south and north coasts. Despite human pressures, Nosy Be is rich in biodiversity and has a high level of species endemism.



Nosy Be is also within the Important Bird Area (IBA) of Nosy Be and Satellite Islands designated for the presence of the Critically Endangered Madagascar Fish-eagle (Haliaeetus vociferoides). Although the species has been sighted in the proximity of the airport, this is a rare occurrence due to noise and disturbance from aircraft and human population around the airport. The species is not known to nest in the airport area and the nearest known nesting site is located over 5 km away.



Baseline surveys undertaken for the ESIA found that the area of influence of the airport consist of mostly degraded natural habitat and cultivated areas and few remaining patches of non-degraded vegetation remain. Degraded secondary forest and plantations are the main land cover types of the area around the airport. Despite degradation, the patches of secondary forest house a range of threatened and endemic species of flora and fauna.



Mangrove vegetation can be found along the coastline in the immediate proximity of the existing airport. Some of this mangrove is degraded and part of it has been replanted. However, some of it is still highly diverse: eight species of mangrove have been identified and they provide habitat for several species of birds and mollusks. There is a coastal lagoon and mudflats in the proximity of the project site which also constitute important areas for birds and mollusks. These coastal habitats will not be affected by the project.



A Critical Habitat Assessment was conducted as part of the ESIA. Although the airport is located in an area of modified habitat and degraded natural habitat, the area is considered critical habitat due to the presence of the following critically endangered/endangered fauna species and endemic/restricted range species, which occur mainly in the forested areas and also in the mangrove habitat of Nosy Be:



Lepilemur tymerlachsonorum (Nosy Be Sportive Lemur), confirmed as present in the area by the baseline surveys

Stumpffia pygmaea (Andoany Stump-toed Frog), confirmed as present in the area by the baseline s
urveys

Paroedura oviceps (NosyBe Ground Gecko), confirmed as present in the area by the baseline surveys

Trachylepis lavarambo (a gecko – no common name), confirmed as present in the area by the baseline surveys

Haliaeetus vociferoides (Madagascar Fish Eagle), confirmed as present in the area by the baseline surveys

Microcebus mamiratra (Claire''s Mouse Lemur)

Ardeola idae (Madagascar Pond-heron)

Rhombophryne testudo (Nosy Be Burrowing Frog)

Lygodactylus madagascariensis (Madagascar Dwarf Gecko)

Zonosaurus boettgeri (a lizard – no common name)

Zonosaurus subunicolor (a lizard – no common name)

Typhlops reuteri (Reuters Blind Snake)

Three endangered/critically endangered flora species also trigger critical habitat (Dalbergia humbertii, Euphorbia ankarensis, Euphorbia pachypodioides) for Nosy Be but they have not been found in baseline surveys undertaken around the airport.



Phase 1 or the project will not have any physical footprint outside the airport area and therefore significant impacts on biodiversity in the area surrounding the airport are not expected. As the airport is already in operations, bird strikes involving Madagascar Fish-eagles are possible at Fascene. However, the likelihood is low because the species is rarely present around the airport. The concessionaire has committed to monitor bird strikes around the airport at Fascene. (see ESAP item #14). Monitoring of bird strikes will determine whether an impact on bird populations is occurring which would require additional mitigation.



Due to its location, and although impacts on critical habitat values are not expected, the project is required to achieve net gains in line with Performance Standard 6 requirements. In addition to the good industry practice measures to minimize impacts during construction and operation included in the project ESMP, the concessionaire will contribute to programs aimed at the conservation of species identified as critical habitat triggers and their habitats, and to conservation programs targeting the IBA. The concessionaire will identify suitable conservation programs with input from their biodiversity consultants and in consultation with relevant conservation NGOs (including Birdlife counterpart in Madagascar) this is detailed in ESAP item #15.



At least three invasive plant species, one invasive amphibian and two species of rodents were found in the immediate areas surrounding the airport during the baseline surveys. The introduction and spread of invasive species is one of the main threats to the endemic vegetation and fauna of Nosy Be. The concessionaire will include specific measures in the project management plans to ensure that construction and operation activities do not lead to introduction or spread of invasive species (ESAP item #16).



The project will be undertaken in line with good international practice in order to avoid impacts to water resources and soils, and is not expected to impact any priority ecosystem services.

Ongoing Reporting to Affected Communities

The ESIA consultant conducted meetings with citizens and representatives of Fascene community for the Fascene Airport ESIA, and with citizens and representatives of Ivato, Talatamaty and, Anosiala communities and Ambohidratrimo district for the Ivato Airport ESIA during the second half of 2015. The key concerns raised at these meetings were related to the potential negative impacts related to the construction work. The key impact to communities during construction will be noise and increased traffic which has been taken into account through the mitigation measures and will be managed through the Traffic Management Plan and the Construction Noise Management Plan.

The Environmental Impact Assessment and its Non-Technical Summary have been made available to the public and public consultation was conducted in compliance with the Malagasy Décret n° 99-954 for the communities of Fascene, Ampasy and the municipality of Nosy Be and for the communities of Ivato, Talatamaty and Anosiala. These meetings took place in April 2016 and were organized by ONE.

After the signing of the concession agreement the concessionaire has developed a stakeholder engagement plan (SEP) for each of the airports which documents the consultation with a broad range of stakeholder. The SEP will be updated to include stakeholder mapping, engagement strategy for the affected communities as well as actions to socialize the emergency response plans (see section on PS4) for the relevant communities (ESAP item #5).

The SEPs will include a community based grievance mechanism that will be available to the affected communities. The engagement plan will include ongoing reporting to directly affected communities regarding risks and risk management at least on an annual basis.

The concessionaire will monitor complaints from the affected communities and other stakeholders during the construction and operational phase of the project and will address project related concerns in a timely manner (ESAP item #6).

Contact Person: Vincent Devauchelle / Jean-Baptiste Guenet
Company Name: Ravinala Airports
Address: BP - 133 - Anosibe - 101 ANTANANARIVO - MADAGASCAR
Email: mailto:ravinala@colas-mg.com
Phone: +261345486016
Facsimile: Not yet available

Broad Community Support is not applicable for this project

S.no	Description	Anticipated Completion Date	Status
1	Organizational Capacity and Competence Appoint an EHSC Manager for the Concession and develop EHS organization commensurate to the project risks. Appoint a Community Liaison Officer (CLO) for Fascene Airport and a CLO for Ivato Airport.	12/15/2016	Completed
3	ESMS Develop and implement an ESMS in line with PS1 requirements.	12/15/2016	Completed
6	Management Plans Develop and implement the following Management Plans. Some of these are currently in the form of framework management plans in the ESIA but will be made site specific and operational for the construction and operational phase: • Contractor’s management plan (including EHS and labor) both for construction and for operations • Site Management Plan and Emergency Plan • Site Waste Management Plan; • Hazardous Waste Management Plan; • Spill Preparedness and Response Plan; • Dust Management Plan; • Traffic Management Plan; • Construction Noise Management Plan; • Effluent Management Plan (surface water and wastewater) • HSE Plan • Construction Environmental Management Plan (CEMP) • Operational Environmental Management Plan (OEMP)	03/01/2022	Completed
8	Emergency Response Plans and Procedures Emergency response plans for Nosy Be and Ivato updated to i) reflect the recommendations from the risk assessment for the fuel farms and ii) include emergency response procedures for potentially affected communities including methods for dissemination and emergency drills for affected communities. The existing emergency plan for Ivato will be reviewed against good international industry practice and updated as needed. An EPRP for Nosy Be’s Fascene airport will be developed by Ravinala Airports. Both plans will include procedures for dissemination of relevant information on emergency preparedness and response and to assist and collaborate with the affected communities and the relevant government agencies in their preparations to respond effectively to emergency situations	02/28/2017	Completed
10	Stakeholder Engagement Plan and Grievance Mechanism Develop and implement a community based stakeholder engagement plan and a community based grievance mechanism. The engagement plan will include ongoing reporting to directly affected communities regarding risks and risk management at least on an annual basis.	02/28/2017	Completed
12	Employee transfer Provide a detailed report of the employee transfer plan, after consultation with employees on their preferences for transfer either to Ravinala Airports or staying with ADEMA. The report will outline the consultation process, details about the employee’s choices and options.	12/31/2016	Completed
14	Develop and implement an employee grievance mechanism A grievance mechanism for employees will be developed and implemented to ensure that employees are able to submit grievances including anonymous grievances without repercussion. A grievance mechanism will also be provided for employees of contractors, either through the corporate grievance mechanism or through a grievance mechanism provided by the contractor.	01/31/2017	Completed
16	Develop Human Resources (HR) Policies and Procedures Develop and implement HR policies and procedures in line with Performance Standard 2	12/15/2016	Completed
18	Engagement with public and private security forces The concessionaire’s Risk Manager will ensure, through direct engagement with civilian and military operation related to airport safety, security and to emergency situations that any risks to the affected communities are assessed and recommendations provided on how such risks can be managed.	03/31/2017	Completed
20	Fire and explosion risk for affected communities The Concessionaire will implement the mitigation measures from the risks assessment for the fuel farms in coordination with Total to reduce the risk from fire and explosion. Coordinate with the Government to make sure that the GoM relocates the household within the security zone of the fuel farm at Fascene Airport.	05/31/2017	Completed
22	Life and Fire Safety (LFS) audit for Ivato and Nosy Be Upon completion of the refurbishment of the existing terminals and other existing buildings with public access at Fascene and Ivato airports the LFS system audit has to be conducted by an international expert to ascertain that the LFS system at these terminals comply with National requirements and one of the internationally recognized fire codes.	07/31/2019	Completed
24	Supplemental Resettlement Plan If required, as defined in PS5, the concessionaire will commission a qualified independent consultant to develop and implement a supplemental resettlement plan that together with the documents prepared by the responsible government agency will address the relevant requirement of PS5. The need to develop a supplemental resettlement plan will be defined when the resettlement program of the government has been fully defined and implemented. As needed, regular monitoring and a completion audit by an independent consultant will be part of the supplemental resettlement plan.	12/31/2017	Completed
26	Monitoring of bird strikes Undertake monitoring of bird strikes with aircraft, targeting the Madagascar Fish Eagle and other species that are IBA triggers or have been identified in the ESIA as high value. If monitoring shows that significant impacts are occurring, the project will be required to develop mitigation to prevent bird strikes.	12/15/2016	Completed
28	Contribution to conservation programs targeting CH triggers and the Nosy Be and Satellite Islands IBA The project will contribute to suitable conservation initiatives that target the Critical Habitat species identified for the project or their habitat. The project’s contribution to conservation programs will also target the IBA. Initial identification of suitable conservation initiatives will be undertaken through consultation with specialists and relevant conservation organizations/NGO (including Birdlife’s Madagascar counterpart).	03/01/2022	Completed
30	Alien and invasive species As part of their Construction and Operational Management Plans, the Concessionaire will develop mitigation measures to avoid the introduction and/or spread of invasive species due to the Project’s activities. Monitoring of the effectiveness of these measures will be included in the project’s environmental monitoring plan.	12/15/2016	Completed