This is a Category B project as the proposed investment is expected to have limited environmental and social impacts, which are site-specific, temporary and none of which is expected to be significant.  The LNG shipping, transfer and floating regasification sector is considered to have an excellent safety performance record, with no fatalities directly attributable to the cargo or material containment breaches having occurred in the sector’s 57 year operating history.

The key environmental, social, health and safety risks associated with this proposed investment include the company’s management capacity to develop a floating LNG regasification terminal, including how environmental and social risks are taken into account in planning, design, construction and operation.

Excelerate will maintain overall responsibility for the environmental and social management of the installation and operation of the project.  An Environmental and Social Impact Assessment (“ESIA”) has been developed as part of the project development, described further below.  An Engineering, Procurement and Construction (EPC) consortia consisting of Geocean Entrepose (Geocean) and Macgregor (Norway) has been selected and will be appointed for the Project.  Similarly, for the operations phase of the project, an operations and maintenance (O&M) contractor, EXMAR Ship Management (ESM), has been selected to operate the FSRU vessel, with a ports services contractor, Svitzer, having been retained to undertake the port services and tug operations. 

Environmental & Social Policies and Management Systems:
At the corporate level, Excelerate has implemented an environmental policy which states the company’s strategic commitment to the management of environmental and social performance.  The policy commits to complying with host national laws and regulations; designing and operating Excelerate facilities to ensure the protection of human health and the environment; the assessment of risks prior to commencing on any given activity; the provision of adequate training for employees; engagement to improve technology regulations; provision of the resources necessary to support environmental activities; and monitoring and reporting for continuous improvement.

As noted previously, the Excellence is an existing vessel currently in operation which was purpose built as an FSRU with onboard LNG regasification and high pressure natural gas export capabilities in addition to cargo storage and transfer systems found on conventional LNGCs.  The FSRU has been assessed and classified against applicable International Maritime Organisation (IMO) codes and regulations.  The IMO is a specialized agency of the United Nations, and is the global standard-setting authority for the safety, security and environmental performance of international shipping.  To achieve these standards, a system of marine classification has been developed to assess compliance with technical and engineering standards for the design, construction and life-cycle maintenance of vessels. The Excellence FSRU has been Classified as a type 2 LNG carrier whose design and management systems are regularly assessed against relevant IMO standards and by Bureau Veritas, a French Classification Society.  Both the FSRU and support vessels deployed for the project are required to meet IMO standards for safety, security and environmental management, with all vessel environmental and safety management systems being audited annually against the IMO’s SOLAS and MARPOL requirements and by Bureau Veritas. 

The FSRU is required to dry dock at 5-yearly intervals and will have intermediate in-water surveys performed at site between 24 and 36 months after each major docking.  The Excellence FSRU will undergo a full dry docking within 6 months prior to commencing operations for the Moheshkhali LNG project.

The supporting infrastructure, namely the 7.5 km pipeline, the Pipeline End Manifold (PLEM), delivery point and mooring system will be designed to meet a number of applicable good international industry codes and standards including those of the American Petroleum Institute; the American National Standards Institute; International Organisation for Standardisation; ASTM; Det Norske Veritas; and the Oil Companies International Marine Forum Guidelines for the design, operation and maintenance of multi-buoys mooring.

With regard to contractors assisting with the project development, Geocean, who will lead the consortium undertaking the installation of the fixed infrastructure of the project, is a marine contractor based in Marseille, France, having operated for 30 years in the offshore oil and gas industry and operates a fleet of specialized vessels and equipment.  The company operates an integrated management system organised to comply with ISO 9001 and ISO 140001. 

As noted previously two contractors have been retained to assist with the project’s operations phase.  With regard to the FSRU operations, ESM, based in Belgium, is a maritime and offshore asset management company providing crew, commissioning services, operational management and maintenance services for FSRUs and specializing in performing ship-to-ship transfers of LNG and other offshore units.  Excelerate and ESM have worked together since 2003, with ESM being the technical manager for Excelerate’s FSRUs worldwide as is the case for the current project.  The company operates an integrated management system which is organised to comply with a number of ISO standards including ISO 29001 (quality management system for product and service supply organizations for the petroleum, petrochemical and natural gas industries); ISO 14001 (environmental); OHSAS 18001 (occupational health and safety) and ISO 9001 (quality). 

Svitzer, a Maersk Group Company, is based in Denmark having been in operation since 1833.  Svitzer will be providing towage and vessel support services for the project.  Svitzer has recently revised, and is implementing its safety management system that complies with OVMSA (Offshore Vessel Management and Self-Assessment), a code that incorporates best practices from other standards, including: OHSAS 18001, ISO 9001, ISO 14001, the International Maritime Organisation’s International Safety Management (ISM) Code, the UK Health and Safety Executive and the Australian Maritime Safety Authority (AMSA).

Environmental and Social Assessment:
A regulatory Environmental Impact Assessment is required by the Government of Bangladesh.  The Bangladeshi Department of Environment (DoE) issued Terms of Reference for the project EIA during November 2011, with an EIA submitted in 2012. The Department of Environment approved the EIA and provided Site Clearance and Environmental Clearance in January, 2016.
As part of IFC’s financing an ESIA was required and has been completed in a manner consistent with IFC’s Performance Standards.  The ESIA builds on the original EIA, and integrates a number of supplemental studies to support impact evaluation, including an air emissions inventory; air emissions dispersion modelling; LNG leak simulation modelling; thermal plume dispersion modelling; sediment dispersion modelling; navigability and water suitability assessment and Critical Habitat Assessment. 

The project company has completed an offshore environmental baseline survey, sampling sediment, water and benthos.  The survey builds upon a previous geophysical sampling campaign in 2008.  Results from the 2008 and 2016 surveys show a shallow bathymetry, comprised of muds and sands.  The 2016 environmental baseline survey found no sensitive seabed features, with macrofauna species richness and diversity found to be low.  No marine mammals or turtles were observed during the survey.  Water and sediment quality was found to be generally good, with the exception of nickel which was found to slightly exceed indicative ecological effect thresholds (Effects Range Low).

Installation of the subsea infrastructure will take place almost entirely offshore.  These installation activities will involve limited disruption of the sea floor primarily as a result of trenching and post-trenching activities for the burial of the pipeline.  Sediment modelling indicates that sediments will become suspended in the water column temporarily returning to ambient levels within 12-24 hours. The delivery point is located approximately 30m from the high tide line with a permanent footprint of approximately 45m x 45m, as described further in the PS6 section below. 

Human settlement is limited to the eastern shore of Moheshkhali Island and there is no settlement within 6km of the project’s on-shore delivery point.  As the construction site will be accessed from the water, installation activities will have a negligible human impact.  The closest fishing communities are located in the villages of Ghatibhanga (within Kutubjom Union), Boro Dale (within Boro Moheshkhali Union), and Panirchara (within Hoanak Union), with navigable distances to the FSRU location of 17 km, 20 km and 31 km respectively.  Artisanal fishing activities are generally focused toward the intertidal zones of the project area (commercial fishing activities not permitted in water depths of less than 40 m in Bangladesh).  Artisanal fishing activities will be limited from operating within a permanent 500 m radius (safety zone) established for the FSRU and its pipeline connection to shore.  As outlined further in the PS4 section below, Excelerate has previously engaged with and advised Port Authorities, other agencies, local government officials, fishing agencies, and fishing association leaders of this safety zone.  Impacts to fishing communities as part of the ongoing project operations are expected to be limited and site-specific, although fishing communities did express concern over the safety zone during project consultation.  As part of IFC’s investment, Excelerate will develop a transparent grievance redressal mechanism to address concerns raised by local stakeholders, including the fishing community, with regard to impacts and mitigation [ESAP #5].

Management Programs:
Excelerate is ultimately responsible for the management and supervision of all project activities.  A framework Environmental and Social Management Plan (ESMP) for the project has been developed and is described further in Chapter 6 of the project ESIA.  The framework ESMP describes the structure and processes that will be applied to development and operation activities to assess and monitor compliance and effectiveness of the mitigation measures.  The elements of the framework plan will be incorporated into an integrated ESMP that will be implemented in order to deliver the project environmental and social regulatory compliance objectives and other related commitments.

The integrated ESMP will be a component of the overall integrated management system for the project. A construction phase ESMP and the relevant management plans and programs will be in place in advance of the project installation [ESAP #2].  As part of IFC’s investment, the project company will review, and where required augment existing operational management systems developed as part of the vessel’s flag state requirements, to cover both the FSRU and the fixed infrastructure to shore consistent with host national law, international maritime law and IFC’s Performance Standards [ESAP #1]. 

As noted previously, Excelerate will rely on its contractors for many aspects of environmental and social performance. As part of IFC’s investment, Excelerate will perform a bridging analysis to evaluate the adequacy of subcontractor plans and procedures and to ensure all aspects of the project are covered.  Excelerate will integrate the main results of the bridging analysis into a bridging document and will require that each contractor operates according to its own requirements as well as the requirements of the project ESIA [ESAP #2]. The training, procedures and implementation of plans described will require that contractors perform actions that will mitigate or help to minimize potential project impacts [ESAP #2].

As outlined further in the PS 6 section below, the delivery point is located within an area defined as Critical Habitat according to IFC Performance Standard 6. In order to provide a clear set of actions and responsibilities to minimize and mitigate potential impacts to biodiversity for the project and to define required monitoring, a Biodiversity Action Plan (“BAP”) will be developed [ESAP #7].

Emergency Response:
As part of IFC’s investment, Excelerate will develop a number of Emergency Response Plans (“ERPs”) to ensure responses to potential incidents that might result from project activities are undertaken in a safe, rapid, effective and efficient manner.  Such ERPs are also required by international maritime law including a Shipboard Emergency Plan and a Ship Security Plan along with a corresponding Port Facility Security Plan for the project.  Such plans provide the response framework for a number of different shipping incidents and specific gas carrier scenarios [ESAP #3]. The emergency plan will provide the structure for response to any incident and requirements for communication with owners, local and national authorities and services.

The project’s ERPs will be designed to directly address all emergency situations and their consequences and establish command and control over the incident scene, ensure the safety of responders, develop plans of action, and facilitate communications.  Emergency situations to be addressed in the ERP will include spills (diesel, chemical spills, etc.); fire and/ or explosion; personnel (injuries, fatalities, missing person, etc.); evacuations; natural disasters (hurricane, earthquake, etc.); transportation – personnel or equipment (vessel collision, etc.); security (kidnap/extortion, piracy, etc.); media/public relations (could result from any of the incidents above).

Within the ERP, response procedures, key contacts (within and outside of Excelerate), notification procedures and Medical Evacuation Plans (MEDEVAC) will be clearly defined.  Similarly, Excelerate will review and ensure that each subcontractor will have its own specific ERPs, although it is the responsibility of Excelerate to ensure all scenarios are covered and that contractors are aligned in the event of an incident.

Monitoring and Reporting:
Beyond the routine inspection and monitoring activities required by international maritime law, audits will be carried out internally by Excelerate to ensure compliance with host national and international regulatory requirements as well as their own corporate EHS standards and policies. Audits will also cover contractors monitoring and inspection activities during the project installation and operations phases, to ensure contractor activities are in compliance with contractual requirements as defined in the project ESAP and project ESMP. Audits shall be performed by qualified staff and the results shall be communicated to Excelerate executive management.  The audits will include a review of compliance with the requirements of the project ESMP [ESAP #4].

Organizational Capacity:
Excelerate has an extensive depth of experience in the application and operation of good international industry health, safety, security and environmental practice in the FSRU market.
As part of IFC’s investment, Excelerate will review, strengthen as necessary and maintain an organizational structure that defines roles, responsibilities and the authority to implement Excelerate’s integrated management system. Key environmental and social responsibilities will be defined and communicated to the relevant personnel and to partners and contractors alike. Sufficient management sponsorship and human and financial resources will be provided on an ongoing basis to achieve effective and continuous environmental and social performance.

Training:
In addition to the training requirements indicated in the project framework ESMP, training requirements of vessel crews are specified in the IMO Standards of Training, Certification and Watchkeeping for Seafarers (“STCW”) Convention. A wide variety of training is required, including: marine firefighting, water survival, spill response and clean-up, emergency medical procedures, hazardous materials procedures, confined space entry, and training on operational procedures.

Training requirements are also indicated in individual subcontractor management systems. For example, training for local vessel operators in the ERP and other mitigation requirements will be needed at the start of construction and throughout operations. Similarly, and as part of IFC’s financing, Excelerate will develop training programs for contractors operating within Critical Habitats [ESAP #7].

Anowara-Moheshkhali Pipeline Associated Facility:
The Moheshkhali Floating LNG Project will connect to the Anowara-Moheshkhali pipeline, which is owned and operated by GTCL, a Petrobangla subsidiary.  At the time of the signing of the Terminal Use Agreement between the Company and Petrobangla in July of 2016, 88km of the 89.4km pipeline had been constructed.  There are currently no defined projects being developed or at an advanced stage of planning that would share the GTCL pipeline.  Consequently, the Anowara-Moheshkhali pipeline is considered an associated facility.

In order to characterize potential environmental and social impacts associated with the installation of the pipeline, and to evaluate what risks those impacts may pose for the project, Excelerate commissioned a rapid environmental and social assessment survey of the pipeline route.  At the time of the survey – December 2016 – construction of the pipeline had been completed, with the exception of one river crossing section and reclamation work at various points along the pipeline Right of Way (ROW).  The findings of this survey have been incorporated into the overall project ESIA.
The pipeline begins at the delivery point and travels eastward through the Sonadia Island Ecologically Critical Area (“ECA”) for approximately 3.5 km, of which 2.3 km are mangroves and the remaining are abandoned salt pans. The pipeline turns northward through active aquaculture, agriculture, and limited forested areas. Approximately 26 km of the right of way (“RoW”) in the south crosses sparsely populated mud flats used for salt harvesting and shrimp farming. The remaining pipeline route (approximately 60.5 km) is more populated and passes through mixed agricultural and forested areas near homesteads. However, the pipeline route largely avoids physical impacts to houses and permanent assets. The field survey characterizes the social impacts of the pipeline construction as “low” to “moderate” overall.  Similarly, the field survey characterized the environmental impacts of the pipeline construction project as “moderate” and reversible.

The responsible authorities – the District Deputy Commissioners – are reported to have acquired the pipeline ROW on behalf of GTCL in accordance with the Bangladesh Acquisition and Requisition of Immovable Property Ordinance of 1982.  Observations and interviews carried out by the survey team with land holders during the field survey indicate that the acquisition of the pipeline ROW permanently displaced only one household.  Based on available data, field observations and satellite data the ESIA estimates that approximately 630 households were impacted during the construction period.  As is typical with linear projects of this sort, the ROW land take may only impact a small percentage of each affected household’s land holdings and only during the construction period.  GTCL allows farming and other subsistence activities to be restored within the ROW (with the exception of tree plantation).  As such, the ESIA has assessed the social impacts of the pipeline construction as temporary and reversible.

To ensure that the outcome of the GTCL pipeline construction conforms to the requirements of applicable Performance Standards, Excelerate will: a) develop a specific communication protocol which will consist of periodic formal communications with the downstream operator to ensure the Anowara-Moheshkhali Pipeline is being operated and maintained appropriately, including where available the review of Petrobangla/ GTCL Anowara-Moheshkhali Pipeline monitoring reports; b) continuously monitor the operating pressure, temperature and flowrate of the subsea pipeline from the FSRU and in the event of any anomalies, immediately notify the downstream operator; c) subject to host nation approvals, undertake two additional Associated Facility pipeline surveys, once during the first quarter of project construction and once during the final quarter of project construction, to be undertaken in a manner that compliments the Project ESIA Associated Facility pipeline survey; and e) to the extent feasible, document report and facilitate the resolution of any identified stakeholder grievances or anomalies to Petrobangla/ GTCL and appropriate local government authorities. (ESAP #5).

As with all project related activities, Excelerate is responsible for the safety performance of all aspects of the project.  Construction will require approximately 280 personnel, a majority of which will be on-board the vessels at all time. The number of persons working onshore will be limited to those supporting onshore pipeline installation, connection and pre-commissioning activities. 

Once in operation, the FSRU has a permanent accommodation capacity for 40 crew/ operators.  It is anticipated that 32 crew will be required in normal operations, working on back-to-back rotations, with excess accommodation capacity being used for maintenance teams, visitors and other personnel as required.  All terminal accommodations will be aboard the FSRU with the onshore pipeline delivery point being an unmanned remote operation.    The port service vessels will have approximately 40 crew on board spread over 3 tugs, 1 OSV and 1 fast crew boat.

Ahead of operations, health and safety management systems will be developed, implemented and audited per the IMO Convention for Safety of Life at Sea (SOLAS), specifically the International Safety Management (ISM) code.  A requirement of the ISM code is for each vessel to have a working Safety Management System (SMS) on board the FSRU.  As noted previously, Bureau Veritas is the Classification Society used for the classification of the FSRU Excellence and is the responsible auditor for the SMS.

The SMS is the main safety framework which covers all aspects of the FSRU operation, including planned maintenance; crew management; health, safety, environmental and quality procedures; emergency response; ship cargo operations; ship machinery operations; technical management; resources; measurement, analysis and improvement management responsibilities.

Contained within the SMS is a permit to work system which covers the necessary conditions for carrying out maintenance and other work on board the FSRU.  The SMS will be comprised of several permit components, including enclosed space entry; hot work; cold work; working at heights; high voltage and equipment isolation/ segregation.  A permit to work is usually issued for a set period of time. Any change of circumstances requires the permit to be either re-issued or the conditions retested/ checked to ensure that the work area remains safe when work is carried out.

As noted previously in the PS1 section, Excelerate will review and develop HSE bridging documents to ensure responsibilities and gaps between Excelerate and its contractors are adequately addressed [ESAP #2].

Consistent with the IMO Maritime Labour Convention, 2006, Excelerate and its contractors ensure employment relationships recognize the principals of non-discrimination and equal opportunity. Employees have the right to freedom of association and have the opportunity to collectively represent to the management any issues or grievances that they may have.  As part of IFC’s investment, Excelerate will review and formalize existing worker grievance mechanisms for both the project’s installation and operations phases to ensure consistency with the requirements of PS2 [ESAP #6].

There have been no fatalities in Excelerate’s operational history with lost time incident (LTI) rates well within industry norms.  All incidents are investigated and any non-conformity with procedures recorded and, where necessary to prevent re-occurrence, new corrective actions are implemented.

The FSRU and the port service vessels retained for the project conform and are certified to IMO MARPOL (Marine Pollution Prevention) standards for waste management and pollution control.  The vessel was designed, constructed and is audited to all applicable classification society, IMO and other relevant body practices and standards, specifically MARPOL 73/78 - Annex VI “Prevention of Air Pollution from Ships”.  Ambient air quality modelling has been undertaken as part of the project ESIA, which indicates that ground level concentrations will be within national limits during FSRU operations.  Waste management plans for the handling and disposal of non-hazardous, hazardous and liquid wastes are consistent and are certified to MARPOL requirements. This includes, although is not necessarily limited to, the shipment to shore for disposal of all hazardous and non-hazardous solid waste material and the treatment and disposal of sewage waters and oily waters. In line with IMO requirements, Excelerate ensures segregated handling and storage of all hazardous materials is standard practice.

As outlined previously, the FSRU and the port service vessels meet IMO dry docking requirements, also ensuring that tributyltin (TBT) containing anti-fouling paints are not used as per IMO regulations. Excelerate does not use ozone-depleting refrigerants on their vessels.  The Excellence has a Green Passport, as noted in its classification, which refers to a detailed inventory being made during construction of all equipment to confirm that no hazardous or prohibited materials were used in the construction of the vessel.

The Excellence is fitted with Segregated Ballast Tank systems with water discharge systems being certified to IMO International Oil Pollution Prevention (IOPP) requirements. Air emissions are managed and certified to the IMO International Air Pollution Prevention (IAPP) standards in accordance to current guidelines and requirements.

Shipboard Oil Pollution Emergency Plans (SOPEP) are available for each vessel as required by the ISM Code. These emergency plans contain the oil and/ or chemical spill contingency arrangements in place and the response to be implemented in the event of a spill. Excelerate has not experienced any material spill incidents in their operational history.

When operational, the FSRU is expected to generate in excess of 25,000 tCO¬2/ y.  The vessel is in compliance with the IMO’s International Energy Efficiency Certificate requirements.  The certificate requires the FSRU’s Energy Efficiency Design Index (EEDI) meets the requirements set by the revisions to MARPOL annex IV (January 1, 2013).  The amendment sets mandatory limits to greenhouse gas emissions from shipping.  In addition, the International energy efficiency certificate certifies that the vessel has a Ship Energy Efficiency Management Plan (SEEMP) on board, a mandatory requirement.  The SEEMP informs a vessel owner on where improvements to the operational efficiency of a vessel, in a cost-effective manner, can be made over the course of a vessel's lifespan.

The FSRU is considered a vessel with restricted manoeuvrability under the Convention on the International Regulations for Preventing Collisions at Sea (COLREGs), rules established by the IMO. Under these rules, other vessels are required to give way and pass at safe distances to the ship. Fishing vessels and other vessels may pass near the operations area. A safety zone will be established to protect the health and safety of members of the public and maintain vessel security. Members of the local fishing communities will be informed in advance of the project.

Excelerate has previously engaged with and advised Port Authorities, other agencies, local government officials, fishing agencies, and fishing association leaders of this safety zone. The FSRU captain and/or port service vessels will monitor nearby vessel movements and provide warnings by radio and other means (including deploying a support vessel, such as a tug) to notify and redirect other vessels if needed.  These limitations will help to mitigate potential impacts to the public, specifically to fishermen and other vessel operators moving near the FSRU and installation activities.

Excelerate will be performing a port security assessment as required under the International Ship and Port Facility security (ISPS) Code. The results from this assessment will be presented to relevant authorities to allow appropriate controlled areas to be agreed and defined.

For the installation phase of the project, no shore-leave is foreseen and in-transit accommodation will be strictly limited.

The Delivery Point is located on Sonadia Island, approximately 30m from the high tide line with a permanent footprint of approximately 45m x 45m.  Sonadia Island is separated from the main Moheshkhali Island by natural salt water channels.  Sonadia island comprises a wide variety of wetland habitats including mudflats, sand dunes, a large intact mangrove system, sand bars, lagoons, man-made saltpans and beaches. Sonadia Island is within the Myanmar Coast mangroves ecoregion, and overlaps the Indo-Burma Biodiversity Hotspot.

Sonadia meets Critical Habitat thresholds for Critically Endangered (CR) species, specifically the Spoon-billed Sandpiper (Calidris pygmaea), and/or Endangered (EN) species including the Great Knot (Calidris tenuirostris), Spotted Greenshank (Tringa guttifer) and migratory and/ or congregatory species.

The highest priority is the Critically Endangered Spoon-billed Sandpiper (Calidris pygmaea).   The Bangladesh Spoon-billed Sandpiper Conservation Project (BSCP) has been conducting monthly water bird surveys during the winter (October – March) in Sonadia since 2009, and monthly (all year) in 2012 to 2015. This long term monitoring has provided substantial and independently sourced evidence to confirm four key areas used by waterfowl, including the Spoon-billed Sandpiper. BSCP personnel, as well as IUCN species specialists, were formally involved in the preparation of the ESIA. This involvement included an additional waterbird survey (2016) to assess use around the onshore footprint, which confirmed that the closest foraging, roosting, and staging area (Kaladia mudflat) is located approximately 700 m to the south of the Delivery Point and separated by dense to moderate mangrove coverage. The global Spoon-billed Sandpiper population (globally) is estimated between 240-400 mature individuals of which 26 individuals have recently been recorded on Sonadia Island as winter migrants.  This represents between 12.5-7.5 percent of the global population.  The median estimate meets Tier 1 threshold for habitat required to sustain ≥ 10 percent of the global population of an IUCN Red-listed CR species. 

The Endangered Green Turtle (Chelonia mydas) and Vulnerable Olive Ridley Turtle (Lepidochelys olivacea) nest in the beaches of Sonadia. Independent long term monitoring of sea turtle nesting activity has been conducted since 2005. Data from 2005-2010 shows that Olive Ridley nests are the most numerous and widely dispersed on Sonadia Island. The nesting habitat is found from Belekardia to Moghchar on the southwest coast of Sonadia, approximately 2.4 km east of the FSRU and more than 4 km south-southwest of the Delivery Point.  

Sonadia Island triggers requirements for legally protected areas and internationally recognized areas. Sonadia Island is legally recognized as an Ecologically Critical Area, an Important Bird Area and Key Biodiversity Area, and has been proposed as a RAMSAR Wetland of International Importance.  Legal permission to operate in the area has been confirmed. Engagement has occurred with authorities responsible for management of the area and conservation NGOs (BSCP) active in the area, leading to their involvement in ESIA development. Existing management and conservation objectives for the areas, where these exist, will be considered during development of the Biodiversity Action Plan (BAP). Additional actions will be delivered via requirements for net gains in Critical Habitat.

As noted previously, mangroves between Kaladia mudflats and the proposed delivery point range from dense to moderate coverage.  These areas have been largely replanted over the last 7-10 years, following previous clearing by third parties. This has resulted in low mangrove species diversity but the area maintains its core ecological functions and is in transition towards a natural state. As such the area was classified as Natural Habitat by local experts. Clearance of mangroves for construction area for the Delivery Point will measure approximately 75m x 70m and is not considered to result in significant residual impacts.  This limited loss of mangrove habitat is unlikely to affect Critical Habitat trigger species as they are shore birds that utilize mudflats and not interior forest species.

There is no requirement for a laydown area for construction because materials will be stored on barges.  Rather the construction footprint is utilized for fabrication, plant manoeuvring and construction activities.  All access to the site for the construction of the delivery point will be from the sea with the EPC contractor primarily utilizing barges reducing the onshore construction footprint requirement. No overland access or roads will be required. When complete the delivery point will consist of a permanent onshore valve station to house a mainline valve, pig launcher/ receiver facilities, and other controls and safety devices such as the emergency shutdown system, relief valves, and gas and fire detection facilities.  Following construction, approximately 60% of the site will be restored with the remaining area being used permanently as the Delivery Point (approximately 45m x 45m). Experience with mangrove restoration in the area suggests a high likelihood of success for restoration efforts.

In summary, there are very low to negligible impacts predicted on biodiversity in general.   Specifically, there are no significant residual impacts expected to Critical Habitat triggers.  Regardless, to minimize any potential impacts on biodiversity during the installation and operations phases of the project Excelerate will develop a Biodiversity Action Plan which will define specific mitigation measures [ESAP #7].  The plan and monitoring activities will include integration of IUCN-affiliated species specialists and local conservation NGOs that have been studying key biodiversity features in the project area of influence for over 10 years. The confirmation of Critical Habitat will require net gain. Given the nature of impacts and expectation of low to no residual impacts post mitigation, net gain will be delivered through contributions to conservation activities targeting Critical Habitat triggers and particularly the Spoon-billed Sandpiper. Conservation activities will be designed and implemented in close consultation and collaboration with conservation organizations active at the site. A Biodiversity Monitoring and Evaluation Plan (BMEP) focused on Critical Habitat values is required. This will be implemented via support to the existing long term monitoring program by BSCP.

Excelerate has undertaken a satisfactory level of community engagement as part of the project’s ESIA.  Excelerate will develop and implement a community based stakeholder engagement plan consistent with IFC’s Performance Standards to ensure that any adverse impacts of the project’s construction and operation are addressed through a transparent grievance redressal mechanism. 

There are no legal requirements in Bangladesh for public consultation or information disclosure during the permitting process. However, sector specific EIA guidelines suggest public participation as a part of the EIA study and recognize the need to consider socio-cultural, physical, and biological impacts. Project stakeholders include representatives of the government – public agencies responsible for regulatory oversight – as well as interested members of civil society and the general public for whom project development may present potential impacts.

Buck Booth,

Excelerate Energy L.P.
2445 Technology Forest Blvd., Level 6
The Woodlands, TX 77381
USA