PS6 (Biodiversity Conservation and Management of Living Natural Resources) is not applicable. The habitat in which the sites are located is modified and land use is mostly agricultural. According to the Integrated Biodiversity Assessment Tool, no critical habitat and legally protected and internationally recognized areas are in the vicinity of the sites.

Similarly, no indigenous people or cultural heritage will be impacted by the project, therefore PS7 (Indigenous Peoples) and PS8 (Cultural Heritage) are not applicable.                                                 

This proposed investment is an E&S Category B project according to IFC’s Policy on Environmental and Social Sustainability, because potential adverse environmental or social risks and/or impacts are limited, few in numbers, site-specific, largely reversible and readily addressed through mitigation measures.

During construction, key environmental and social risks and impacts include air emissions and noise that could temporarily disturb surrounding residents, occupational health and safety (OHS) of construction workers, community safety, vegetation removal, influx of outsiders and risks of HIV/AIDS, and economic displacement. During operations, risks and impacts include water extraction for cleaning purpose, erosion and dust generation resulting from vegetation removal, and waste management. Main positive impacts include employment opportunities, electricity production, and reduction of greenhouse gases (GHG).

Environmental and Social Assessment and Management System

Engie was selected to build, operate and maintain the plants. Each plant and associated transmission line will be built by Solairedirect Global Operations (SDGO) and Solairedirect Senegal (SDS), subsidiaries of Engie, under an EPC solution comprising a Coordination Contract, a Supply Contract and an Installation Contract. Once constructed, the transmission lines will be handed over to Senelec, the state-owned utility, while Engie Senegal, a subsidiary of Engie, will continue to operate and maintain the plants. Engie is a member of the United Nations Global Compact. The Compact asks businesses to embrace, support and enact, within their sphere of influence, a set of 10 core principles in human rights, labor, environment and anti-corruption. Engie has an environmental policy considering environmental health risks to stakeholders (employees, local communities, clients and others), climate change, preserving natural resources and biodiversity. It also has a societal policy including stakeholder engagement, access to energy, responsible consumption, and governance.

During the project lifetime, the Project Companies will implement their own Environmental and Social Management Systems (ESMSs). The ESMSs will incorporate the following elements: (i) a policy that will indicate who within the Project Companies will ensure conformance and be responsible for its execution; (ii) identification of risks and impacts; (iii) management programs/procedures for environmental aspects, and social related issues (e.g. water management, waste management, OHS); (iv) organizational capacity and competency; (v) emergency preparedness and response; (vi) monitoring and review; and (vii) stakeholder engagement plan to manage grievances and communications with  communities and others (ESAP #1).

Identification of Risks and Impacts

An Environmental and Social Impact Assessment (ESIA) and a Resettlement Action Plan (RAP) were prepared for each plant by local consultants in 2018. The Senegalese Ministry of Environment is expected to validate the ESIAs and emit the environmental permits in February 2019. A notice to proceed with construction for each plant is expected to be available during the first quarter of 2019.

According to the ESIAs, during construction, environmental and social risks and impacts will include air emissions and noise; OHS; community safety due to increased traffic; vegetation removal (Kahone plant and transmission line: approximately 400 trees and shrubs will be removed; Touba plant and transmission line: approximately 30 trees and shrubs will be removed); economic displacement (Kahone plant: 3 families owning the land through customary rights, and about 98 people using it for agricultural purpose; Touba plant: 2 families and 6 individuals with customary rights); loss of access to pasture land, and for medicinal plants. 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. transformers oils); and vegetation clearing operations.

The plants, which is located in a semi-arid region, will require approximately 300 m3 of water during the 12-month construction period and, provisionally, about 1,500 m3 per year during operations (for panel cleaning) most likely from local groundwater resources. The quantity of water required by the Project Companies shall be fully assessed including potential impacts on other groundwater users. Following the assessment, the Project Companies will develop and implement a water management program to ensure sustainable use of natural resource and prevent impacts on water users (ESAP #2).

Management Programs

The ESIAs for Kahone and Touba include an Environmental and Social Management Plan (ESMP) defining management programs related to risks and impacts identified in the section above. The Project Companies stated that they will ensure that relevant management programs will be integrated in the EPC contracts and sub-contracts, and fully implemented during the construction phase. For the operations phase, the Project Companies will also ensure full implementation of the ESMPs. The government-led resettlement is to be conducted by Senelec, and the Project Companies will supervise implementation of the RAPs. If the measures to compensate and restore livelihoods of affected people do not meet IFC’s requirements, the Project Companies will develop action plans to complement government action. This will be discussed further under PS 5.

Organizational Capacity and Competency

During construction and operations, Engie will have an EHS Officer at each site. This Officer will supervise and coordinate all EHS activities of the different sub-contractors. Each Project Company will also set up an EHS team to support the Contractor’s EHS Officer to ensure that mitigation measures of ESMPs are effectively implemented. This team will be composed of an EHS Manager, and a Community Liaison Officer responsible to manage grievances and oversee implementation of the Livelihood Restoration Plan (ESAP# 3).

Emergency Preparedness and Response

As set forth in the ESAP (action #4), each Project Company will prepare an Emergency Preparedness and Response Plan. The plan will include the following elements: administration; organization of emergency areas; roles and responsibilities; communication systems; response procedures; resources; training and updating (including drills); checklists; and business continuity and contingency.

Monitoring and Review

Under the ESMSs, each Project Company will develop and implement a structured EHS monitoring and reporting system on environmental, OHS and social impacts of its operations. Monitoring frequencies and methodology will be reflective of the risks and impacts identified by the above mentioned ESIAs and incorporated into the ESMSs; monitoring data will be stored in a centralized database for monthly and annual report production. The Project Companies will each disclose monitoring results to provide feedback to affected communities on at least an annual basis in relation to any impacts affecting them and associated mitigation measures.

Human Resources Policy and Procedures

Construction works for each plant will generate about 100 jobs for approximately one year, and operations will involve about 10 workers at each plant. According to the Senegalese Labor Law (Law no 97-17 of 1 December 1997), regular employees will receive a contract registered at the “Inspection Régionale du Travail et de la Sécurité Sociale” (Labor Ministry). Each Project Company will ensure that Solairedirect contributes to the ‘’Institut de prévoyance médicale’’ (medical insurance for employees and his/her family) as well as to the ‘’Caisse nationale de sécurité sociale’’(CNSS) in case of work accidents. In line with legal requirements, daily workers are equally entitled to CNSS partly paid by the employer and partly by the laborer. In Senegal, the minimum age for work is 15. Kahone and Kael Solaire, SDGO, SDS and Engie Senegal will not hire anyone under the age of 18 years.

As set forth in the ESAP (action # 6) to comply with the requirement of IFC’s PS 2, each Project Company will develop its own HR Policy and procedures for the construction and operations phases that will cover all type of workers, including direct workers and contracted workers. Each Project Company will ensure that the EPC and O&M contractors develop similar policies and procedures. At a minimum, the HR Policies will include the following provisions: working relationship; working conditions; terms of employment; workers’ organizations; non-discrimination and equal opportunity; grievance mechanism; prohibition of child and forced labor; and occupational health and safety. The HR Policy will be communicated to all new employees during the induction process.

Occupational Health and Safety

The ESIAs include a detailed description of OHS risks and impacts during construction, operations, and decommissioning, with a series of preventive measures. The main risks and impacts will include heat exposure, traffic safety, exposure to welding light and fumes and potential for fires and/or explosions resulting from ignition of flammable materials or gases. As referenced earlier under PS 1, the EPC and O&M contractor will develop and implement the ESMPs for the different phases of the project.

Neither Project Company intends to build workers accommodations at the construction camp. For migrant workers who will be housed by subcontractors in the neighboring communities in and around the sites, or in the event that either Project Company decides to offer central accommodations on the construction camp, it will ensure that standards for workers’ accommodations will be compliant with the IFC PS2 requirements.

Workers engaged by third-party

As stated above, each Project Company will include EHS provisions in the EPC and O&M contracts and contracts with other sub-contractors providing services to that Project Company’s operations. These provisions will include as a minimum:  compliance with labor legislation, terms of OHS management, and access to a workers’ grievance mechanism including review and response to anonymous complaints. Each Project Company will monitor third-party compliance with approved EHS requirements.

Water and Energy Consumption

According to the ESIAs, water will be sourced from ground aquifers via a borehole during construction and operations. Water will be used for sanitary purposes and to clean the panels during operations. For each plant, it is estimated that about 20,000 L/month will be used during construction, and about 100,000 L/month during operations. The quantity of water required by each Project Company shall be fully assessed for potential impacts on other groundwater users followed by implementation of appropriate water management programs. During construction, there will be a generator on site and the electricity needs are estimated at 30 kWh/day.

Wastes

According to the ESIAs, during construction, waste will consist mostly of wood residues (about 2,000 pallets per plant) and packaging material (about 4 m3 plastic and 5 m3 cardboard per plant), metal (about 400 kg per plant), and domestic waste (about 5,000 kg per plant). During operations, waste will be mostly generated at each office, along with mineral oil from transformers, and sanitary effluents. During decommissioning, waste will consist of used panels, metals, wood residues, used oil, and concrete. As part of the ESMSs (action #1), a waste management procedure will be developed and implemented by each Project Company. The procedure will include characterization of waste by type, quantities, and potential use/disposition establishment of priorities based on a risk analysis that takes into account the potential EHS risks during the waste cycle and the availability of infrastructure to manage the waste in an environmentally sound manner; opportunities for source reduction, as well as reuse and recycling; procedures and operational controls for onsite storage; and final disposal.

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

Hazardous Materials Management

There will be a total of 13 transformers of 3,150 kVA on the Kahone site and 10 on the Touba site. Mineral insulating oils will be used to cool transformers. These oils will be handled by trained personnel to ensure that manufacturers’ recommendations are strictly followed. Provision of secondary containment, drip trays or other overflow and spill containment measures will be implemented in designated areas. Vegetation control will be carried out manually without any pesticide use. The waste management system described above will include used hazardous materials and will address issues linked to waste minimization, generation, transport, disposal, and monitoring.

Community Health and Safety

The Kahone plant will be located in an industrial zone next to a secondary road, while the Touba plant will be located in a rural area. As such, potential adverse impacts from construction will be increased traffic which may represent a risk for the local population. Transport employees and sub-contractors will be required to produce a valid driver license. As set forth in the ESAP (action # 7), the Project Companies will develop and implement safe driver and transport safety vehicle procedures, including training sessions for their own and third-party haulage contractors, especially during construction.

Security Personnel

At the moment of appraisal security arrangements had not been made but client has confirmed that security will be provided by a private firm and CCTV system. Non-armed guards will be posted on site. Before hiring security personnel, the Project Companies will make reasonable inquiries to investigate the employment statement and other available information, including any criminal record, of individuals or firms and will not employ or use any individuals or companies that have abused or violated human rights in the past (ESAP #8)

During the preparation of the ESIAs, public consultations were held in July and August 2018, for Touba and Kahone, respectively. With respect to Kahone, most concerns were related to community health and safety during construction, employment opportunities, training, and provision of electricity as a project benefit. With respect to Touba, main concerns were related to community health and safety during construction, employment opportunities, influx of workers and impacts on communities, ongoing information about the development, occupational health and safety, danger of electrical equipment, training, and provision of electricity as a benefit of the development. During the RAP development process, consultations with affected people were held in March and April 2018, for Kahone and Touba respectively. With respect to Kahone, main concerns were related to the loss of access to land and the lack of replacement lands, conflict resolution, lack of confidence related to Senelec’s commitment in implementing the RAP, the importance of a transparent compensation process, skills needed to engage in alternate livelihood activities, and capacity building. With respect to Touba, main concerns were related to the loss of revenues resulting from displacement, livelihood restoration, conflict resolution, need to address vulnerability of people, and food security.

At the Group level, Engie has a procedure for external communications that includes methods to (i) receive and register external communications and complaints from the public; (ii) screen and assess the issues raised and determine how to address them; (iii) provide, track, and document responses, if any; and (iv) adjust the management program, as appropriate. 

As described in ESAP #5, each Project Company will develop a Stakeholder Engagement Plan. The Stakeholder Engagement Plan will include the following elements: engagement principles, objectives and criteria; requisites and regulations; summary of any previous engagement activities including any documented evidence (i.e., agreements, minutes of meetings, etc); identification, characterization and priority of stakeholders, focusing on those directly affected and identifying any vulnerable individuals or groups; engagement program including indication of how interactions should be formalized (i.e., agreements, acknowledgment of receipt of information, etc); description of grievance redress mechanisms; list of time-bound activities; and resources and responsibilities.

Contact Person: Karim Ndiaye, Investment Director

Company Name: Meridiam West Africa SAS

Address: Immeuble la Rotonde, rue Amadou Assane Ndoye, Dakar, Senegal

Email: k.ndiaye@meridiam.com

Phone: 221 33 829 64 98