There are no groups in the project area that would be considered as Indigenous People so PS 7: Indigenous Peoples does not apply. The ESIAs conducted to date have not identified cultural heritage resources on the project site. PS 8: Cultural Heritage therefore does not apply to the project.

 This is a Category A project per IFC’s Policy on Environmental and Social Sustainability due to the potentially significant, diverse, and irreversible environmental and social risks and impacts associated with the project. Key social, environmental, health and safety impacts associated with this project include: influx; physical and economic displacement; air emissions; operation phase noise; solid waste management; water use and discharge; storm water drainage; labor and working conditions; and worker and community health and safety during construction and operations. The project areas are associated with Critical Habitat under Performance Standard 6.

 Identification of Risks and Impacts

An ESIA for the CIPREL 5 project was prepared by the international consulting firm ERM in January 2019. An updated, supplemental, ESIA was then provided in February 2019 to address IFC’s ESIA requirements. The Terms of Reference of the ESIA were validated on the 25th of February 2019 by to ANDE, the regulator in charge of validating ESIAs in Côte d’Ivoire (according to Environmental Act n°96-766 and the main decree n°96-894 determining rules and procedures applicable to ESIA for development projects).

The ESIA covers the project site and the 15 km transmission line (considered as an associated facility to the project), presents a baseline data set collected on the site and direct surroundings, identifies the environmental and socio-economic impacts of the project during the construction and operational phases, and recommends mitigation measures to minimize negative risks and impacts (also covering construction and operations). The ESIA also addresses the water intake and discharge pipeline that will be installed between the project site and the Ebrié Lagoon. The main risks identified are related to biodiversity, the emissions to air and impacts to ambient air quality, ambient noise, water consumption and discharge and risk of contamination, waste handling and disposal, socio-economic impacts, occupational health and safety for construction workers, community health, safety and security and project decommissioning. Quantitative studies were carried out involving numerical modelling of emissions to atmosphere, ambient air quality and noise during plant operations, and quantification of water abstraction and discharges. A discharge model for the cooling water was also performed by Tractebel Engineering and the conclusions included in the ESIA. The ESIA considers cumulative impacts for the existing activities and area expansion.  

As stated in the project description provided by the company, Atinkou is considering building a loading quay just before the bridge of Jacqueville to transport large pieces of equipment by barge from the port during the construction phase. The material would then be transported by road from the quay to the site. Given the early stage of development of these element of the project, the environmental and social impacts have not been assessed and integrated in the version of the ESIA finalized in February 2019. Therefore, prior to the beginning of the construction and as part of the siting and design process, the project will update the ESIA and integrate an assessment of the environmental and social impacts and propose mitigation measures for the construction and operation of the loading quay – including an assessment of alternatives (ESAP #1). The staff that will be in charge of the operation of the plant will be accommodated with their families in a camp/compound that will be developed in parallel with the construction of the power plant. The precise location of this camp is currently unknown. The project will assess the potential environmental and social impacts of the construction and operation of this camp prior to the beginning of its construction. (ESAP #2)

The public electric utility CI-Energies is responsible for the design, construction and operation of the CIPREL 5 transmission line. However, Atinkou included the 15 km segment of transmission line within the scope of the ESIA and has been working on the development of a Resettlement Action Plan (RAP) for this asset as well on behalf of CI-Energies, together with the Ivoirian company BNEDT, supported by the international consultant Insuco. The main impacts associated with the CIPREL 5 transmission line development are related to land acquisition and biodiversity which are discussed further below in the respective sections of this ESRS.

The 4.2 km gas pipeline segment connecting the site to one of the main gas pipelines is considered as an associated facility. The design and construction of this pipeline segment will be under the responsibility of CI-Energies. Atinkou will assess the environmental and social impacts of the 4.2 km gas pipeline segment as part of the on-going project ESIA. Atinkou will also include appropriate monitoring, auditing and reporting requirements into the Gas Supply Contract to obtain assurance that the pipeline is being developed and operated in accordance with the contractual provisions (ESAP #3)

Management Programs

Based on the results of the ESIA, the project developed a standalone Environmental and Social Management Plan (ESMP) that summarizes the mitigation and monitoring measures to address impacts during construction and operation phases of the power plant and the CIPREL 5 transmission line. The ESMP defines responsibility allocation, to ensure that the project is constructed and operated in accordance with national requirements and IFC Performance Standards. The Company plans to contractually require the project’s EPC contractor to adhere to applicable social and environmental legal/national requirements and fully implement environmental and occupational health and safety (“EHS”) measures defined in project ESIA and ESMP.

The company will develop an Environment and Social Management System (ESMS) compliant with IFC Performance Standards requirements (ESAP #4). The ESMS will include: (a) an Environment, Social and Occupational Health and Safety (OHS) Policy; (b) stakeholder mapping and consultation process; (c) organization structure - roles and responsibility allocation; (d) procedures for environment, social and OHS training of employees and contractors; (e) internal and external communication procedures; (f) procedures for recording, investigation, reporting and corrective action in relation to environmental, social and OHS incidents including those involving contractors; (g) periodic monitoring of EHS performance; (h) periodic internal and external EHS audit process; and (i) procedure for the management review of ESMS effectiveness and implementation of measures for system upgrade. 

The existing CIPREL plant has a robust EHS management system for its current operation which is ISO 14001 and OHSAS 18001 certified. According to Antikou, this management system will serve as reference for the development of the ESMS of the new plant.

As part of the ESMS development, CIPREL 5 will develop and implement the various management plans and programs that are presented in the ESIA to address identified risks and impacts. The ESMP will be the basis of developing the thematic points of the management programs. Key E&S issues to be addressed for construction and operation phase as defined in the ESMP include: (i) compliance with local environmental, health and safety requirements; (ii) solid and liquid waste handling, treatment, storage and disposal; (iii) occupational health and safety practices and training for employees and third party workers; (iv) labor and working conditions; (v) air emissions (point source and ambient air quality); (vi) noise within and outside site boundary; (vii) emergency preparedness and response; (viii) drainage and storm water runoff; (ix) hazardous material handling and storage; (x) soil contamination; (xi) traffic safety (onsite and offsite); (xii) equipment maintenance; (xiii) workers’ accommodation; (xiv) third party workers’ labor and working conditions screening mechanism as well as their access to Atinkou’s grievance mechanism; (xv) auditing of contractors implementation of the construction phase ESMP; (xvi) stakeholder engagement with regards to labor, health/communicable diseases and safety including a grievance mechanism; (xvii) environmental, health, safety and social performance monitoring and internal reporting.

For the construction of the plant, the project will be developing a set of operational procedures, related to communication, security, occupational health and safety (OHS) and incident management, that will be included within the contract of the project’s engineering, procurement and construction (EPC) contractor in charge of the construction. (ESAP #5). The objective of these procedures is to guarantee the integration of these issues from the start of the work and adhesion to applicable social and environmental legal/national and international requirements and implement environmental and occupational health and safety (EHS) measures listed in the ESMP. The successful implementation of the management programs during the construction phase will require close collaboration between Atinkou, the EPC contractors, and suppliers. The EPC contractor’s EHS site supervisor and Atinkou’s EHS team will ensure proper training of employees, contractors and subcontractors, implementation of occupational health and safety (“OHS”) standards on the construction site, have joint meetings on OHS and share lessons learned, and jointly investigate any incidents/accidents related to the Project.

Organizational Capacity and Competency

As part of the project development, the environmental and social component and studies has been led by the Atinkou project manager and E&S officer, supported by the third-party consultant, ERM, that was in charge of the development of the environmental studies and the BNEDT/Insuco, in charge of the resettlement action plans development. For the construction phase, the company will require the EPC contractor to also develop an appropriate EHS organization with roles and responsibilities clearly defined both for the company and the EPC contractor. This includes Atinkou deploying at least one fulltime dedicated EHS Manager during construction and the EPC Contractor deploying the right resources to ensure implementation of the management programs. Atinkou’s EHS Manager will liaise with the EPC Contractors’ EHS supervisor or equivalent and ensure that they adhere to the management programs developed from the project’s construction phase ESMP and approved by Atinkou. During the operations phase, the project will continue to employ a full-time EHS professional to implement the ESMS in line with IFC Performance Standards. (ESAP #6).

Emergency Preparedness and Response

The ESIA states that an Emergency Preparedness and Response Plan (EPRP) will be developed for both the construction and operation phases and presents a framework with the content that should be covered in the document. The existing CIPREL plant in Vridi already has procedures, trained personnel, and equipment for responding to emergencies, including explosion, fire, chemical spills, accidental release of petroleum products, and medical emergencies. This set of plans, procedures and skills will serve as working base for the development of the EPRP of the project. Prior to the start of construction activities, Atinkou will finalize the Emergency Response Plan for the construction activities of the plant. This EPRP will be agreed with the EPC that will be in charge of its implementation on the construction site. Similarly, prior to the project’s commissioning, Atinkou will update and implement a revised site-wide Emergency Response Plan that includes the project operations. (ESAP #7)

This EPRP will include establishment of a communication network between the EPC contractor, Atinkou and emergency services such as fire departments, traffic police, the Port Authorities, local medical services, and the communities and potential companies in the vicinity. Furthermore, the system will be tested through a mock drill to confirm effectiveness of the system or rectify any identified oversight.

Monitoring and Reporting

The project has already identified several E&S indicators relevant for the construction and operation of the future power plant as part of the baseline data collection (such as biodiversity, noise, ambient air and water quality). The Environmental and Social Management Plan (ESMP) of the ESIA is presenting a framework environmental and social monitoring plan that will cover the different E&S aspects related to the project; effluent, ambient air quality, noise environment, ground water quality but also livelihood restoration, workers conditions or grievance mechanism follow-up. As described in the ESIA, the development of the E&S monitoring plan falls under the responsibility of the project, that will follow up and control its adequate implementation on site by the EPC during the construction. The E&S monitoring plan will need to be finalized and implemented by the project during both the construction and operation phase (ESAP #8). Monitoring results will be reported internally to Atinkou’s senior management for review and used to identify and undertake any corrective action to improve E&S performance and ensure compliance with Ivoirian laws and IFC Performance Standards.

Though the EPC contractor is required to ensure adherence to applicable EHS requirements, as indicated in the ESMP, Atinkou will put in place detailed procedures, including reporting requirements for the EPC contractor, site audits jointly with EPC contractors’ staff and periodic meetings with EPC contractor as also their sub-contractors, to review and document EPC contractor compliance with national and ESIA requirements.

 It is estimated that the CIPREL 5 project will employ around 1,000 workers (peak period) during the anticipated 27-month construction phase. Most of the workers during the construction phase will be employed by the EPC contractor. As has been the case for the CIPREL 4 Project, it is expected that most of the workers will originate from Cote d’Ivoire and specifically locally from the Abidjan metropolitan area; however, there may be some expatriate staff for specialized work. No workers will be housed on site; instead, workers will either return home at the end of the work day, live in rental accommodation in the neighboring areas or in Abidjan.  Around 75 workers – skilled labor - will be directly employed by Atinkou during the operation phase of the project. Accommodation for the workers and their families will be built on a location close to the plant yet to be defined. As for CIPREL and all Eranove companies, it is expected that Atinkou will favor female employment to promote gender equality. The project will also create numerous indirect jobs for catering, security and other less skilled tasks that are externalized.

Prior to the start of construction, the project (ESAP # 9) shall develop a corporate human resource (HR) policy in line with the Ivoirian Labor Code and PS2 requirements. The policy will, at a minimum, address non-discrimination and equal opportunity, child labor, forced labor, freedom of association and sexual harassment. Atinkou shall require the EPC to: 1) contractually adopt and implement the corporate HR policy; and 2) develop and implement a HR manual that includes a recruitment procedure; induction procedure; working conditions and terms and conditions of employment (aligned to the Labor Code in Cote d’Ivoire and PS2 requirements); performance management; disciplinary procedures (including in relation to sexual harassment); and termination of contract and dismissal terms. All workers shall receive a contract of employment that will either include or make reference to all relevant terms and conditions of employment. These HR measures will apply to all workers working on the project including those employed by any sub-contractors to the EPC. All HR documentation will be made readily accessible and clearly communicated to all workers at induction and through the provision of additional sensitization and training.

The project shall require the EPC (ESAP #10) to develop a labor grievance mechanism that is aligned to PS2 requirements. The mechanism will also include provisions to enable the receipt and resolution of gender-related issues and grievances such as sexual harassment and gender-based discrimination, in sensitive and confidential manner. The labor grievance mechanism will be communicated and made accessible to all the EPC workers and their sub-contractors’ workers, if required.

The project will develop a construction Occupational Health and Safety Management plan. Prior to the beginning of the construction, the EPC contractor will be contractually required to deploy appropriately qualified supervisors for effective supervision of compliance with the contractual provisions relating to labor working conditions. Atinkou will require the EPC contractor to develop and implement their own Occupational Health and Safety Management Plan (OHSMP) that is aligned with the requirements specified in the project’s OHSMP. The plan will also be cascaded down to all subcontractors that will be active on the construction site. (ESAP #11)The OHSMP of the EPC will assess all risks associated with the construction activities and detail procedures for topics such as the provision of personal protective equipment and ensuring their appropriate use; trainings identification and organization, safe working procedures and emergency response, provision of medical care, first aid, health monitoring, vaccinations, pest management and measures for prevention of disease spread; accident/ incident monitoring, investigation, reporting and corrective action; and periodic joint audits and corrective actions.

 The potential environmental impacts from construction activities for the project include: fugitive dust; noise; water consumption; hazardous materials and waste handling, storage and transport; sewage and domestic garbage treatment & disposal; surface runoff and sediment load management; and vehicle traffic. The EPC contractor and subcontractors are expected to control these to acceptable levels through application of standard construction environmental management practices. The relevant recommendations and mitigation measures called for in the ESMP will be incorporated into the construction contract documents as previously noted.

Water

Water will be supplied from three new boreholes to be drilled on the site in the productive aquifer. The total water consumption of the plant is expected to be approximately 22 m³/hour during the operation phase, excluding cooling water that will be pumped from the Ebrie Lagoon. Based on desktop information on the hydrogeology of the site, the risks of impacts of the groundwater pumping on water resources for the surrounding water users and risk of saline intrusion has been evaluated to be minor in the ESIA. To confirm this assessment, the project will reinforce the impact assessment based on the results of the hydrogeological tests undertaken on site and on additional groundwater user baseline/census in the project surroundings. This will include the results of pumping test to estimate the hydraulic properties of the aquifer and to model drawdown and salt water intrusion according to internationally accepted methods as well as a detailed survey or other water uses and users within the hydrogeological area of influence (ESAP #12).

A unit for the treatment of incoming waters will be installed on the power plant site to provide the various systems with the different qualities of water required. The key effluents from the project will come from the surface water runoff, sanitary water, water from the demineralized water production unit and the water from the water treatment unit that will collect the industrial effluent and drainage water from the plant. Dedicated wastewater treatment, equipment and drainage will be constructed as part of the project to manage any contaminated wastewater during the operational phase. The water treatment unit will include an oily water storage tank, a sand trap and an oily water separator. Sanitary water will be treated on site in a septic tank and soak away pit. Except for the sanitary wastewater, other effluents will be discharge into the Ebrié Lagoon along the cooling water (see below). 

Cooling water – The project will use a closed-circuit water-cooling system (forced-draft) with cooling towers, which extracts waste heat to the atmosphere through the cooling of a water stream to a lower temperature. A water intake and discharge pipeline will be installed on a distance of approximately 1.2 km, between the project site and the lagoon, passing through agricultural lands, to the East of the village of Taboth and to the West of the forest area. Some of the water of the circuit must be added to replace the portion of the flow that evaporates. This make-up amount must equal the total of the evaporation, blow-down, drift, and other water losses such as wind blowout and leakage, to maintain a steady water level in the system. The cooling water will be pumped from the Ebrié lagoon (estimated volumes of 2.168 m³/h at worst case, during summer). Some of the water of the circuit will be discharged back into the lagoon to limit the concentration of dissolved minerals (like salt) and other solids in the recirculating water due to evaporation. The estimated volumes of water discharged into the lagoon are 1.676 m³/h (worst case) including contributions from the industrial effluent and drainage water from the plant described above.  The project will be designed so that combined discharge of the thermal and brine effluent from blow-down water and industrial effluents meet water effluent guidelines from the World Bank Group (WBG) EHS Guidelines for Thermal Power Plants (2007), Table 5 and WBG General EHS Guidelines (2007) for thermal effluent discharge to surface waters. (ESAP #13).

To assess the potential risk of the water discharge in the lagoon, the project undertook a water quality mixing modelling study (using TELEMAC-3D V7.2 software) that was performed by an internationally recognized consulting firm (Tractebel Engineering). The model considered various assumptions on the receiving water body (climate, currents, temperature, water quality, salinity), including various recent scientific studies available for the Ebrié Lagoon and the water quality baseline samples that were collected at the location of the future discharge point as part of the ESIA in June 2018. US-EPA standards were used to determine the radius of the mixing zones (100 m) considering water use, potential receptors and assimilative capacity of the water body. Since there are no clear guidelines on the tolerance limits for salinity (highly dependent on the type of local environment), salinity limits based on the State Water Resources Control Board in California were applied. The lagoon currents speed and waves characteristics were evaluated using Jonswap formulas and Ekman assumptions. The results showed that for modelled scenarios the maximal increase in background temperature was below the applicable WBG General EHS Guidelines of 3 degrees (maximum 1.7 degree difference at a distance of 100 m). The maximal increase in salinity was 1.8 ppt at a distance of 100 m in the worst-case scenario, which is very limited considering seasonal salinity fluctuations of about 20 ppt. Therefore, significant impacts on the environment are not expected under these circumstances. Other elements that will be present in the discharged cooling water are chlorine and PO4. The concentrations of these element will however be limited in the water and controlled prior to discharge into the lagoon to guarantee compliance of the measured concentrations with the national legislation and WBG EHS guidelines, such as presented in the ESIA. The technical study states that, although the elevation of the salinity and temperature is limited and restricted to the immediate surrounding of the outfall pipe, mitigation measures should be installed were possible, such as using outfall solutions favoring rapid dilution and a location that rules out recirculation and concentrated discharge along the shoreline due to wind effects. Potential impacts of the water discharge into the lagoon to ecosystem services, including those associated with fishing communities, are discussed in the section related to Performance Standard 5 below.

As presented in the ESMP, a specific water management plan will be developed by Atinkou to summarize the various elements and monitoring requirements that will be associated with the management of the different water streams presented in this section.

GHG Emissions

The selected technology for the plant, using a combined cycle system that recuperates the heat produced by the gas combustion to produce additional energy, will reduce gas consumption by 31% compared to an open cycle technology. The overall approximate efficiency rating is expected to be about 58% net of the fuel’s Lower Heating Value (LHV).  The project’s greenhouse gas emissions will primarily be carbon dioxide emitted by the plant due to combustion of natural gas. Total GHG emissions are estimated around 1,031,203 tonnes of carbon dioxide equivalent (CO2e) annually on open-cycle mode (gas-fired OCGT) and 1,096,208 tonnes of CO2e annually during combined-cycle operations. Note that the combined cycle process represent a save of around 500 000 tonnes CO2 per year with regard to the equivalent power in combined cycle.

Air Emissions and Ambient Air Quality

During the construction phase the pollutants of interest will be dust and particulate matter, evaluated as PM10, PM2.5 and Total Suspended Particulates (TSP), nitrogen dioxide (NO2), oxides of nitrogen (NOx), and sulphur dioxide (SO2) arising from construction traffic. Sources of dust and particulate matter include earthworks, access road construction and traffic along the existing road that connects the site to the main access road.

During the operational phase, the main pollutant of interest will be NO2 as the project will run on natural gas. According to project design specifications, NOx emissions from the gas turbine will not exceed 25 ppm dry volume during natural gas combustion. These limits are consistent with the 2008 World Bank Group Environmental, Health and Safety (EHS) Guidelines for Thermal Power Plants.

Considering that the project is located in a rural area with no major sources of atmospheric emissions (e.g. industries are absent, and the closest urban area is Jacqueville, located about 10 km to the east), the local airshed was assumed to be undegraded for the purpose of the present impact assessment. To confirm this assumption, baseline air quality measurements are being conducted as part of the supplemental ESIA, using diffusion tubes, for nitrogen dioxide (NO2) and nitrogen oxides (NOx) at different selected baseline air sampling locations - determined through consideration of the prevailing wind direction (almost exclusively from the southwest) and the location of sensitive receptors, in order to gain a representative sampling of the ambient air quality in the airshed.

As part of the ESIA, potential incremental impacts from operating activities were evaluated through the use of a predictive atmospheric dispersion model under open and combine cycle operating modes. The modelling took into account the plant design and local meteorology. Based on predictive modelling results, the maximum project contribution to NOx levels will be below the applicable ambient air quality standards, contributing only about 3.89 % (open cycle mode, limited to the first months of operation) and 15.41 % (combined cycle mode, used thereafter) of the NO2 1-hour maximum WHO Ambient Air Quality Standard (200 µg/m3) and 1.77% (combined cycle) of the NO2 annual average WHO Ambient Air Quality Standard. These results are compliant with the WBG General EHS Guidelines recommendation that no single project contribute more than 25% of the air quality headroom to allow for future project development. The CIPREL 5 plant design includes a continuous emissions monitoring system (CEMS) to automatically monitor NO2 emissions at the stacks on an on-going basis.

Noise

The ESIA addresses the potential for noise impacts affecting off-site receptors during the construction and operational stages of the project. Baseline ambient noise level were measured at the closest sensitive receptors that include the closest houses at the South-Eastern part of the village of Thabot (1 km away from the site) and three isolated houses/farm located closer to the future project site (including a ‘temporary’ house, approximately 300 m from the site). Noise emissions from the project will add to sources of noise from other existing noise sources in this rural environment. Background noise levels at the closest receptors around the project were evaluated to be below 45dB(A) at night for the closest receptors (except for the centre of the village of Thabot where the noise level reached 47 dBA due to human activities) and below 50dB(A) during the daytime for all receptors (isolated houses to the west of the site and houses locates at the limit of the village of Taboth, to the North-West from the site. 

Potential impacts from incremental noise during operation included an evaluation with a noise propagation model (SoundPLAN v.7.3) which generates noise contours based on assumed noise emissions levels of activities and operating equipment to provide an overall view of the predicted noise levels around the project site. Considering the fact that the nearest receptors affected by noise are residential and educational institutions, and because plant operation during the day and at night are expected to be the same, the project will be designed to target an overall project plant contribution of 45 dB(A) at the nearest receptors, noting that at worst only a marginal addition to pre-project noise level would occur (<3 dB(A)).

The results of the model showed that operational phase noise levels are estimated to comply with the WBG EHS Guidelines limits of 45 dB(A) and not to result in increased background noise by more than 3dB(A), except for the isolated house located approximately 350 m from the site and the ‘temporary’ house (300 m North-West) for which the predicted noise levels would reach 50 dBA. As stated in the ESMP, Atinkou will conduct a formal assessment of alternatives to prevent and mitigate impacts due to noise and vibrations at the nearest receptors.  Based on results of this assessment, the company will engage with the owner/users of these isolated houses (to the West of the site) to consider the potential options to limit the impact of elevated noise and vibrations on the occupant above the WBG General EHS Guidelines (2007) noise levels. This could include source control at the power plant if technically and financially feasible and cost effective, acoustic isolation of the house if technically feasible and accepted by the occupants, or the resettlement of the house to a quieter location, located further away from the power plant, also if accepted by the occupants.  If resettlement is the selected option, affected persons will be incorporated into the RAP prepared by the company and compensated according to IFC PS5 requirements (ESAP #14).

A number of additional mitigation measures for operational noise are proposed in the ESIA, to minimise the potential noise impact and that includes regular noise monitoring following the commissioning of the plants, information of the public of plans and effort to minimise noise and establish a complaints response procedure and consideration of additional mitigation measures in the event of noise complaints following the commencement of operation.

Solid Waste Management

The project construction will generate general solid waste (household waste, plastics, paper, food, packaging, glass, office equipment, scrap metal and wood) and hazardous waste (waste oil, oily rags, filter cartridges, absorbent materials, medical waste, paint waste and paint cans and lead-acid batteries). Most of the hazardous waste will comprise oil-contaminated materials. The primary hazardous waste during operations will include: the oil collected from oil water separators; sludge and residual solids from oil and grit separator tank; waste water treatment plant sludge; compressor cleaning waste; oil filters; batteries; oil and grease contaminated maintenance waste; used oil/paint/chemical drums; oil contaminated water or spills from oil storage areas; used oil generated in maintenance; oily rags/oil contaminated scrap from maintenance activity; and transformer oil. 

Atinkou will identify appropriate authorized entities that can handle the different types of hazardous wastes that will be generated during construction and operation. As stated in the ESMP, capability to treat and dispose of the different types of waste in accordance with WBG General EHS Guidelines and national laws will be considered in selection of waste management entities. Further, the Company will implement procedures to assure itself that the hazardous waste treatment and disposal facilities remain compliant with the national laws and good international industry practices. As presented in the ESIA, a waste Management Plan will be finalized prior to the start of construction for proper storage and disposal of all wastes generated during construction. A post-construction survey of the construction area will be conducted to confirm that all debris and wastes have been removed and appropriately disposed at the end of the construction phase.

Hazardous Materials

During the construction phase, fuel oil, lube oil, paints, and maintenance products are likely to be required. No bulk storage of chemicals is anticipated. Through contractual requirements and as stated in the ESMP, Atinkou will ensure that good site management practices are observed by the EPC during construction, and that hazardous materials are properly stored and handled at site (e.g. as appropriate within secondary containment, double walled tanks, over filling alarm system, etc.).

During the operational phase, type and volumes of hazardous materials stored and used at the power plant will also be limited and include acid, caustic soda, fuel, solvents, lubricating oils, transformer oil, natural gas (not stored on site but used).

As specified in the ESMP, Atinkou will develop and implement a procedure for appropriate storage of these materials during construction and operation phases, including appropriate segregation, labeling, storage based on compatibility assessment, where required provision of secondary containment, corrosion resistant lining as required and access control.

  The community of Taboth is the closest to the power plant site and is located approximately 1 km north-west of the site. Two to three isolated houses are located to the West, between 300 m and more than one kilometer. During construction, the heavy pieces of equipment will be shipped to the project site through barges on the Ebrié Lagoon, to the future loading quay that will be located before the bridge of Jacqueville, approximately 10 km east from the site. This option will significantly reduce the project impact on road traffic in Abidjan and community exposure to road safety risks up to the debarking point. From the debarking point to the project site, there are likely to be increased transportation safety risks along the route followed, during construction and operations.

As stated in the ESMP, Atinkou will require the EPC contractor to develop a project Traffic Management Plan (TMP) that will cover aspects such as training of drivers on safe driving techniques, drugs and alcohol testing for truck drivers, speed controls, posting traffic marshals at high risk locations and undertaking community awareness programs. Measures to undertake continuous monitoring and periodical audits of the implementation of the plan will also be developed.

During the construction, the project area will experience significant additional project-related population influx and associated social impacts. Mitigation measures are proposed in the ESIA to avoid or minimize transmission of communicable diseases that may be associated with the influx of temporary or permanent project labor. Details on temporary and permanent workers accommodation (location and type) are not finalized yet. The solution retained for workers accommodation will determine potential social impacts on surrounding communities and mitigations measures to be implemented accordingly. 

Atinkou will also implement measures, as presented in the ESMP, to minimize risk of community exposure to disease due to the presence of workers on site and in the neighboring communities including: ensuring that appropriate medical facilities are available for all workers; an awareness and prevention program on HIV/AIDS and STIs including voluntary testing campaigns for site workers as well as local communities; and measures to control disease vectors.

Security guards will be hired to ensure the security of the power plant premises. Prior to the construction starts on site, Atinkou shall undertake (ESAP #15) a Security Risk Assessment as per PS4 requirements and as guided by the IFC Good Practice Handbook on the Use of Security Forces: Assessing and Managing Risks and Impacts and develop an appropriate Security Management Plan that includes a security policy, Code of Conduct, and relevant procedures for managing the project’s use of and relationship with third-party security personnel. Relevant security procedures will be communicated to the surrounding communities to ensure common understanding regarding security and to minimize potential for conflicts.

 The project is located in the coastal region of Ivory Coast, approximately 50 km west of the capital Abidjan. The site and all associated facilities are located within the Eastern Guinean Forest ecoregion. Moist evergreen forest is the characteristic habitat type of the southern part of the ecoregion where the project is located. The land comprising the project site is a combination of fragmented patches of natural habitat and modified habitat. Natural habitats in the project area include swamp forest and temporary inundated forests. Modified habitats consist of agricultural fields and recent fallow areas. The site of the gas plant largely consists of coconut plantations and is mostly modified. The transmission line crosses several areas of natural habitat.  As per ESAP #20, CIPREL engaged a qualified consultant to prepare a detailed habitat map to enable further avoidance of impacts (e.g. micro-siting of project facilities) and an accurate calculation of the extent of natural habitat impacted by the project. The 15 km transmission line and to a lesser extent the water and gas pipelines will impact a total of 13.4 ha of natural habitat. This includes 7.9 ha under the transmission line where large trees will be cut in order to maintain the vegetation under 3 m high, but the land will not be cleared. Of the 13.4 ha, 6.5 ha consist of relatively well conserved swamp and temporary inundated forests.  The area impacted by the project accounts for 0.7% of all swamp and temporary inundated forest areas in the Project’s area of influence and around 0.03% of the total surface of these habitat types in Ivory Coast.

Completion of the ESIA included desktop review, coarse-level mapping of natural vs. modified habitats, preliminary Critical Habitat screening, scoping visit, rapid biodiversity surveys by local specialists over a 5-day period, and community interviews.  Additionally, a desktop review and the result of fishermen interviews were used to develop a baseline for Lake Ebrié, located 1 km north of the site. The ESIA includes an Ecosystem Services review and identification of priority ecosystem services and identifies impacts on priority Ecosystem Services and proposes mitigation measures.  While the current project area is mostly rural, with no industrial activity, the ESIA identifies possible future development plans in the same area, which could lead to cumulative impacts on these natural habitats. The main planned development is the extension of Abidjan towards the west (Grand Abidjan de l’Ouest), which includes the creation of approximately 60,000 new homes around the villages of Dabou and Jacqueville.

The ESIA also include undated reports from various community members regarding the presence of Western chimpanzees (Pan troglodytes verus), which are IUCN Red List Critically Endangered (CR) species, within the project’s area of influence. A block of swamp forest fringed by temporary inundated forest to the northeast of the site, identified in the ESIA as the most likely area of refuge for chimps, was surveyed in February 2019 to confirm the presence of chimpanzees in the project area and obtain an estimate of the size of the population. A team of national primate experts carried out the survey, and an expert affiliated with the IUCN Section on Great Apes reviewed the methodology and results. The rapid survey did not identify any signs of chimps either through fieldwork, camera traps or focus groups with members of local communities.  

An additional biodiversity study was undertaken post-ESIA and has been disclosed alongside this ESRS. A desktop assessment and rapid field surveys were undertaken. The study includes an updated Critical Habitat Assessment (CHA), habitat mapping exercise, updated biodiversity impact assessment and development of detailed mitigation measures. A Biodiversity Action Plan (BAP) and Biodiversity Monitoring and Evaluation Plan (BMEP) have also been included in the document (as per ESAP #21, #22 #23). The study also includes an update of the Ecosystem Services Review included in the ESIA.

The updated CHA confirmed that the project is located in Critical Habitat for two restricted range amphibian species (Phrynobatrachus sp. - which is new to science - and Morerella cyanophthalma). After avoidance, minimization and restoration measures have been implemented, there will be a significant but limited residual impact to the habitat of these species. In order to achieve Net Gain for the species and using their habitat as a proxy, the Project’s biodiversity consultants have identified the need for an offset.

The Project’s offset strategy (as defined in the BAP) is based on financial contributions to the management of the nearby Azagny National Park. The Park is located 50 km to the west of the project site and chosen as offset site because it contains the same habitat types present in the project area. One of the two Critical Habitat-triggering amphibian species has already been confirmed as present at the offset site. Based on expert opinion, the second amphibian is likely also present at the offset site and presence will be confirmed through field surveys. Actions to reduce deforestation and improve the knowledge of key species distribution and conservation needs will be implemented by the Park managers as compensation for project impacts.

The Ivory Coast Protected Areas agency (OIPR) and Atinkou are in the process of negotiating a binding agreement that defines specific mitigation measures and includes a commitment to implement the Project’s BAP. In addition to the Monitoring and Evaluation Plan (BMEP) included in the Project’s BAP, a committee formed by the OIPR and Atinkou will be set up to monitor implementation of compensation activities and to evaluate their effectiveness. The total financial contribution will be EUR107,000 disbursed over 10 years. The amount has been set based on a similar offset in Côte d’Ivoire. This amount constitutes 2 percent of the current budget of the Park and will not replace any of the existing budget.

The project will also fund a 10-year field-based research project to improve understanding of the distribution of the Critical Habitat-triggering amphibians. The findings of the field work will enable better conservation of the amphibian species. The total funding provided by the project for amphibian research will be of EUR30,000.

Other species of concern for the Project include: manatees (Trichechus senegalensis, VU), reported by local fishermen as present in the project area (Lake Ebrié) and the Cercopithecus lowei (VU) a primate endemic of the south of Ivory Coast and south-west Ghana. Habitat-focused mitigation measures have been identified to avoid impacts to these species.

Cooling water for the plant will be abstracted from and discharged into the lake. During construction, the lake will be used to transport machinery and construction material in barges to a landing point to be constructed in the proximity of the Jacqueville Bridge. Lake Ebrié extends for over 140 km to the north and north east/west of the site, with a width of 4 km. It is separated from the sea by the Vridi channel. Despite high pollution levels, the ESIA identified the potential presence of manatees in the lake as well as a rich fish population. Fishing and harvesting of bivalves and crustaceans are significant activities in the lake. As required in ESAP#22, specific mitigation measures to protect biodiversity and ecosystem services of Lake Ebrié have been included in the BAP. In the event that dredging is required to enable transport of construction materials, the BAP will also include specific measures to adequately assess and mitigate the impacts of dredging activities.

The transmission line overlaps one legally protected area (Audoin Classified Forest), triggering paragraph 20 of IFC Performance Standard 6 (PS6).  According to the ESIA, the Audoin forest has a surface of about 5,300 ha and is utilized by local communities. The classified forest area is mostly modified by human activity except for a humid low-lying area that constitutes a biodiversity-rich habitat. No government management plan exists for the Audoin Classified Forest. Additional biodiversity studies concluded that the area of the forest to be traversed by the transmission line is highly degraded and has been partly “declassified” (i.e. it is no longer part of the classified forest). The “declassification” took place to allow the construction of a military camp and housing and it is not linked to the Project. 

The additional biodiversity studies identified four priority Ecosystem Services provided by the project area: fisheries, provision of water resources, cultural value linked to the presence of large trees and regulation of surface and groundwater. The mitigation measures included in the BAP and other project documents were considered appropriate by the biodiversity consultant to mitigate any residual impacts to priority Ecosystem Services.  

Stakeholder engagement

Atinkou developed a Stakeholder Engagement Plan (SEP) in January 2019 with the support of ERM and their local partner ENVAL. The first draft of the SEP mainly captures the consultations undertaken as of November 2018 for the ESIA preparation. Several consultations were organized with communities potentially impacted by the power plant (Taboth) and the transmission line (Sassako, Ndjem and Abreby). During these consultations, communities raised concerns regarding mainly compensation rates for land loss and potential negative impacts of the transmission line on communities’ health and safety. Consultations with communities helped further understand potential impacts from the project. 

The current draft of the SEP needs to be expanded with details for additional engagement especially with key stakeholders including Environment Protection Government Agencies and NGOs, SICOR company which owns the coconut trees plantations adjacent to the power plant site, the National Army Forces planning to develop a military camp to be crossed by the transmission line. Atinkou shall update the Stakeholder Engagement Plan (ESAP #24) to detail engagement planned going forward and document engagement done with key stakeholders.   

Atinkou plans to develop and implement an external Grievance Mechanism as described in the current SEP. Atinkou shall develop and implement a structured Community Grievance Mechanism (ESAP #25) that is aligned to PS1 requirements and is able to receive and address, in a sensitive and confidential manner, complaints related to the project impacts.