Identification of Risks and Impacts:  An Environmental & Social Impact Assessment (ESIA, February 2017) was prepared for the project by Arabtech-Jardaneh (AJ), a regional consultancy group . The ESIA was prepared  in accordance with Jordanian ESIA regulations and also references the IFC PSs. As mentioned previously, the ESIA documentation disclosed with this summary comprises an ESIA, an ESMP, a Surface Hydrology Study, aSoaring Birds Sensitivity Analysis, and an Archaeological Survey Report, and considers construction, operation, and decommissioning phases of the project.

The ESIA is generally fit for purpose, though it does not consider the matter of operations phase water use, which is a relevant E&S impact given Jordan’s water scarcity. No cumulative impacts have been identified, although there is one smaller solar PV plant planned in the broad vicinity of the project site.

Transmission Line:  A dedicated 10 km 132 kV transmission line will be constructed by NEPCO to link the project to the grid. This line was not covered under the ESIA as no route was available and because its routing and construction is not under Masdar control. NEPCO does not conduct ESIAs for such transmission lines. As Masdar is required under IFC PS 1 to identify opportunities to collaborate with NEPCO in order to help achieve E&S outcomes consistent with the Performance Standards, the company has agreed to obtain the proposed transmission route corridor from NEPCO and to commission an E&S screening study of this corridor in order to identify potentially sensitive E&S issues or receptors (ESAP action # 1). The company will then share this screening report with NEPCO, in order that the utility is able to complete detailed route alignment taking into consideration the location of these sensitive receptors (if any).

Management Programs:  The ESIA contains an ESMP for the construction and operational phases of the project.  Key aspects covered include air quality, noise, soil, visual impacts, waste, hydrology, health & safety, biodiversity, cultural heritage / archaeology, traffic, local and workers’ communities.The ESMP outlines the key mitigation measures, details on monitoring/reporting actions and frequency, along with the performance indicators that the company and its contractors will implement during the different phases of the proposed project to meet Jordanian and IFC E&S requirements. Construction and operations phase E&S management and monitoring responsibilities will be shared between the company and the EPC and the Operation & Maintenance (O&M) contractors. Both the EPC and O&M contractors will be contractually bound to adhere to the requirements to which they are assigned as the responsible party in the ESMP. 

Baynouna will ensure that workers understand the requirements, measures, and protocols stipulated within the ESMP and receive training on EHS matters.  They will also ensure that all E&S personnel are competent to carry out their duties, or, where necessary, arrange for suitable training to be undertaken.

Organizational Capacity and Competency:  An Environmental, Health & Safety (EHS) Officer will be employed on-site by the EPC contractor, as stipulated in the EPC contract agreements. As identified in ESAP action item #2, the company will either ensure that the Owner’s Engineer (OE) hires an EHS Officer during construction, or will hire an EHS Officer directly. During operation, there will be an EHS Officer based off-site contracted by the O&M contractor. The EHS officer contracted by the EPC / O&M contractors will be responsible for the day-to-day implementation of the ESMP, including monitoring actions and reporting.  Baynouna’s EHS Officer will be responsible for supervision of the implementation of the ESMP, including tracking compliance and reporting.  The latter will also be responsible for interfacing with and responding to any grievances which are reported through an external communication mechanism as per ESAP Action Item #3. Other ESMP measures, for example follow-up assessment of informal land use in spring 2017, will be the responsibility of the company.

Emergency Preparedness and Response:  Baynouna will ensure that an Emergency Preparedness and Response Plan is developed by EPC / O&M contractors as described in sub-section below on ‘Occupational Health and Safety’ in PS2.

Monitoring and Review:  EHS monitoring requirements are included in the ESMP for construction and operations phases as mentioned in the sub-section above on ‘Management Programs’. 

The project is expected to employ approximately 300 workers during peak construction; during operation, there will be an average of 20-30 persons on site. The company has committed to hiring 70% of its workforce locally during construction.

Human Resources Policies and Procedures:  The company will develop its own overarching Human Resources (HR) Policy in line with IFC PS2 and with Jordanian labor law and will ensure that the HR Policy and Procedures developed by the EPC and O&M contractors are fully alignment with these (ESAP Action Item #4). Any sub-contractors responsible for hiring workers will be required to implement HR Policy and Procedures in line with those of the EPC / O&M contractors. The HR Policy and Procedures will stipulate that the terms of employment, such as wages and benefits, hours of work, overtime arrangements and overtime compensation, annual and sick leave, maternity and paternity leave, vacation and holiday, are established according to national labor regulations, and will be included in employee contracts. Additional workers’ benefits for full-time operations staff will include health insurance and medical assistance, among others.  Working conditions (including health, safety and security), employee termination, prohibition to employ minors, disciplinary actions, workers’ rights and obligations, employer’s rights and obligations will also be referenced. No child or forced labor will be used by the project at any time. Proof of identification and age will be required at the time of employment. The company will ensure that the EPC and O&M contractors provide all workers – including sub-contractor workers – with written documentation concerning the terms and conditions of their employment, including their rights under Jordanian labor regulations, e.g. in relation to hours of work, wages, overtime compensation and so forth, as per IFC PS2 requirements. Induction training on the HR Policy and Procedures and basic safety awareness training will be provided to all newly hired workers.  Other types of technical skills training will be identified for staff on an as-needed basis.

Workers’ Organizations:  It is unlikely that workers’ unions will be involved in the project as the main concentration of workers will be on site during a short-lived construction period only; as noted above, the operations staff will be small. The company will not in any way prevent workers from seeking to join unions or other workers’ organizations; this will be specified in the HR Policy and Procedures.

Non-Discrimination and Equal Opportunity:  The company is committed to avoid all forms of discrimination against its employees, based on the age, gender, sexual orientation, health, race, nationality, political opinions or religious beliefs of its counterparties. The requirements of non-discrimination and equal opportunities will be extended to all contractors and subcontractors as part of contractual obligations.  

The company’s HR Policy will exclude the use of any form of forced or compulsory labor, in accordance with national law and IFC PS 2. 

Workers’ Grievance Mechanism:  As indicated in ESAP Action Item #4, the company will ensure that a worker grievance mechanism is established, including by its EPC / O&M contractors, to ensure that workers have the opportunity to raise any grievances and have these systematically recorded, tracked and addressed.The company will inform all direct and contracted workers of the grievance mechanism, as needed through the EPC O&M contractor, and describe how to make use of it during the induction training.  The grievance mechanism will also be accessible to other contractors and subcontractors performing work in core business processes of the project.

Occupational Health and Safety:  Key occupational health and safety (OHS) risks for a solar PV project include slips and falls, potential hazards from on-site moving machinery, heavy load lifting, exposure to electric shocks and burns, and safety issues related to PV module assembly. Given that local laborers may be employed during construction/operation, their lack of education or missing specified skills may increase OHS-risky situations. Taking into account the hot and arid project site, construction workers might also be at risk of dehydration, heat exhaustion and heat stroke if adequate measures are not taken, including work/rest schedules, hydration, awareness and first aid support.  

As identified in ESAP Action Item #5, the company will ensure that the EPC / O&M contractors develop a site-specific OHS Procedure for the construction and operations phase.  The procedure will be designed to be specific to the PV solar sector (in terms of industry specific hazards) and the project site. The OHS Procedure will also include project-specific Emergency Preparedness and Response plans.

The company will also ensure that the EPC / O&M contractors assess and track their OHS performance during both construction and operations. OHS performance evaluations will be carried out considering lagging (or trailing/downstream) indicators and leading (or upstream) indicators.  The EPC / O&M contractors’ EHS Officer will record and track any OHS incidents through an incident tracker and will report on OHS performance.

Construction workers will receive training on EHS matters, and in particular OHS (health and safety) awareness specific to their tasks, use of appropriate personal protective equipment, site rules concerning housekeeping matters such as waste management and traffic/driving safety. The company and its EPC contractor will ensure that all workers are overseen by suitably qualified site and project supervisors. This training will be delivered by the EPC contractor and supplemented as necessary by the client’s site manager. O&M work will be conducted largely by O&M contractor’s technicians who will receive specialized OHS training off site. 

Resource Efficiency: Greenhouse Gases:  The project is expected to generate approximately 560 gigawatt hours (GWh) of electricity per year.  Jordan’s current carbon dioxide emission performance (from fuel combustion) is 0.637 kg carbon dioxide per kilowatt hour (CO2/kWh) (according to International Energy Statistics, 2013).  Using this factor, the project is expected to avoid around 390,000 tons of CO2eq/year. 

Resource Efficiency: Water Consumption:  Resource consumption on a PV project is expected to be minimal, with the main resource of note being the water required for cleaning the PV modules. The company is still reviewing the technology options for cleaning the PV modules. As per the ESIA, the company is committed not to exceed a limit of 2,000 cubic meter (m3) of water per cleaning cycle with minimum four cleaning cycles per year expected, resulting in a worst-case water consumption of 8,000 m3/annum (assuming wet panel cleaning). The water will be trucked in from nearby municipal areas and stored in a tank on-site.

As indicated in ESAP Action Item #6, the company will consider the contextual risk of water scarcity in Jordan as a guiding principle for selecting a water efficient cleaning technology option (e.g. dry and/or robot cleaning), and benchmark the considered options against current performance indicators in the sector. The company will refine the cleaning regime during operations to avoid unnecessary cleaning and use of water. The company will include a key performance indicator relevant to water consumption per kWh generated as part of its Environmental Management Plan.

Pollution Prevention:  The company will require the EPC / O&M contractors to implement pollution prevention measures in accordance with the management and monitoring procedures contained in the ESMP to minimize the risk of any pollution and as needed remedy any accidental pollution in an effective and timely manner. As per the ESMP, the EPC / O&M contractors will also be required to produce a waste management plan prior to the commencement of construction incorporating designated waste storage areas, procedures for the responsible management of solid and liquid wastes and spill prevention measures for fuel and hazardous substances.

As per the ESIA, the design of the PV solar plant will take into account the potential surface water runoff and flood risks that were assessed as part of the Surface Hydrology Study. The EMSP includes measures (for example channelization, creating depressions, constructing culverts) that take into account the local characteristics of the natural streams and wadis. The EPC contractor will be responsible for implementing erosion control and drainage measures on site during project construction. 

Wastewater Treatment

Other than minor amounts of sanitary wastewater the project will generate little wastewater, with all run-off and rainwater being allowed to evaporate and/or infiltrate the ground. The project will use septic tanks to be disposed of regularly during construction and operations.