The proposed investment is a Category B project as per IFC’s Environmental and Social Sustainability Policy because it is expected to have limited adverse environmental and social impacts during construction and operation, with impacts primarily expected to be short term, restricted to the site and relatively minor. Predicted adverse impacts can be avoided or mitigated by adhering to recognized site selection and design criteria, guidelines and performance standards, as described in the following sections.

IFC’s appraisal considered environmental and social management plans for the project and gaps if any between these plans and IFC requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable period are summarized in the paragraphs that follow and in the agreed Environmental and Social Action Plan (ESAP) disclosed in this review summary. Through implementation of these management plans and the ESAP the project is expected to be operated in accordance with Performance Standards objectives

Environmental and Social Assessment and Management System

Although YDE does not have an established environmental and social management system (ESMS), primarily because it is in the start-up phase, it has articulated its commitment to environmental and social aspects by drafting a corporate ‘Environmental and Social Policy Statement’, Additionally, as evidenced in the WAA project in Jordan, YDE conducts Environmental Impact Assessments were required by local laws and typically only applicable to ground-mounted projects.    YDE has a site selection process that focuses on two key factors; (i) grid capacity in the selected location, and (ii) government approvals and environmental clearance process.

YDE has additional procedures applicable to the design and construction phase of its activities in UAE (Dubai) and Jordan (so far limited to the Amman-WAA project). As evidenced in the Jordan WAA project, prior to the construction phase, YDE screened the site location for visual impacts, (far and near) shading losses, specific arrangements needed for water supply, waste management, access to the site and run-off water management. YDE develops Health & Safety guidelines for the EPC and includes them as legal obligations in the EPC contract. In the case of the WAA project, the HSE guidelines included the following; Health, Safety, and Environment (HSE) Statement; HSE training requirements for the contractor; Planning, measuring, auditing and reviewing procedures of HSE performance; required resources; Organization for HSE implementation; Fire arrangements; accident and injury reporting; first aid arrangements; waste management; traffic management; and emergency procedures.  Also, in WAA, the EPC contractor (Spectrum) developed a Safety Program with a Safety Manual covering such aspects as; Safety Overview and commitment; Scope, applicability and responsibilities; Safety requirements (orientation, inspection/worker observation/emergency response instructions/fire safety/accidents, medical treatment and reporting instructions/first aid kits amongst other measures); Personal Protective Equipment (PPE); Tools; Hazardous Energy Control (LOTO). Except for a ‘Health, Safety, and Environment (HSE) Evacuation Policy’ for its Dubai (solar rooftop) operations, YDE does not yet have examples of HSE procedures for operation and maintenance (O&M) phase. Going forward, to promote consistency in environmental, health, safety, and social management across its Jordanian and UAE operations and as described in ESAP item #1, YDE will develop and implement an environmental, social, and health and safety management system (ESHS MS) in line with applicable aspects of IFC Performance Standards (PS). The ESHS MS will apply to construction and operation of roof-top and ground-mounted projects and include plans and procedures applicable to the company and its contractors. The ESHS MS shall include at least the following items: (i) ESHS Policy, (ii) identification of the risks and impacts, (iii) management programs and plans (covering aspects applicable to YDE operations such as contractor management; occupational health and safety; and waste management), (iv) organizational capacity, responsibilities and competence, (v) training programs, (vi) emergency preparedness and response , (vii)  monitoring actions and an overarching system for reporting and tracking non-compliances, (viii) stakeholder engagement plan.  The ESHS MS will include a site E&S screening procedure to guide YDE in the avoidance of potentially significant E&S risks in the selection of sites for ground-mounted systems such as, for example: land expropriation; impacts on significant biodiversity resources (critical habitat); indigenous people’s communities without their consent; and critical cultural resources.

Organizational Capacity

During the construction phase of the WAA project in Jordan, YDE’s appointed project manager acted as the EHS focal point overseeing the EPC contractor obligations under the Health & Safety Guidelines discussed above. Going forward and as described in ESAP item #2, YDE will appoint one qualified Environment, Social, Health and Safety (ESHS) Coordinator in Jordan and one in UAE whose main responsibilities (possibly amongst others) will include development of the ESHS MS and oversight of YDE and their EPC and O&M contractors’ compliance with YDE’s ESHS policies and procedures.

 YDE currently has 7 people working for the Company in Jordan and 18 in UAE.  These numbers are expected to increase to approximately 8 workers in Jordan and 20 workers in UAE as the Company ramps up construction of projects in its pipeline.  Additionally, the company is expected to generate an average of about 85 and 75 jobs in Jordan and UAE respectively on an annual basis for construction project and 30 and 25 respectively during long term O&M activities by year 2020. In Jordan the O&M labor will consist of Engineers, Technicians, and Security. At least 95% of this labor will be Jordanian, with all of the security teams and some of the Technicians originating from the communities near the solar plants. In the UAE most of the labor will be from other countries including Jordan, Pakistan, and India.

Human Resources Policy and Management and Employee Grievance

While the company does not have an overarching consolidated Human Resources (HR) Manual, it has developed different policies at the corporate level (based in Dubai), but also applicable to its Jordan office. These policies and HR documentation include: Employment policy (covering equal opportunity, work schedule, general conduct, sexual harassment); external grievance mechanism; anti-bribery corruption policy signed by the CEO; compensation and benefits; and hiring policy. YDE to provide IFC with a sample employment contract for each country office reflecting aspects such as wages, benefits, training, working hours, etc..; In addition to evidence on how EPC HR risks are managed in each country office/operation.

YDE HR documentation is consistent with the principles and requirements of IFC PS2. While at present HR policies are mainly developed at the corporate level mainly from Dubai office, as described in ESAP item #3 the Jordan office will develop an internal HR manual in line with Jordanian labor law and consistent with IFC PS2 requirements and will appoint an HR coordinator. The HR manual shall include a worker grievance mechanism covering both construction, and O&M phases and will inform its workers and third-party / EPC workers of this mechanism according to PS2 requirements. YDE will also ensure that EPC/O&M provider apply these to their sub-contractors. Training workers on the Human Resources Policy and Procedures is to be included in EPC/O&M’s procedures. YDE to share with IFC YDE Corporate HR procedures/ Dubai & Jordan offices HR procedures (if different due to national regulations in UAE and Jordan) + EPC HR procedures

Occupational Health and Safety (OHS)

In recognition about the importance of occupational health and safety (OHS), the company has developed a Safety Manual which covers certain aspects of YDE’s office and field operations including, for example, HSE Emergency Evacuation Coordinator responsibilities and evacuation procedures and life and fire safety training.  As described above, for the project site in WAA project in Amman, the EPC company developed a Safety and Health Policy for workers and sub-contractors, an EHS plan and an Emergency Response plan.

Going forward and in order to ensure a consistent and comprehensive approach to OHS management across YDE’s operations, YDE will development and implement an OHS management plan and supporting procedures as described in ESAP #1, covering construction and operational phase OHS risks of YDE’s employees and contractors including such aspects as: work-in-heights/fall prevention; heat and sunlight exposure; lifting equipment; electrical safety; training; and auditing/monitoring (ESAP #4).

This project is expected to contribute to the reduction of greenhouse gases (GHG) emissions by adding more renewable generation to the grid-generated power, and substituting fossil fuel combustion of off-grid systems. Potential annual CO2-equivalent eq) emission reductions, assuming YDE reaches its business target of 200MW installed capacity in Jordan and UAE by 2023 will be about 223,265 tons CO2-eq per year.

Water and Wastewater: Water requirements during construction are minor, consisting of water for cement mixing for ground mounts and foundation, washing equipment and drinking water. At YDE’s only existing ground-mounted plant in Jordan the company plans to clean the panels using both dry and wet cleaning methods. Water use for cleaning purposes is planned to depend primarily on water supply from mobile water tanker trucks and water storage tanks. It is estimated that cleaning will take place 12 times per year depending on the need (not necessarily on a monthly basis), with an estimated water use of 24m3 per cleaning in the case of the WAA project (amounts will vary from project to project). No chemicals will be used during this procedure.. Typical PV solar operations include small control rooms with an average of less than 10 workers at any point in time.  These operating rooms are typically serviced by public water supplies or water storage tanks and  septic tank for human waste and sanitation purposes. With the exception of the need to dispose of solar PV panels due to damage/operational defects or at the end of their life-cycle, the installation and maintenance of solar energy systems generate small volumes of generally non-hazardous waste such as packaging from new panels, inverters, and other components which are disposed of by local waste service providers.   During construction of the WAA, damaged panels were collected by the EPC contractor and stored in a container on site. Going forward and as described in ESAP item #5, YDE will develop and implement waste management plans and procedures to cover solid and liquid wastes, including a clear policy towards panel recycling and disposal in line with national laws and international standards.

The Project involves either the installation of solar panels on rooftops or ground-mounted solar plants located on vacant land. Electrical systems are insulated and earthed, with safety features including access control such as fences to keep the public away from electrical installations. 

Site Security

YDE’s security arrangements depend on the type of security risks which are limited for both roof and ground-mounted operations and which often include the use of unarmed security.  YDE will develop and implement security management plans and procedures to ensure that security arrangements governing the screening, hiring and management of these unarmed security personnel are consistent with the requirements of PS4, as captured in ESAP # 7.

Stakeholder engagement & grievance mechanism

In terms of stakeholder engagement for the WAA project in Jordan, YDE completed a stakeholder mapping matrix and developed an engagement plan and assigned a focal point from the local community to communicate grievances during the construction phase. However, overall, impacts on local communities due to roof or ground-mounted solar projects are minimal given that YDE’s projects are typically small and are located in vacant and often remote land (in the case of ground-mounted systems). Going forward and as part of the ESHS MS development (ESAP #1), YDE will develop and implement a stakeholder engagement plan applicable to construction of operations of all of its projects.

In terms of grievance mechanism, YDE has already developed a ‘Grievance Mechanism Procedure’ established at the corporate level to formalize the management of grievances from YDE’s stakeholders. The grievance process provides an avenue for stakeholders to voice their concerns and gives transparency on how grievances will be managed internally, which aims to reduce conflict and strengthen relationships between external stakeholders. YDE’s Grievance Procedure includes the following elements; scope, definitions, grievance reporting channels, roles and responsibilities, process, appeal, reporting, storing of grievances.