Performance Standard 7 on indigenous peoples is not applicable as the socio-economic baseline studies and the additional study confirm that no indigenous peoples (i.e. pygmy peoples), as per the PS7 criteria, are living or using the natural resources in the direct or indirect area of impact of the project. The study was conducted by an anthropologist with experience in Gabon and was based on a literature review and interviews with various stakeholders, including NGO representatives of pygmy groups, experts from academia, and community members in the project area of influence. The assessment concluded that there is no presence of pygmy groups within the project area of influence.    

 The Kinguele Aval project will flood 187 ha of the Monts de Cristal National Park (MCNP - 0.3% of the total area of the Park), as well as 74 ha of the park’s buffer zone, impacting Critical Habitat values. Furthermore, this project will be the third hydroelectric power plant in the Mbé River, downstream from existing Kinguélé 58 MW and Tchimbélé 69 MW power plants, in addition to yet a fourth one, Ngoulmendjim 73MW Hydro, planned to be built downstream from this Project in the Nkomo river, and therefore there are potential cumulative impacts on the biodiversity values, ecosystem services and river hydro-morphology that could be significant. Consequently, as expected environmental and social adverse impact could be diverse and largely irreversible this project has been categorized A according to IFC's Policy on Environmental and Social Sustainability.    

 E&S Impact Assessment Process

An ESIA for the Project was carried out in accordance with the Environmental Code of Gabon (2014) focused on meeting relevant national requirements and regulations.  This ESIA was submitted to the General Direction of Environment and Protection of Nature (DGEPN) in the Ministry of Forests and approved via environmental licensed 001774/MEMEPCPAT/SG/DGEPN on date 10/25/2019. After, in the context of the financing sought by project sponsors from multilateral and international development banks, the original ESIA process has been complemented to include further focused studies and assessments to meet both IFC Environmental and Social Performance Standards and AfDB Safeguard Policies. These additional studies were performed by a consortium of ARTELIA, EDF and BIOTOPE, and included but not been limited to (i) additional social baseline assessment, further development of the stakeholder engagement plan, and development of a PS5-compliant Livelihood Restoration Plan (LRP), (ii) focused screening/ confirmation of  the absence of pigmy peoples living or using the natural resources in the direct and indirect area of impact, and (iii) Critical Habitat Assessment and Biodiversity Action Plan (BAP).

The ESIA process included extensive baseline studies, analysis of project alternatives, assessment of the direct and indirect project construction, commissioning and operation impacts, including contribution to cumulative impacts in the River Mbé-Nkomo watershed, and the impacts from Associated Facilities, such as the Transmission Line (TL) and access road. The assessment of project alternatives included consideration of impact avoidance by selecting the option with the smallest footprint in the Monts de Cristal National Park (MCNP) and the lowest dam height. This resulted in a reservoir area of almost half of other options. Existing brownfield areas will be used to locate associated infrastructure such as the workers camp, avoiding clearance of additional habitat. The preferred option also minimizes the length of access road to be upgraded and no new road construction will take place since construction material and workers will be transported by the river to an already existing docking area.

The main environmental, social, security, labour and occupational health and safety (ESHS) impacts and risks identified in the assessment process, and their mitigation measures, are discussed in the relevant sections of the ESRS. In general they include, and are not limited to: (i) direct impacts on Critical Habitat through inundation of a total of 261 ha of Monts de Cristal National Park (MCNP) and its buffer zone; (ii) cumulative impacts on aquatic and riparian ecosystems and services resulting from modifications to existing water, sediment and biota flow (eFlow) dynamics in the Mbé-Nkomo river system; and (iii) economic displacement as result of 65 hectares of uncultivated forest land used for hunting and collection of non-timber forest products by the local community. The 40-month construction period will involve approximately 700 workers at peak time, and will present typical ESHS impacts and risks associated with construction of large infrastructure projects such as (iv) reduced air quality due to increase in  dust and noise from construction and operation of heavy machinery, (v) solid and hazardous waste and wastewater generation and discharges, (vi) occupational and safety risks to construction workers including risk of boat capsizing / spills and drownings associated with fluvial transportation, and (vii) population influx (construction workers, job seekers) increasing risks to neighbouring community health and safety, including potential increase of Gender-Based Violence (GBV).   A construction camp will be established by the EPC Contractor outside the nearest village of Andok Foula, about 7 km from the dam site.  This camp will be set up at the site of an old construction camp and will have a dedicated diesel power plant which will provide the power needed during construction.  Following construction, some of the facilities will be retained for use during operations and maintenance (O&M) phase.

Since the project is located downstream of the two existing hydropower schemes it will only require the construction of a 300-m powerline to connect to the existing 225 kV TL, less than 1-km of new access roads, and realignment 1.4 km of the existing access road to route it around the new reservoir upstream of the dam.  Construction materials for the Project will be provided from nearby existing quarries and no off-site borrow pits are envisaged.

As a run-of-river scheme, the dam will not be used to regulate the river flows.  Once the reservoir is filled, then in the operation phase all the inflows will be immediately transferred downstream through the turbines, limiting the changes to the river flow of the River Mbé and impacts on the aquatic ecosystem downstream of the project’s tailrace.

Cumulative Impacts

The analysis of cumulative impacts was carried out as part of the ESIA. In particular, this focused on the potential cumulative impacts related to developing a new hydro scheme on the Mbé River in addition to the two existing Kinguélé and Tchimbélé hydro schemes. Kinguele Aval contribution to basin-wide cumulative impacts is limited as it sited in a river system already hosting two hydropower projects, will impact a small area of the MCNP and its buffer zone, and uses existing roads and transmission lines corridors. Management measures related to hydrology, sedimentation, operations, etc, have been included in the planning, taking account of the cumulative impact analysis. However, the analysis of cumulative impacts was high level and some key gaps still remain (e.g. connectivity assessment, biodiversity, communities’ access to ecosystem services and potential loss of livelihood). Furthermore, irreversible cumulative impacts risks are likely to materialize if the planned Ngoulmendjim hydropower project, to be located on the adjacent Komo River, is constructed. 

Furthermore, as part of the appraisal process, the IFC has engaged with The Nature Conservancy (TNC) and is exploring further cooperation under a parallel Advisory project with the Government of Gabon (GoG). TNC has studied the cumulative impacts of various hydropower development scenarios in the Mbé and Komo Rivers basins to help the GoG identify hydropower development scenarios which balance impacts and benefits on valued environmental and social components (VECs) in a way that is acceptable to all stakeholders. Based on multiple scenarios for hydropower development in the Mbé and Komo River basins, the Kinguélé Aval project falls within approximately one-third of the scenarios which strive to minimize environmental and social impacts while maximizing generation and financial benefits. 

The objective of this emerging Advisory engagement is to strengthening understanding and capacity in Gabon to implement good environmental, biodiversity and social industry practices, and further expand the use of TNC’s HbD process to the whole country and encourage further stakeholder consultation in order to evaluate scenarios for the mid-to-long term development of energy in Gabon, including in the Mbé-Komo River system, and including various alternative energy generation technologies.  This will increase GoG’s and other relevant stakeholders’ understanding of the tradeoffs that are inherent across hydropower development scenarios and help identify those development scenarios that balance impacts while providing power to Gabon’s growing economy. 

As a requirement to IFC’s investment, the client will apply best efforts to enter into a tri-partite agreement between the GoG-TNC and IFC, drafted and organized by these three parties, to foster the consolidation of a management strategy to guide any further development of hydropower in the Mbé-Komo River system sustainably (ESAP #1). Further, the client’s involvement in this agreement implies, not only including within its own ESMPs measures to mitigate its contribution to cumulative impacts, but also participating in meetings, providing available data, and sharing knowledge.

Management Plans and Programs

Asonha Energie has aligned its environmental and social investment policy with that of several international finance institutions, including the IFC.  The ESIA work included the development of an Environmental and Social Management Plan (ESMP) for both the construction and operation phase of the project.  The project’s framework Environmental and Social Management System (ESMS) and ESMP will commit the developer, EPC contractor, and operator to implement the environmental and social actions in line with Gabonese regulations and IFC Performance Standards.  It will be integrated into all contractor legal documents.  The framework ESMS and ESMP includes a set of management plans and procedures, many of which will be the responsibility of the EPC and O&M contractors.  The detail of these plans and procedures will be further developed by the project company and the contractors before the start of construction and operation (ESAP #2), including the development of a compliance registry detailing all required local permits (e.g. permission to develop within the core and buffer of the MCNP) as well as Lenders’ requirements.  The ESMPs include, but are not limited to: Biodiversity Management Plan; Atmospheric, Dust and Noise Emission Management Plan; Waste Management Plan; Water Quality and Discharge Monitoring Management Plan; Environmental Monitoring Plan; Earthwork and Erosion Management Plan; Explosive, Hazardous Product and Pollutant Management Plan (including spill response plan); Road Traffic Management Plan; Camp, Access and Installation Security Management Plan; Influx Management Plan; Community Health and Safety Plan; Cultural Heritage Management Plan; Livelihood Restoration Plan; Stakeholder Engagement Plan, including Communication Procedures and Grievance Mechanism; Local Employment Plan, including Recruitment Procedure; E&S Audit Procedures; control procedures for the panel of experts audits and the Occupational Health, Hygiene and Safety Plan.

Sponsor ESHS Capacity and Organizational Structure

Asonha Energie has employed an ESHS Manager and Community Liaison Officer (CLO) during the project planning and intends to recruit further specialists as necessary during construction and operation, for ESHS management and monitoring roles. Asonha Energie will develop a staffing plan and organigram to guide the project ESHS staffing based on a timebound plan and a defined budget (ESAP #3). The EPC and the O&M contractors will be required to include specific experience and capacity in their ESHS teams, including for occupational health & safety.  The ESHS Manager of Asonha Energie will monitor the ESHS obligations and practices of both the EPC and O&M contractors (ESAP #4).

Monitoring and Review

The ESMP includes a framework of ESHS monitoring, including monitoring frequency, performance indicators and targets.  In addition to the monitoring and reporting plans to be implemented by the EPC and O&M contractors and the sponsor, several independent external ESHS supervision activities will be implemented in line with lender requirements. Furthermore, the Lenders will hire and Independent Environmental and Social Advisor (LIESA) to perform quarterly visits during the construction period and first year of operation and yearly thereafter, to ensure the project is complying with all ESHS requirements, including the agreed ESAP.

Community Development

The ESIA baseline work identified that 34 people live in Andok Foula, and that many properties are unoccupied because of movements of people to towns to look for employment.  Most people maintain strong ties to the villages and are likely to return if opportunities arise and/or at certain times of year (e.g. school holidays).  The local villages have no access to safe drinking water nor centralized power supply, and generally can be considered precarious dwellings. The main local economic activity is slash-and-burn subsistence agriculture, fishing, forestry, and hunting. However, these activities have been greatly limited due to their proximity to the National Park, which has created tensions between local population and conservation efforts. Furthermore, during consultation activities, locals expressed clear expectation that if another hydropower development project was going to be build that it would provide economic opportunities / employment for them, as well as better infrastructure and at a minimum, electrification of their homes. There is very limited local commercial activity in the area. Based on initial consultations with the community, a Local Community Development Plan is being prepared (ESAP #5), containing two main components: (i) provision of electricity to Andok Foula village and (ii) setting up a local development fund for small local community projects (e.g. in healthcare, education, culture, and resolution of human-elephant conflict). As part of community engagement on the Community Development Plan, the Project will thoroughly engage with the communities on the detailed conditions of the support to be provided in order to align community expectations and project support.                                                  

 The construction of the Project is forecast to take 40-45 months.  The number of workers required will vary during construction and will depend on the selection of the preferred EPC contractor, but the peak number of workers is expected to be at 900.  The EPC contractor will implement a Recruitment Procedure which will prioritize employment from local villages within the project's area of direct or indirect influence (ESAP #6).  The employment opportunities and application process during construction will be communicated to the local villages.  The staff levels during operation are not yet known but expected to be between 30-50 total.

Human Resources Policies and Procedures

The sponsor will require the EPC and O&M contractor to prepare and implement Human Resource Policies and procedures governing labour and working conditions, consistent with Gabonese labour legislation and PS2, specifically prohibiting any type of forced or child labour, (sexual) harassment and articulating hiring and promotion policies which will not discriminate based on age, gender, ethnicity, or any other socio-economic characteristics (ESAP #7). All employees and contracted workers will be issued with individual contracts of employment providing clear terms and conditions as well as benefits.  These will refer to a worker Code of Conduct in relation to the construction and operator’s camp and interactions with local communities, and explicitly include gender-based violence (GBV) training and zero-tolerance policies.

Workers Organizations, Non-Discrimination and Equal Opportunity, and Grievance Mechanism

Freedom of association and establishing workers’ representation will be reflected in the Human Resource (HR) policies and procedures of the contractors.  The Sponsor will also require the EPC and O&M contractor to develop and implement non-discrimination and equal opportunity, demonstrated in their HR policies and relevant procedures.  The Sponsor will develop and implement a grievance mechanism for workers, and the procedures will be properly explained to all workers as part of their formal induction, including the method for raising grievances (ESAP #8).  The grievances will be recorded and resolved in accordance with the procedures. 

Workers engaged by third-party

The Sponsor will include ESHS provisions into the EPC and O&M contracts and contracts with sub-contractors providing services to the 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. In cases where the contractors/sub-contractors are not able to provide a grievance mechanism, the Sponsor will extend its own grievance mechanism to workers engaged by contractors/subcontractors. The Sponsor will monitor third-party compliance with approved ESHS requirements through regular labor audits to assess compliance with Gabonese law and PS2 requirements per ESAP #9.

Occupational Health and Safety

Accommodation will be provided for the construction workers at a dedicated camp near Andok Foula and designed and constructed to comply with requirements and guidance by IFC and clearly specified in the IFC-EBRD Worker Accommodations: Processes and Standards (2009) (ESAP #10).

The EPC contractor will be required to prepare and implement an Occupational Health, Hygiene and Safety Plan to protect construction staff and nearby communities (ESAP #11).  Other required plans that are relevant to worker safety include: Emergency Prevention and Management Plan; Explosive, Hazardous Product and Pollutant Management Plan (including spill response plan); and Road and River Safety and Logistics Road Transportation Management Plan.  All workers will be trained in the implementation of the Occupational Health, Hygiene and Safety Plan, including use of personal protective equipment (PPE), and the relevant workers will also receive job-specific training in the other management plans.  These requirements will be included into the EPC and O&M contracts, as well as the requirement to monitor and report performance related to health and safety.                                       

 Water Quality: The water quality in the River Mbé is typical of tropical river in forest environment.  Under normal operating mode, the analysis shows that the impact on water quality will be very low.  This low impact is due to the small size of the reservoir in relation to the daily inflows and hence the short reservoir holding time.  If the turbines are stopped a valve will be opened at the base of the reservoir to maintain a minimum flow of 20 m3/s downstream until the spillway overspills.  To avoid the risks that the water released from near the bottom of the reservoir is anoxic, the structure will integrate an aerator immediately downstream of the valve to oxygenate the water.  The Environmental monitoring plan includes water quality monitoring in River Mbé every two months during construction and every six months during operation phase.

Erosion and Sedimentation: The Kinguélé Aval dam will result in the build-up of sediment in addition to the blockage of sediment flow by the other hydro schemes upstream.  This Project will therefore contribute to disruption in sediment flow downstream in the Mbé River and into the Komo River catchment.  Silting up of the reservoir by sediment has a significant dependency on sediment passing through the upstream hydroelectric schemes.  The presence of bedrock reportedly limits the amount of erosion.  Mitigation measures will include integrating a bottom valve in the Project design that will allow some transit of the finest sediment fraction; and monitoring sedimentation downstream in the Mbé River and Nkomo estuary, in co-operation with operators of other existing and future hydro schemes.  Remedial measures that could be taken as a result of potential impacts identified from monitoring include dredging of the reservoir tail area, and adjusting the flow from the dam at certain low and high water times.  An Earthwork and Erosion Management Plan will be implemented by the EPC contractor for the construction phase and a sediment management strategy for the operational phase (ESAP #12).

Climate Change: Climate change analysis has been carried out as part of the feasibility studies and taken into account in the Project design (e.g. impacts on power production and risks of floods).  The ESIA estimates that the Project's operational greenhouse gas (GHG) emissions will be low (1,140 and 2,360 tCO2eq/year) and will have a positive impact in terms of avoiding greenhouse gas emissions compared to using thermal energy.  Ongoing climate analysis will be carried out during project planning in terms of the risks of future climate change scenarios on the project (ESAP #13).  

Noise and Air Quality: Emissions at construction site will be managed through application of good international industry practices (GIIP) to mitigate dust and construction/ transport noise, including a Blasting Management Plan, as well as noise from traffic bringing materials to site.  A Dust, Air Pollution and Noise Emission Management Plan will be developed in detail and implemented by the EPC contractor (ESAP #14).

Solid Waste and Wastewater: Domestic waste will be generated from the construction and operator camps and the contractors will be required to develop and implement a Waste Management Plan.  This will have the core principle of the waste hierarchy, to minimize waste generation, reuse, recycle and compost as a priority to disposal.  The waste generated will be handled by a licensed waste management contractor.  The Waste Management Plan will also include actions to manage the low quantities of domestic and industrial hazardous waste that will be generated during construction and operation, including where necessary the design and construction of WWTPs to meet discharge limits required under WBG General ESHS Guidelines.  The effectiveness of the control and treatment of domestic wastewater will be managed through the implementation of the Water Quality and Discharge Monitoring Plan and the Environmental Monitoring Plan (ESAP #15).               

 Key community health, safety, and security risks associated with the project include construction safety, dam safety, and road safety; and aspects related to the interactions with construction workers and potential influx of people seeking employment or business opportunities.  An old construction camp will be reused for the Project’s construction camp, near the village of Andok Foula, and that camp will become the permanent accommodation for the operators.  The EPC contractor will be required to perform a Security Risk Assessment and prepare and implement a Camp, Access and Installation Security Management Plan aligned with PS4 and with the UN Voluntary Principles of Security Forces and Human Rights (ESAP #16). This will include access control to site, employment of unarmed security guards, training, equipment and monitoring for security personnel, and recording of security incidents, code of conduct, training on sexual harassment and GBV covering the construction site and the worker camp.  An Influx Management Plan will be developed and implemented as part of the management plans required under ESAP #2.

Community Health and Safety

A Community Health and Safety Plan will be developed and implemented for the project as part of the management plans required under (ESAP #2).  A temporary medical dispensary will be built for the site, which will be available during some periods for emergency use by the local community in Andok Foula.  A partnership will be set up with Kango hospital to implement preventative health actions locally.  Two water boreholes will be installed with pumps at the village to improve water supply. Although the impact of the project on existing hydrology downstream of the dam is considered low, measures will be implemented on behalf of the local population to limit the risks to community safety from changes in downstream water levels (e.g. from plant restart after turbine shutdown, emergency electromechanical incidents, or total / partial dam structural failure). These measures will be key components of the Community Health and Safety Plan and include early warning systems, regular awareness campaigns, and precision monitoring of structural movement.  Similarly, awareness activities will be implemented in the community related to construction and road/ river transport safety. As noted above, a Road and River Safety and Logistics Transportation Management Plan will also be developed. The Sponsor will develop a community emergency response plan and provide training to the communities on the response plan. In the Project context, the likelihood of female employees working in remote or isolated locations or in close proximity to male employees with limited supervision presents a risk of occurrence of GBV in the workplace.  The project location in close proximity to communities also present a risk of project-induced GBV in the communities. For both GBV risks in the workplace and in the communities, the project will (i) carry out further assessment of the project specific GBV risks, (ii) propose adequate mitigation measures to address these risks, and (iii) implement these actions and monitor as applicable per ESAP #17.           

  For Disclosure

The Project is sited in WWF’s Atlantic Equatorial coastal forests ecoregion, which contains large blocks of evergreen lowland and cloud moist forest and is characterized by exceptionally high levels of species richness and endemism. The majority of the project footprint will be inside of the core (187 ha) and the buffer (74 ha) zone of the Monts de Cristal National Park (MCNP).  The project will occupy 0.3% of the core zone of the MCNP

The direct Project footprint will impact a total of 290 ha of land, 46 ha of Modified Habitat and 244 ha in Natural Habitat of which 261 ha are within the National Park or its buffer zone. Modified Habitat includes patches of degraded and secondary forest in the headworks area, evidence of human presence and industrial activities, forestry concessions, several quarries and associated infrastructure (roads and river transport facilities). Natural Habitat includes about 244 ha of well-preserved dense humid broadleaf forest to be inundated by the reservoir, as well as river habitat including rocky rapids, and riparian and swamp habitat. A total of 9 km of the main stem of the Mbé river and approximately 39 km of small and medium size tributaries will be also inundated.  Although there is commercial and subsistence bushmeat hunting due to the relative proximity to Libreville and the presence several villages and towns in the nearby area, and the project is the third hydro in a cascade, impacts of these activities have not significantly modified the downstream habitat nor the stretch of river that the project will occupy, and it is therefore considered Natural Habitat as it is composed of viable assemblages of plants and/or animal species of largely native origin that continue to maintain it primary ecological functions and species composition.

Based on the Critical Habitat Assessment performed to date, the project is located on Critical Habitats, given to the presence of 31 CH triggers, namely eleven aquatic and riparian plant species that are either Critically Endangered (CR) or Endangered per the IUCN Red List (Criterion 1) and/ are endemic or present a restricted range (Criterion 2), four terrestrial plant species (Criteria 1 and 2), four fish species (Criterion 2), two amphibians, two reptiles, forest elephant, two pangolin species, Western gorilla, chimpanzee (all Criterion 1) and three butterflies (Criterion 2). However, due to hunting, according to the BAP, large mammals are considered almost absent from the direct project area and even in the overall area of influence. On the other hand, rapids to be inundated in the larger tributaries provide habitat for several highly threatened aquatic plant species with very specific ecological requirements, and the project could potentially result in worsening their IUCN threat status.

Protected or Recognized Areas and Ecosystem Services: As stated before, the Project will be located in the MCNP and this activity has been authorized by the Gabonese National Parks authority (ANPN) as well as the General Directorate for Environment and Protection of Nature (DGEPN in French). One of the stated objectives of the creation of the MCNP was to protect the hydroelectric potential of the Mbé valley including the catchment of the existing Kinguele and Tchimbele hydropower dams. The forested areas within the park have both ecological and socio-economic values because they protect the Mbe river basin, which provides drinking water for Libreville. ANPN in Libreville and MCNP’s management have been in discussions with the project since the commencement of BAP and ESIA processes in 2017. Several meetings and workshops have taken place to discuss impacts on the MCNP and mitigation options, and as it will be further detailed below, the Project will contribute to the management of the MCNP through the provision of support and capacity building to ANPN and direct funding for additional guards during construction and operations. Communities living near the MCNP have been consulted during the preparation of the ESIA and key impacts of the Project will have in their livelihoods are covered in the LRP and community development programs.

Alien Invasive Species: No alien invasive species have been identified during surveys. The BAP includes mitigation measures to avoid the accidental introduction and spread of invasive species.  These measures will also be included in the EPC contractor’s ESMS under ESAP #25. The BAP also includes measures to support ANPN avoiding the introduction of exotic species in the reservoir for fishing and commercial purposes.

Expected Impacts on Biodiversity: As a run-of-river scheme that is not intended to regulate river flows downstream, there will be no significant seasonal or weekly change in the hydrological regime downstream of the Kinguélé Aval dam. Inflows will depend on the releases from the Kinguélé and Tchimbélé hydro schemes upstream on the River Mbé which will serve to manage the water flow in terms of smoothing of peak floods.  Daily hydropeaking might significantly modify the downstream flow conditions over short time periods and vary the water level by an additional 0.3 m at Andok Foula compared to the variation under current conditions of 0.8 m.  The ESIA concludes that with the exception of the reservoir area, the impact of the Project on existing hydrology is considered low. The area occupied by the reservoir will become a lentic environment of calm and deeper waters. Fish species that prefer fast and free flowing waters will be impacted as will their movement in the river system. Due to the dam, longitudinal connectivity will be lost as well as lateral seasonal connectivity between the main of the river and tributaries and their floodplains. The BAP estimates that the project will lead to a loss of connectivity in 100 km2 of the 5000-km2 Nkomo basin, which would only represent about 2% of the basin. However, when added to the 1730 km2 already impacted by the two existing dams, the accumulated impacts do represent over 1/3 of the Nkomo basin, noting that these are gross estimates given that the Mbé-Nkomo river system hosts multiple rapids and waterfalls that are likely to be natural barrier for longitudinal connectivity.

In addition to connectivity losses, the project will impact 12 CH triggers, namely one amphibian (Leptodactylodon stevarti (EN)) and three restricted-range fish species (Chromidotilapia regani (VU), Grasseichthys gabonensis (VU), and Plataplochilus sp. nov. (potentially new species)). Furthermore, the population of two aquatic plant species (Ledermanniella sanagaensis (officially CR, 2007; re-assessed EN by the MBG in the framework of the project) and Ledermaniella linearifolia (officially EN, 2007; re-assessed VU in the framework of the project)), six riparian plant species (Thaumatococcus flavus (EN);; Pauridiantha longistipula (EN) ; Phyllobotryon sp. nov. (CR); Pauridiantha longistipula (EN); Palisota cristalensis sp. nov. ined. (EN) ; Tridactyle minutifolia; Salacia diplasia (VU); will be directly impacted. Based on current data, nine of the species are known to be present only in less than five locations globally, while the other four are known to be present in less than 10 locations globally. The majority of the plant species found in the project footprint are under-researched, so it is possible that they will be found in additional locations through surveys planned by the project. However, there is uncertainty that if some of the species are indeed only present in these unique habitats due to a high degree of specialization, restricted range, and endemism, the project may worsen their IUCN Red List status.

Based on the BAP, out of the initial 31 potential CH triggers identified during scoping, impacts on the remaining 19 Critical Habitat triggers noted above were determined to be low-to-negligible, including impacts to great apes. The assessment concluded that even though the Project is located at the edge of an exceptional landscape for western lowland gorilla and central chimpanzees, presence of great apes has not been confirmed in the Project footprint and area of influence.  While the surveys undertaken to date are deemed sufficient for the ESIA and for the design of the mitigation strategy, additional surveys will be initiated during 2020 before the Project is presented to the IFC Board of Directors for consideration and continued in 2021 (ESAP #20). These additional surveys will strengthen the baseline and provide the basis for monitoring and evaluation (M&E) of project impacts over biodiversity values and assessing the effectiveness of mitigation measures during Project construction, commissioning and operation.

Proposed Management Measures: A Biodiversity Action Plan (BAP) that includes a Biodiversity Management Plan (BMP) and a Biodiversity Monitoring and Evaluation Plan (BMEP), has been prepared and it is being disclosed alongside this ESRS. Extensive consultation of the proposed mitigation measures, including the proposed offset strategy, took place between the project sponsor and the ANPN, MCNP management, and other national authorities. ANPN has signed-off on the project’s compensation strategy and offset budget. The project sponsor and their biodiversity consultants also carried out multiple meetings with TNC, WCS and has initiated discussions with the Great Apes section of the IUCN, among others. This remains an ongoing dialog.

In brief, critical habitat triggering plant individuals will be removed from the project footprint, propagated ex-situ and/or translocated to suitable areas located inside of the MCNP where they will be protected from future development and other threats. Based on previous experiences, IUCN-affiliated botanists consulted and hired by the Project have confirmed that propagation and translocation of most of the plant species have a good probability of success, with the exception of Podostemaceas sp (four species in total of this family, including 2 CH triggers) and one other riparian species. As detailed in ESAP #21, the sponsor’s botanical specialists will prepare a detailed calendar of activities related to critical habitat triggering plants including identifying translocation and propagation sites, undertaking trials, and setting up nurseries. The plan will prioritize the highest risk species and will be peer-reviewed by independent botanical experts prior to Board.  To ensure that translocation is successful, monitoring of translocated plants will occur for several years, until the IUCN affiliated specialists are satisfied that translocation and propagation has been successful. The target is that for every individual that is removed from the project footprint, two individuals will be successfully replanted in the wild.

The project has committed not to impact any critical habitat triggering plant species until the feasibility of Net Gains has been demonstrated (ESAP #22).

The project will result in the loss of 244 ha of well-preserved broadleaf forest and has precautionarily assumed a 100% loss the habitat of the fish and amphibian species, and therefore significant residual impacts are expected, mainly related to the loss of terrestrial and river habitat due to the reservoir. The project is proposing a mitigation strategy involving an offset and has identified two ecologically equivalent areas where an offset site of about 1150 ha will be located. The search areas for the offset site are in the buffer area of the MCNP, which don’t have any legal protection and where commercial activities are currently permitted, including several timber concessions. Existing users of the proposed offset area will be consulted prior to finalizing offset selection.The proposed areas would represent a compensation four times the flooded forest and about twice the length of river habitat converted into a reservoir.  For terrestrial habitats, net gains will be obtained through a combination of improvement to forest quality and a reduction in hunting by increasing capacity and strengthening MCNP management (e.g. closure of existing roads to reduce accessibility for hunters and revegetation of access, if necessary). For aquatic and riparian habitat, in addition to protecting twice the length of rivers than the length of river lost to flooding, catchment protection resulting in erosion control and reductions of sediment loads into surface waters is also being proposed as a proxy for improved aquatic habitats. This approach to gains from sediment load and erosion control is based on research that TNC has undertaken in the Mbé catchment area over several years. Erosion and sedimentation rates in the offset site will be reduced through restoration of riparian vegetation and avoidance of further degradation as forestry exploitation and associated activities will no longer be permitted once the offset site is converted into a protected area. The offset site will be finalized following site visits and surveys that are planned to start in late 2020 and in collaboration with ANPN (ESAP #23). This area will be gazetted and the exact level of protection is being agreed. The project sponsors have an agreement with the Gabonese authorities to this effect. The expectation is that this offset will be a protected area added to the core zone of the MCNP. It should be highlighted that since the key mitigation approach proposed involves like-for-like habitat compensation, if additional species of concern are identified through the pre-construction surveys, this is not likely to result in material changes to the offset strategy.

The disclosed BAP is still preliminary. Per ESAP #24 during the remaining months of 2020 and prior presenting the project to IFC Board of Directors, the sponsors will (i) strengthen the baseline via pre-construction surveys, (ii) select and agree with ANPN and other stakeholders the final offsite site, (iii) present a detailed offset implementation and management plan, (iv) budget, and (v) complete the Biodiversity Monitoring and Evaluation Plan (BMEP).

During construction, the sponsor will include within the EPC contract clear language requiring application of good international industry practices (GIIP) for mitigation of impacts over biodiversity, and in addition it has committed to fund seven (7) park rangers / guards in top of the twenty (20) already present at the MCNP. Key function of these seven guards will be the surveillance of areas near the construction site to prevent any construction workers entering the MCNP. Per ESAP #25, the EPC will prepare a Biodiversity Management Plan (BMP) at least 3 months prior to the start of construction work on site and the Sponsor’s biodiversity specialists will oversee implementation of the BMP.

To minimize the impacts of the commissioning stage of the project (including filling up of the reservoir), the Sponsor will prepare and implement a Commissioning Management Plan per ESAP #26.  During operations, the Sponsor will continue to assist the MCNP management to reduce illegal bushmeat hunting by funding 7 additional park rangers / guards, and providing resources and strengthening their capacity and prepare and implement an operation’s Biodiversity Management Plan (BMP) which will include a biodiversity team to oversee biodiversity-related mitigation and the implementation of compensation measures during operations (ESAP #27).

Management of Ecosystem Services: As discussed above, while the nearby villages are sparsely populated, residents relay on the Project area for both subsistence and commercial hunting (though illegal within the MCNP), fishing, and the collection of non-timber forest products. Some of the measures proposed to mitigate impacts on biodiversity values, such as supporting the MCNP management strengthening anti-poaching activities or prohibition of fishing and introduction of commercial fish species in the reservoir, will likely impact livelihoods and access to some of these ecosystem services. Mitigation for these impacts will be covered by the LRP discussed in the PS5 section above.                   

 The potential impacts of the project on cultural heritage were investigated during the ESIA, covering cultural heritage in terms of ecosystem services (e.g. trees, landscape areas with particular cultural value to local people), as well as archaeology and local traditions.  In relation to archaeology, the baseline tasks identified 14 sites of ancient human presence in the study area (e.g. stone artefacts), one of which is directly impacted by the construction.

Most residents of the area of impact belong to Fang ethnic clans. They are often both Christian and animist.  The ESIA baseline work and local consultation noted the need for special attention to customs, traditions and rituals of local populations.  No impacts on intangible cultural heritage such as spiritual or religious significant to local communities are anticipated during the construction phase subsequent to participative consultations with local communities. However, it is anticipated that with the project’s support a ritual ceremony would be undertaken by the local communities prior to the construction phase in line with local cultural practices.  Possible projects identified during consultation for the local community development fund included actions in the cultural field to promote and conserve the knowledge of local Fang culture, and promotion of traditional medical and botanical knowledge.

The Cultural Heritage Management Plan will be implemented by the EPC contractor as part of the management plans required under ESAP #2). It will include the implementation of chance finds procedures, which will require arrangements for seeking advice from an archaeologist should potential archaeological finds be made during construction.  Any remains of cultural items of value will be carefully handled and stored according to the procedures.  Contractor employees will receive training and awareness in the chance finds procedures as well as on the local cultures and traditions.                                       

 Stakeholder engagement started as an integral component of the ESIA process. The Stakeholder Engagement Plan (SEP) included identification and mapping of key stakeholders, degree of impact and influence-capacity of different project’s stakeholder groups.

Detailed stakeholder consultation was carried out during the ESIA in line with Gabonese legislation and IFC Performance Standards.  It included interviews of stakeholders (e.g. local administrations, customary and village authorities), community surveys and focus group discussions, other stakeholder interviews and public meetings.

Initial public consultation meetings were held early in the ESIA process in the villages directly affected by the project (Andok Foula) and indirectly affected (Alen Komo, Makabane and Madouaka). Consultations were held in Andok Foula on 10 October 2017 and in Alen Komo on 14 October 2017.  The Project details were presented to participants, including a summary of the ongoing baseline studies and details of the planned consultation program. Open discussion was facilitated to discuss questions and concerns.  Additional focus group meetings were held with the same formats on the ESIA on 12 October 2017 in Makabane and Madouacka. A second series of public consultation meetings was held to present the key findings and management plans from the ESIA.  These were held in Andok Foula and Alen Komo on 30 July 2018, and Kango on 31 July 2018.   Ongoing community engagement activities are carried out by the project’s Community Liaison Officer.

The ESIA was finalized following these meetings, taking into account comments and concerns from the community and other stakeholders.  The main concerns in all villages consulted related to uncertainty on whether the project would bring opportunities and benefits to the local community and related to the strong local perceptions of a previous lack of dialogue about the project.  In particular, the local communities strongly requested local electricity supply to improve the socio-economic situation.  There were concerns about the state of the access road, the lack of local healthcare facilities, and the lack of local telephone networks.  In addition, the local community requested ritual ceremonies to be undertaken before the start of construction in line with local cultural practices.  Several local socio-economic concerns were raised, and the expectation expressed that the construction camp could bring some benefits to the local economy. 

The SEP covers ongoing actions and responsibilities for stakeholder engagement related to the project and describes the main stakeholders’ concerns identified during the ESIA process, which have been taken into account before finalizing development of the Environmental and Social Management Plan (ESMP).  The SEP also includes the procedures for the community grievance mechanism for the project.  As part of the stakeholder engagement, an external communication procedure will be implemented.

Grievance Mechanism: An external grievance mechanism will be set up for the local communities and other stakeholders (ESAP #28).  It will allow them to communicate their concerns, questions, and issues through a single channel.  The grievance mechanism is described in the ESIA.  Grievances will be recorded into the grievance register / database so that responses are tracked and closed out.  Grievance records will be maintained for analysis so that actions can be taken.  Responsibility for implementation of the grievance mechanism will be a shared responsibility between the Sponsors and the EPC contractor during construction, and under the Project company through commissioning and operations.  A mediation committee will be set up and this will assess grievances that cannot be easily resolved.  The composition of the mediation committee will be agreed with the local communities, customary and administrative authorities in the project area.                                                  

 Contact Person: Louis Lefevre

Designation: Chief Executive Officer

Company Name: Asonha Energie SA

Address: Immeuble du Bord de Mer, 5eme Etage, BP 3873, Libreville, Gabon.

Email: louis.lefevre@asonha.com

Phone: +241 74 00 76 18