Environmental and Social Assessment and Management Systems:
3B does not have an Environmental and Social Management System (ESMS). As such 3B will develop and implement as ESAP Item #1 an Environmental and Social Management System (ESMS) aligned with IFC Performance Standard 1, the applicable parts of World Bank Group’s (WBG) Environmental, Health, and Safety (EHS) Guidelines, Tourism and Hospitality Development guidelines, and national requirements. Specifically, the ESMS is to include: an overarching policy statement objectives & targets; and an organization capacity including roles and responsibilities. Environmental and Social Management Plans to be developed and implemented as part of the ESMS include; (i) Labor and Human Resources (LHR) Plan; (ii) Environmental Health and Safety (EHS) Management plan; (iii) Waste Management (WM) Plan; (iv) Emergency Preparedness and Response Plan (EPRP); (v) Traffic management Plan (TMP); (vi) an External Communication and a Grievance Mechanism and (vii) Standard Operational Procedures for food safety following good industry practice (e.g. HACCP).
Identification of Risks and Impacts:
Article 30 of the new environment law and Ministerial Order N°004/2008 of 15/08/2008 establish the list of works, activities and projects that have to undertake an environmental impact assessment (EIA). For hotels and public buildings, only large hotels and public buildings which accommodate more than one hundred people daily are included. As such, all 3B hotels were build as green fields but without EIA. However, an EIA was conducted for the proposed acquisition, with the main findings include; increase in traffic flow along the main street, solid waste management, dust and noise from machinery during the construction phase. At appraisal, all proposed mitigation measures have been implemented. For the operation phase, the EIA expects 3B to carrying out regular environment audits and submit audit reports to the authority; allow inspectors from Rwanda Environment Management Authority (REMA) for site inspections, comply by all national social and environmental safeguard policies and standards, etc. 3B will implement the environmental management plan and comply with all conditions stipulated in the Rwanda Development Board (RDB).
The Akagera Safari Camp is adjacent (approximately 1 km) but not within the Akagera National Park, the habitat appears to be within modified habitats and the footprint of the project is very small (2 km2). At appraisal, the IBAT report flagged several species which are unlikely to still occur at the hotel facilities. However, as an ESAP Item #2, 3B will commission a biodiversity expert to conduct a biodiversity risk screening for the Akagera Safari Camp focused on ground truthing the list of species flagged in the IBAT report and flagging any other biodiversity issues of concern raised by protected area managers or conservation NGOs. In addition, based on the risk screening assessment results, 3B will develop a procedure for screening all plant materials used for landscaping to avoid any invasive alien species and use indigenous species in all landscaping activities.
Management Programs:
As at appraisal, 3B did not have documented management programs, but operate entirely under the regulator; the tourism department of RDC, which has a mandate to develop management programs for all tourism facilities in Rwanda and ensure enforcement. As such most 3B complies with the tourism department programs, which include food safety, fumigation regimes, life and fire safety, etc. As part of the ESMS, 3B will develop the listed management programs to manage its expansion.
Organizational capacity and Competency:
The operations of 3B hotels are currently managed within five departments; front office, house-keeping, food & beverage, security, and maintenance with a defined governance structure with clearly delineated roles and responsibilities. However, 3B does not have a designated officer in charge of Environmental, Health and Safety risks. As such, as ESAP Item #3, 3B will appoint a designated EHS officer to ensure development, implementation, enforcement and review of E&S compliance within the current structure.
Emergency Preparedness and Response:
The building designs of Nobilis hotel has several elements of emergency plans incorporated; such as wide corridors, disabled persons’ ramp and firefighting systems. Under Rwanda national laws, the designs have been approved by RDB. The Akagera facility is yet to be inspected. Other existing facilities are inspected annually by RDB for life and fire safety compliance. In addition, 3B as part of ESMS will develop a corporate level emergency preparedness response plan which will be cascaded to existing and planned facilities. The plan shall include identified areas where accidents or emergencies may occur, communities and individuals that may be impacted, response procedures and periodic training for all employees and in particular for the internal emergency fire marshals, evacuation exercises and semi-annual fire drill programs as per the WBG General EHS Guidelines on emergency preparedness and response. 3B will work closely with the nearest emergency response department (Rwanda National Police) to ensure that the response is effective.
Monitoring and Review:
During the construction of Akagera and as part of the EHS plan for the contraction phase (see below), 3B will ensure the contractor monitor, record and report injuries and other occupational, health and safety risks. During the operational phase, 3B will develop a Standard Operating Procedure (SOP) for monitoring of EHS performance by defining Key Performance Indicators (KPIs) such as, energy and water use, fire safety and solid waste quantity, to be monitored and the frequency of monitoring. External monitoring is conducted annually by RDB and international tour operators like Abercrombie & Kent covering food safety, and life and fire safety.
