The E&S due diligence found that the Project is not expected to have impacts on biodiversity sensitive areas, Indigenous Peoples lands, or cultural heritage. For the latter the project will adopt a Chance Find procedure in line with local laws and IFC PS8 (ESAP #16).                                                  

 This is a Category B project according to IFC’s Policy on Environmental and Social Sustainability as the E&S impacts associated with the project are limited, generally project-specific and can be addressed through the implementation the E&S Management Plans and the agreed E&S Action Plan (ESAP).  The project does not involve physical displacement of population or impacts on biodiversity sensitive areas.                                                  

 The development of the broader 100 MW National Solar Park (NSP) involved the preparation of an E&S Impact Assessment (ESIA) and other documents covering the NSP and its ancillary facilities (i.e. 40 km transmission line, access roads, substation, etc). These documents are aligned with ADB’s E&S requirements and includes, among other: E&S Management Plan (ESMP), Biodiversity Assessment, Stakeholder Engagement Plan (SEP); Resettlement Policy Framework (RPF) and a Land Acquisition and Resettlement Plan (LARP) for the transmission line. The site of the NSP was selected based on an analysis of alternatives that sought to avoid environmental and social impacts and the site does not require physical displacement of people. The NSP ESIA concluded that impacts are limited and no protected areas or biodiversity sensitive areas, community forests, ethnic minorities or significant number of people would be affected. The NSP ESIA guides the development of the NSP and EDC is responsible for the E&S performance at the broader NSP level. See https://www.adb.org/projects/51182-001/main.

In addition to the above, the development of the 60MW Project to be financed by IFC required the company to commission the preparation of an additional Project-specific ESIA and ESMP (January 2021) aligned with local and Lenders’ E&S requirements (i.e. IFC PS and ADB Safeguards). The Project ESIA covers the Project’s footprint (e.g. solar plant, internal roads, etc) and an area of influence in a radius of 3 kms from the Project’s boundary. The Project ESIA covers all Project stages (i.e. pre-construction, construction and operation).

The Project ESIA also includes a cumulative impact assessment (CIA), which considers the potential cumulative impacts of the additional 40 MW solar plant planned under the NSP and found that there are no other solar PV plants in operation near the proposed Project, with the closest solar park being located over 40 km away. The CIA provides and analysis on Valued Ecological Components (VECs) including topography and land-use; soils; surface and groundwater; air quality; noise and vibration; ecology; human environment; waste; and visual and aesthetics. It is concluded that the proposed 60MW solar plant has minor and mitigable impacts on all concerned VECs.

The Project’s ESMP within the ESIA contains the following components, among others: a) mitigation and monitoring measures; b) institutional arrangements and project responsibilities, including contractor E&E management; c) public consultations and information disclosure; d) GRM; e) training and capacity building requirements; and f) budget.

Prior to start of construction, Construction Environmental & Social Management Plans (CESMPs) will be developed by the EPC contractor based on the Project’s ESIA/ESMPs to mitigate any E&S impacts.  CESMPs to be developed and reviewed by the company include: Spoils Disposal Plan; Hazardous Material Control Plan; Site Rehabilitation and Clean-up Plan for Land and Vegetation Impacts; Noise and Dust Control Plan; Drainage and Storm-Water Management Plan; Materials Management Plan (including warehouse/storage); Waste Management Plan; Community Health and Safety Plan; Occupational Health and Safety Plan (including worker’s accommodations and work areas); Emergency Response Plan; Traffic and Road Management Plan; and Chance and Find Procedures.

The company will establish a Social and Environmental Compliance Unit (SECU) to supervise and handle day-to-day Project-level E&S issues, including EPC Contractor E&S performance, with support from an E&S Consultant team. SECU will be staffed with two E&S and health and safety (EHS) specialists who will supervise the E&S performance of the Engineering, Procurement, and Construction contractor (EPC), and coordinate the project’s community engagement efforts and Grievance Redress Mechanism (GRM). SECU’s EHS specialists will coordinate with the relevant personnel at NSP-level as needed.

During construction phase, the EPC will appoint at least one EHS officer who will be in charge of coordinating the implementation of the CESMPs and routine site inspections. One staff from the EPC will also be appointed as GRM focal person for handling complaints and support ongoing community engagement efforts.

Prior to construction, workers from the EPC and subcontractors will be provided with training and drills on: 1) implementation-level ESMP; 2) EHS at work sites; 3) community health and safety, including the Workers Code of Conduct; and 3) record and maintain briefing and orientation events log with duration and list of attendees. The NSP-level E&S personnel will also supervise this training process. 

As set forth in the E&S Action Plan (ESAP), the Company will:

-ESAP #1: Develop and Implement an E&S Management System at the Company and at the EPC Level aligned with IFC PSs and socialized among relevant Sponsor and EPC contractor workers.

-ESAP #2: Obtain the Environmental Permit granted by the Ministry of Environment (MOE) for the 60 MW solar project,

-ESAP #3: Include specific provision in the EPC Contract ensuring compliance with the project E&S requirements, including IFC PSs; and

-ESAP #4: Submit final Construction Environmental & Social Management Plans (CESMPs) reflecting the requirements of the Project’s ESMP and IFC PSs and evidence of training of the EPC workforce on its implementation.                                                  

 It is estimated that the future employment of the project will generate approximately 197 jobs during construction and 57 during operation. 

Human Resources Management: The Company manages labor aspects in line with Cambodian Labor Law, which covers a range issues including provisions relating to the condition of hiring, calculation and payment of wages and perquisites, benefits in kind, working hours, breaks and holidays, notice periods, OHS, obligations of workers and sanctions that can be imposed on workers. As set forth in ESAP #6, the Company will develop a Human Resources (HR) Policy in line with IFC PS2. The HR Policy will be communicated to all employees working within the Company and will have provisions for workers engages through third parties (i.e. construction contractor and subcontractors).  

Non-discrimination and Equal Opportunity: The Company does not have in place a clearly defined nondiscrimination and equal opportunity policy. The Company will develop a nondiscrimination and equal opportunity policy which is aligned to national law and IFC PS2 as part of its HR Policy to be developed as per ESAP #6 above. The company will identify migrant workers and ensure that they are engaged on substantially equivalent terms and conditions to non-migrant workers who carry out the similar work. Also,  as part of the HR Policy to be adopted as per ESAP #6 the company will include employment terms and conditions with zero-tolerance approach for proven case of gender-based violence (GBV) or reports of sexual harassment and shall include a mechanism for receiving complaints that protects the identity of the complainer, investigates the process based on a survivor centered approach, applying remediation in accordance with the HR policies and procedures and national regulations.   

Grievance Mechanism: The Company does not have in place a formal grievance process that enables workers to bring and escalate grievances as needed. No channel is available for anonymous filing of grievances or concerns. As part of the HR Policy required under ESAP #6 above, the Company will establish its worker grievance mechanism procedure which will be available for its permanent, casual and contractual workers, as applicable. This procedure will include steps to be taken by workers to manifest any concerns, engage in a mediation process, contact responsible persons, and provide timely feedback. The company will also reinforce the policy of confidentiality and non-retribution, along with ability to raise anonymous grievance.  

Workers Engaged by Third Parties: As set forth in ESAP #7, the EPC Contractor will implement a Labor and Working Conditions Policy in line with local laws, the Company’s HR Policy and IFC PSs  including the following procedures, among others: Workers Code of Conduct; workers grievance mechanisms, anti-harassment; treatment of in-migrant workers; and avoidance of child and forced labor.

Occupational Health and Safety: As set forth in ESAP #8 the Company will adopt an OHS Procedure for the Construction and Operations phase in line with IFC PS2 and relevant WBG EHS Guidelines, including measures related to infectious diseases. Additionally, as set forth under ESAP #4 above, the CESMPs will also include an OHS Program to manage these risks during construction.

Workers Accommodations: Given the location of the Project, workers accommodations are likely to be required. As set forth in ESAP #9 the company will develop and ensure implementation of a Workers Accommodation Plan for the Temporary Workers Camp in line with internationally recognized standards.                                                  

 The Project will have limited impacts linked to use of resources and pollution, most of which will occur during the construction stage.  Related impacts during operation are expected to be negligible. All relevant impacts will be managed through measures reflected in the Project ESIA and resulting CESMPs as per ESAP #4 under PS1.

Water: There are no plans to extract groundwater for the project and the field investigation confirmed that there is no borehole located in the project site. It is anticipated that the project requires an amount of 6-8m3/day for construction and 13m3/day for workers' consumption.  It is reported that during the operation, 170-200m3/month will be required for panel cleaning and 0.5 m3/day for domestic uses. Water will be sourced from a local licensed supplier, which will complement stormwater and tanked water. The Project ESIA found that even during dry season there will be sufficient water for Project construction and operation and water use will not hinder water availability for local villagers since project water use is relatively small and other water sources (stormwater and tanked water) will be used in combination.  In any case, as set forth in ESAP #10 the Company will adopt a Water Management Plan, including E&S assurance of sourcing of water by the supplier, measured to assess and manage any groundwater extraction required in the future, a water harvesting procedure to harvest stormwater runoff to minimize water use and measures to recycle water used in panel cleaning.

Liquid Effluents: Septic tank will be installed to keep wastewater from toilet and kitchen to prevent pollution to groundwater.   A septic system for wastewater collection and disposal is provided and maintained; tank system will be located at least 400 m from any water sources, to avoid contamination. The ESMP includes provisions to have permanent secured (‘bunded’) areas on impermeable surfaces and dykes capable of carrying 110% volume of materials for accidental spills or leakage.

Hazardous Materials:  During operation, the project will not use of chemicals/detergents for cleaning PV panel. Most hazardous waste is generated from replacement and removal of used, broken PV panels and the measures as set out in the ESMP include: use of licensed vendors/suppliers for collection, transportation and disposal of broken/unused PV panels and store broken/redundant panels in covered bunded areas. As set forth in ESAP #11, the Company will adopt a Procedure to manage the storage and final disposal of redundant / broken solar panels.

Erosion: Erosion control measures during construction and operation are presented in the ESMP and will be reflected in the resulting CESMPs. During construction, the project will implement engineering and biological measures to prevent surface erosion such as provision of silt traps or sowing soil-binding grass, as needed. During operation of the solar plant, the measures are maintaining and assuring the structural integrity of these project components and existing topography of the site.          

GHG Emissions: The operation of a 60 MW solar PV plant will avoid approximately 84,000 tons of carbon dioxide-equivalent (tCO2e) annually. For a lifetime, the project will contribute to the reduction of emissions up to 1,760,000 tCO2e.                                                    

 The Project ESIA indicates that there are no people residing in the Project site and that there are some local residents living along the access road. There are also a primary school, church and Buddhist temples that may be disturbed from Project-related traffic. Traffic nuisance to nearby communes and increase in dust due to movement of vehicles and increase in vehicular emissions affecting air quality are expected. A Traffic and Road Management Plan will be implemented as part of the CESMPs as set forth under ESAP #12.

In order to manage potential community health and safety risks linked to workers’ influx, as set forth in ESAP #13 the Company will adopt a Workers Influx Plan and Worker’s Code of Conduct (WCC) in line with IFC PS4. 

Additionally, in order to minimize workers’ influx and enhance opportunities for local communities, as set forth in ESAP #14 the Company will adopt a Local Recruitment and Training Plan.

The project will recruit two security guard from local people, who would be unarmed.