Based on IFC’s review of the project, PS7: Indigenous People is not applicable as there are no indigenous peoples in the project area; and PS8: Cultural Heritage is not applicable as the project is not located in an area of known historical or cultural significance and does not impact any known cultural heritage.  However, the project has developed a Chance Finds Procedure in case of the identification of cultural/archeological resources in the area during construction and/or maintenance activities.

This is a Category B project according to IFC’s Policy on Environmental and Social Sustainability as the Environmental and Social (“E&S”) impacts associated with the project are limited, generally project-specific and can be addressed through the implementation of good international industry practices.  Furthermore, it is possible to design and implement engineering and management measures to mitigate adverse impacts during construction and operation.  The environmental and social risks are moderate and for those that have been identified, the client’s ESHS management system and the agreed E&S Action Plan (“ESAP”) provides appropriate mitigation.

Environmental and Social Policy and Management System

At a corporate level, the company has developed a set of policies, including quality, health and safety, environmental and a social sustainability, that outlines their commitment to quality, the prevention of injury, ill-health, limiting pollution of the environment, and compliance with applicable statutory and regulatory requirements at all times.  These policies apply to all AMEA projects, including Tunisian Solar, and will be communicated to all project employees including contractors.

AMEA has developed an Integrated Management System (“IMS”) that has been recently (April 2021) certified ISO 9001:2015 (Quality), ISO 14001:2015 (Environment) and ISO 45001:2018 (OHS).  As per ESAP 1, the IMS will be updated to include its applicability to all company and project contractors and sub-contractors.  A project specific Environmental and Social Management System (“ESMS”) manual has been prepared by AMEA detailing processes and standards to be implemented during construction in order to provide adequate management and supervision of all E&S issues.  This ESMS manual also provides a guidance for the EPC and O&M contractors that, once selected, will be required to develop project specific Environmental and Social Management Plans (“ESMPs”).  The manual, along with mitigating provisions outlined in the project ESIA, provide a detailed outline of the project requirements and standards to underpin the project’s ESMPs.  As per ESAP 2 below, the project’s ESMS will detail processes and standards to be implemented during construction to provide adequate management and supervision of all E&S issues.

As per ESAP 2, the EPC and O&M contractors will develop and implement a project specific EHS/OHS management system including all relevant ESMPs in accordance with the general requirements of all relevant PSs and applicable WBG’s EHS Guidelines, in line with the objectives of AMEA’s policies, ISO certifications (e. g. 14001 and 45001), project manual and ESIA provisions.  AMEA/KSP will review and approve all management plans before any construction activities start.

As part of its IMS, the company has developed procurement and contractor/supply chain management procedures that sets out minimum requirements to ensure E&S requirements are incorporated in contractual requirements.  These requirements, that comply with ISO 14001 and 45001 as well as IFC PSs and Guidance note on Contractor’s management, have been included in all requests for proposals and in the draft contract for the EPC contractor.

Identification of Risks & Impacts

The company developed an ESIA in accordance with local legislation, IFC PSs and WB provisions and guidelines, and good international practice that was submitted to the competent authority for approval on 23 of September 2022 and is pending approval.  The ESIA assessed all relevant baseline conditions (e. g. air quality, noise, traffic, biodiversity, etc.), analysis of alternatives, climate change risk assessment, impacts along with relevant mitigating measures and expected residual impacts once mitigants are implemented, and a framework ESMP.  As outlined above, the project includes an 8 km OHTL that will be built and operated by STEG.  The line will be constructed on public (5,5 km) and private (2,5 km) land. AMEA completed an ESIA for the OHTL which builds on data and information collected for the project’s ESIA.  The project ESIA was disclosed via multiple meetings with all stakeholders and selected focus groups in February, May and June 2022 within the three nearby communities of Daoussi and EL Alam and Metbasta.  ESIA disclosure has been conducted during the preconstruction and document preparation phases to ensure that local community’s needs and expectations are well understood and integrated into the project’s ESIA and ESMS.  KSP has provided evidence of such disclosure activities.

As part of the ESMPs, a project specific and detailed risk assessment procedures will be developed, according to the ESIA findings, covering the construction and operational phases; these procedures will be approved by AMEA/KSP prior commencement of each phase (see ESAP 2).

Management Programs

As mentioned above, the project’s ESIA includes a framework ESMP, which provides a summary of the E&S management framework, monitoring requirements and mitigation measures applicable to the construction and operation phases of the project.  As per ESAP 2, the EPC and O&M contractors will develop a Construction Environmental and Social Management Plan (“CESMP”) and Operation Environmental and Social Management Plan (“OESMP”).  The CESMP and the OESMP will be based upon the ESIA framework ESMP and AMEA’s IMS and project manual and will be reviewed and approved by the Lenders prior to use. 

The CESMP will consist of a suite of sub-plans, which will include but not be limited to: waste management; pollution prevention (including emissions, spill response, etc.); water management (including supply, treatment, disposal, etc.); hazardous materials; emergency preparedness and response; community health, safety and security; road safety and traffic management; accommodation management; local recruitment and labor management; influx management; environmental monitoring plan; stakeholder engagement (including grievance management); contractor management plans; and biodiversity management plans.  With respect to the OHTL, STEG has committed within the power purchase agreement to follow IFC PS requirements during the construction and O&M phases, as per ESAP 3, the project will establish an EHS/OHS coordination procedure with STEG aimed at achieving compliance with the IFC PSs during construction and operations of the OHTL. The procedure will detail the type and frequency of the engagement and the proposed steps the project will take to ensure STEG and its selected EPC and subcontractors comply with relevant PSs standards and WBG General and sector specific EHS guidelines with particular focus on PS5 and PS6 identified issues.

As part of ESAP 2, AMEA will develop a detailed project specific Chance Find Procedure, based on local requirements and international standards, to be implemented during the construction phase.

The OESMP will consist of a suite of sub-plans, which will include but not be limited to: waste management; pollution prevention (including emissions, spill response, etc.); water management; hazardous materials; emergency preparedness and response; community health, safety and security; road safety and traffic management; biodiversity management; environmental monitoring plan and stakeholder engagement (including grievance management). 

Construction and operations phase E&S management and monitoring responsibilities will be shared between the company and the selected EPC and O&M contractors that will be contractually bound to adhere to the requirements to which they are assigned as the responsible party in the ESMPs.

The EPC and O&M contracts are key tools for ensuring compliance with the ESHS requirements of the company.  As outlined above, the company has developed and included ESHS and labor provisions, including relevant child/forced labor provisions, and compliance conditions (including compliance with IFC PSs and WBG EHS guidelines) in its EPC and O&M contracts which will provide contractors and third-party service providers (including security agencies) with clear guidelines on performance requirements.

Organizational Capacity & Competency

The company has at a corporate level a Environmental Social and Governance (“ESG”) Head, based at its headquarters, that have overall responsibility for the project’s ESHS and OHS management.  The company has good capabilities to manage a range of ESHS and OHS issues as well as understanding of IFC and international best practices provisions and standards.

At the project level, AMEA has as social specialist based in Tunis and plans to hire a dedicated Community Liaison Officer and a local EHS officer to support QHSE staff.  The EPC and O&M contractors will be required to have qualified personnel to oversee all E&S issues including an EHS director and manager, an EHS/OHS officer, and a social specialist. 

As per ESAP 4, the company will finalize the project related EHS organogram for both AMEA/KSP and the selected EPC and O&M contractors.  As per ESIA requirements, an ecologist/biodiversity specialist will be hired to oversee the construction phase and support monitoring during the O&M phase.  Appointed personnel will have adequate qualifications and experience, including knowledge of international requirements and best practice.  These individuals must have sufficient authority and resources to fulfil their responsibilities as required by the project ESMS, IFC requirements, the ESAP, and local regulation. 

As per ESAP 5, the company will require their EPC and O&M contractors (including their sub-contractors) to appoint suitably qualified environmental, labor, social and OHS teams to manage their scope of work.  These individuals must be aware of, and fully understand, the obligations and responsibilities placed upon them by the project ESMS and ESMPs. 

Emergency Preparedness & Response

The company has developed a corporate Emergency Preparedness and Response (“EPR”) procedure that sets out minimum requirements and guidelines for the identification and response to possible emergency situations.  These requirements comply with ISO 14001 and 45001 standards as well as IFC PSs.  The project ESMS manual further outlines the requirement for this plan to be fully developed by the selected EPC contractor.

As per ESAP 6, AMEA/KSP and the EPC and O&M contractors will develop a project specific EPR plan in accordance with IFC PS1 and PS4 provisions.

This plan will cover preparedness and responses to a range of potential emergency scenarios including, but not limited to: medical emergencies (including on-site injuries, pandemic type outbreaks); fire, extreme weather conditions; transport incidents and major hydrocarbon spills.  Security related incidents, act of sabotage/vandalism, terrorism etc. will be addressed with a separate Security Management Plan (ESAP 14 see below).  The response plan will include a communication protocol to alert local authorities, communities as appropriate, as well as the management team in addition to specific responses and evacuation procedures. 

Regular drills and emergency training and exercises will be developed according to AMEA corporate and KSP requirements and conducted by the EPC contractor covering the different emergency scenarios.

Monitoring & Review

The company will be responsible for reviewing and formally auditing their contractors with regards to their ESHS performance and compliance against project standards, national requirements and IFC guidelines. 

As part of its project management system, the company will establish specific procedures, based on corporate and project ESMS manual guidelines and framework, and allocate resources to monitor and measure the effectiveness of theirs and their contractor’s management plans / programs as well as compliance with relevant Tunisian legal requirements.

E&S / OHS monitoring requirements of the EPC contractor for their own activities and that of their subcontractors will be defined within their management plans (ESAP 2) and approved by AMEA/KSP.  The implementation will be closely followed by the company during construction activities.

As outlined in the AMEA project ESMS manual, the EPC contractor will provide, as a minimum, monthly E&S / OHS reports as part of the general project reporting requirements.  The report will include coverage of the contractor’s E&S / OHS performance in accordance with reporting requirements outlined within the project ESIA and ESMPs.  Clear Key Performance Indicators (“KPIs”) will be developed as part of the reporting. 

AMEA has in place a Contractor and Supply Chain Procedure specifying selection, contractual agreements, auditing, monitoring and supervision requirements for contractors and suppliers.  The company will implement the requirements outlined in these procedures at the project level; in particular, covering child, forced labor, and significant safety issues requirements (see ESAP 8).

IFC has appointed an independent auditor to undertake review of the effectiveness of CESMP and OESMP; monitoring frequency will be quarterly throughout the construction phase and semi-annually in the first two years of operations.

The project is expected to employ up to 450 workers at the peak of the 16-month construction phase, of which 100 would be skilled and 350 unskilled.  A majority of these workers will be employed by the EPC contractor and sub-contractors and are likely to be sourced from Tunisia.  Some expatriate staff may be retained for project management and specialized construction related work.  There are high expectations of employment opportunities amongst the local communities; therefore, AMEA/KSP will work with the EPC contractor and the local authorities to ensure that recruitment from these communities is maximized and equitable to the extent possible.  Up to 45 workers will be employed during the O&M phase of the project.

Human Resources Policies and Procedures

AMEA has an approved corporate HR policy and associated Code of Conduct that outlines principles related to core company values and ethics, for its own employees.  As part of its IMS, AMEA has developed overarching Labor and Working Conditions Management and Labor Recruitment Procedures that articulate the company’s commitments to labor and working conditions and sets out minimum requirements on labor management in line with IFC PS2 requirements.  These procedures, together with the relevant parts of the project ESMS manual, underpins the labor and working condition requirements for all project entities including the EPC contractor, O&M contractor and all subcontractors.

As per ESAP 7, guided by the requirements defined in the relevant IMS procedures and the project ESMS manual and consistent with the requirements of host nation law and PS2, AMEA/KSP will develop for the construction and operations phases, project specific (i) Labor Policy statements on non-discrimination and equal opportunity, prevention of child labor and forced labor, freedom of association, and prevention of Gender Based Violence and Harassment (“GBVH”); (ii) HR procedures, including local recruitment, with provisions for increasing gender equality; worker induction; terms and conditions of employment; disciplinary requirements (including in relation to GBVH); and demobilization of the project workforce following completion of construction; (iii) Workers Code of Conduct to account for respectful worker behavior including in host communities and zero-tolerance provisions against GBVH; and (iv) Labor Grievance Mechanism with provisions to enable the receipt and resolution of grievances including gender-related issues such as GBVH and gender-based discrimination, in a sensitive and confidential manner.  These HR policies and procedures, Code of Conduct and Labor Grievance Mechanism will apply to all project workers including those employed by any contractors and sub-contractors (e. g. the security services providers) and will be translated into French and Arabic (or as relevant), readily accessible and clearly communicated at induction and through the provision of additional sensitization and training.  AMEA/KSP will also ensure that the EPC and O&M contractors’ processes and procedures are fully aligned with the above policies, plans and procedures and that the HR function is adequately staffed with experienced personnel. 

No workers accommodation camp will be set up during the construction phase; workers will be accommodated in the surrounding villages.  As part of its IMS, AMEA has developed an overarching Accommodation Management Procedure that articulates the minimum requirements for workers accommodation including provision of basic services and welfare facilities.  It also includes measures to manage risks related to COVID-19.  These are consistent with PS2 requirements and the IFC/EBRD guidance note on Workers Accommodation: Process and Standards.  These provisions will guide, if necessary, the development of a project specific accommodation management plan by the company or its contractors or subcontractors (ESAP 7).  Should workers be accommodated in the surrounding villages, AMEA/KSP will develop a transportation management plan assessing and addressing the risks associated with transporting workers to and from the worksite (ESAP 13).

Working Conditions and Term of Employment

The project will ensure that all employee contracts are consistent with Tunisian labor codes and IFC PS2 requirements.  All employees (including those employed by contractors and subcontractors) will be provided with a contract in French/Arabic, stipulating their terms of employment, working conditions (including health and safety requirements), wages and benefits, hours of work, overtime arrangements and overtime compensation, annual and sick leave, vacation, holidays as well as other leaves stipulated by national legislation.  Contracts of the construction phase workers shall have a clear description of the short-term nature of the project and provide an indication of the potential employment duration.

Workers’ Organization

As per ESAP 7, AMEA/KSP will develop a project specific policy statement ensuring that the project will not in any way prevent workers from seeking to join unions and other workers’ organizations.  This will include direct workers and third- party workers throughout the construction and operations phases.

Child and Forced Labor

The project will ensure that no child or forced labor will be used by the project at any time.  The company will ensure adequate contractual provisions are in place, such as proof of identification and age, with their contractors/suppliers.

Occupational Health and Safety

Key OHS risks for a PV project include slips and falls, potential hazards from on-site moving machinery, heavy load lifting, traffic accidents, exposure to electric shocks and burns, and safety issues related to panels module assembly.  AMEA has an OHS procedure as part of their IMS covering these aspects (e.g. Personal Protection Equipment - PPEs, subcontractor requirements, electrical works, hand tools. power tools, ladders, etc.).  However, a comprehensive and detailed OHS Management System, aligned with OHSAS 18001 / ISO 45001 and AMEA’s IMS and project manual, for the construction and operational phases will be developed by the EPC and O&M contractors respectively (as per ESAP 2).  The main elements that make up the OHS plan include: a robust OHS training program for staff and contractors; Job Safety Analysis and Risk and Hazard Assessment and associated management procedures for work activities; PPE requirements; Permit to Work System; Lock Out-Tag Out System; OHS signage requirements; medical support requirements; rest and sanitary facilities; actions and procedures related to COVID-19; training requirements, including at induction and repeated/refresher Toolbox Talks; roles and responsibilities for implementation of plan; incident recording and investigation; performance monitoring; etc.  The EPC and O&M contractors will also be contractually required to deploy a suitable number of appropriately qualified Health and Safety (“H&S”) supervisors for effective supervision of compliance with the contractual provisions relating to OHS requirements.  A H&S Committee composed of worker representatives will also be set up to provide feedback and recommendations on H&S matters, in accordance with Tunisian regulations.  An OHS plan and associated procedures will also be developed for the operations phase by Tunisia Solar.  As per ESAP 8, AMEA will put in place appropriate monitoring requirements including third-party audit procedures for both the construction and operation phases, to obtain assurance that the contractors and their sub-contractors maintain statutory compliance with host country law, the employers labor requirements, and PS2 provisions.

Resource Efficiency – Greenhouse Gases

Greenhouse gas emissions from the project during the construction are expected to be minimal and predominantly associated with the use of fuels such as in generators, transport, on-site equipment, and machinery.  Although the quantities of emissions have not been calculated, these are expected to be low and significantly less than 25,000 tones CO2 equivalent (tCO2eq/year). 

The project is expected to generate approximately 230,000 gigawatt hours (GWh) of electricity per year, resulting in a predicated annual GHG reduction of between 94,650 and 117,000 tCO2eq/year.

Resource Efficiency – Water Consumption & Availability

The estimated water requirements (domestic and industrial) are 5,400m3 total during the construction phase and 0.5m3/day (domestic) and 3,200m3/year (an average of 8.8m3/day) for industrial use during the operational phase. 

The main water requirement during construction is likely to be water for dust suppression, concrete production, minor concrete batching will be required for the substation, control and administration buildings, and domestic use.  Construction phase water consumption requirements will be accurately quantified by the company when all key elements (e. g. concrete batching, workers accommodations, etc.) will be defined. 

Water requirements during the O&M phase will be largely focused on panel cleaning with priority given to dry-cleaning via a brush-cleaning program which does not entail the use of water.  However, wet cleaning will be required in certain instances (e.g., when dust becomes adhesive from rain or humidity); it is estimated that wet cleaning will not exceed four times per year with an estimated consumption of approximately 800m3/cleaning cycle.  KSP will consider the general and contextual risk of water conservation as a guiding principle for selecting a water efficient cleaning technology option and will refine the cleaning regime during operations to avoid unnecessary cleaning and use of water.

During construction and operation, the project will supply domestic and industrial water needs from nearby licensed sources and truck it to site by local companies.  For potable water there is a viable option to have it trucked to site by the local municipal authority. 

The ESIA indicates that a project specific water management plan needs to be developed for the construction and operational phases.  AMEA has in place a water resources management procedure as part of their IMS upon which the plan is to be developed.  The procedures detail management, consumption efficiency, monitoring and reporting requirements.  Furthermore, the AMEA/KSP project manual indicates that water management plans are to be in compliance with relevant national legislations and in line with IFC PS3 and the WBG’s EHS General Guidelines.  The manual elaborates on the contents of the plan which shall include potable and non-potable water requirements; water sourcing; resource efficiency measures such as water saving taps; trainings; KPIs; roles and responsibilities; and monitoring of the quality in the water tanks.

As per ESAP 9, KSP will develop a project specific water management plan, based on ESIA baseline findings and sustainability assessment, for the construction and operational phases which will include measures for efficient water use/water minimization as part of the cleaning needs for panels and for general use as well as monitoring procedures of water supply services. 

Pollution Prevention – Waste

The ESIA identified waste streams generated during the construction and operational phases; however, estimates on amounts are based on similar solar projects.  The overall volumes of both solid and hazardous waste generated by the project during both phases are expected to be low.  The company is yet to develop a comprehensive estimation of their anticipated waste streams and volumes for the project while a preliminary evaluation of waste treatment and disposal options have been conducted as part of the ESIA.

It is anticipated that the project will produce both non-hazardous wastes, such as paper, wood, plastic, scrap metals and glass, and a limited quantity of potentially hazardous materials such as transformer oils, paints, batteries, etc. as well as some electronic waste.

The ESIA indicates that a project specific waste management plan needs to be developed for the construction phase and operational phases.  Furthermore, the ESIA indicates that currently there is no operational hazardous waste landfill in Tunisia; JRADOU the only hazardous waste landfill in Tunisia is not operational.

AMEA has in place a waste management procedure as part of its IMS on which the plan is to be developed.  The procedure details management, training, monitoring, and reporting requirements for waste.  Furthermore, AMEA’s IMS includes a hazardous material management procedure covering transport, storage, refueling, emergency response, community awareness, training, monitoring, and reporting.  At the project level, AMEA/KSP ESMS project manual indicates that waste management plans are to be in compliance with relevant national legislations and in line with IFC PS3 and the WBG’s EHS General Guidelines.  The manual elaborates on the contents of the plan which shall include estimation of waste quantities per stream, final disposal, management measures such as storage specifications and utilization of waste manifests, trainings, KPIs, roles and responsibilities, monitoring, and reporting.

As per ESAP 10, KSP and its EPC and O&M contractors will develop a waste management plan for the project aligned with local legal requirements, AMEA/KSP EMS guidelines, IFC PS3 and WBG EHS general provisions.  The waste management plan will commit to the reduction of wastes whilst maximizing the re-use and recycling of materials and will outline process for appropriate waste storage, segregation, tracking, transportation, and disposal / treatment.  Provisions will be included to fully track waste from source to final destination and for selecting third parties hired for waste transport.  The plan will also include specifics for management of broken, expired, or surplus PV panels, address local requirements for the designation of a hazardous storage area, provide details on hazardous waste disposal solution(s) in line with good international industry practices, and include provisions to ensure hazardous waste contractors are licensed from the local relevant authority.

The company will develop a waste inventory and will undertake an assessment of disposal and treatment facilities / options.  Project waste will only be disposed of and treated at appropriately licensed facilities.  The company will adhere to Principles of “duty-of-care” in waste management.

As per AMEA/KSP ESMS, an assessment of the suitability of each licensed disposal facility will be undertaken prior to use to ensure project waste is disposed / treated in such a manner that is safe for human health and the environment.

Pollution Prevention – Hazardous Materials

Hazardous materials likely to be required during the construction and operation phases of the project include hydrocarbons, oils, lubricants, and paints.  Furthermore, leaks from contractors’ vehicles and equipment may impact the soil/subsoil.  An impermeable hazardous material storage area is to be established onsite, with restricted access, are required by local legislation.  The ESIA indicates that a project specific hazardous management plan needs to be developed for the construction and operational phases.  AMEA has in place hazardous material management procedure as part of its IMS on which the plan is to be developed.  The procedure details transport, storage, refueling, emergency response, community awareness, training, vehicles/equipment inspections and maintenance, monitoring and reporting.  At the project level, AMEA/KSP ESMS project manual indicates that hazardous material management plans are to be in compliance with relevant national legislations and in line with IFC PS3 and the WBG’s EHS General Guidelines.  The manual elaborates on the contents of the plan which shall include inventory, use of material safety data sheets, storage requirements, training, KPIs, roles and responsibilities, monitoring and reporting requirements.

As per ESAP 11, KSP and its contractors will develop a project specific hazardous material management plans and spill prevention and repose plan that are commensurate with the potential risks present at site.  These management plans will address the protection of workforce and the prevention and control of releases and accidents.

A limited number of waste PV modules are expected to require disposal during the construction phase; KSP plans to return these modules to the PV manufacturer for recycling.

Pollution Prevention

During construction, a minor and insignificant amount of pollution to air, water and soil, and increased noise levels is anticipated; these impacts that can be easily mitigated through standard pollution prevention and control measures that will be outlined in the respective environmental management plans.  Wastewater will be collected in impermeable tanks and transported by a licensed contractor to the nearest municipal treatment plant.  During the operational phase, no environmental pollution impacts are anticipated except for wastewater, primarily derived from panel cleaning, and regular household waste generation.  The company will implement pollution prevention measures in accordance with national law, IFC’s PSs, and project ESIA provisions.

Community Exposure to Disease

The project is located in a sparely populated rural area, with the nearest residential area, located approximately 2.2km to the south.  Although, the project intends to maximize recruitment from local communities to the extent possible, the large construction related workforce needs may lead to an influx of workers into the region.  As stated earlier, no workers accommodation camp will be set up for the construction phase.  Any accommodation of workers by the company or its contractors will need to meet the requirements of IFC/EBRD’s guidance note Worker Accommodation: Process and Standards.  As per ESAP 12, the project will develop and implement a Community Health and Safety and Worker Influx Plan.  The plan will include an assessment of worker influx at a cumulative level given other development projects within the area and will include: (i) a communicable disease (including HIV/AIDS and sexually transmitted infections) awareness and prevention program for site workers as well as local communities; (ii) requirements for adequate on-site medical facilities; (iii) a community grievance mechanism (“CGM”); and (iv) provisions for periodical monitoring of social related effects of the influx of migrants.  The implementation of this plan, together with the project Code of Conduct, measures to maximize local recruitment in the local procurement and employment procedure and plan, and the Worker Accommodation Plan (if needed, as per ESAP 7), will help manage the risks and impacts of population influx.

The project will also implement measures to manage risks related to COVID-19 and will ensure that adequate plans and procedures are developed to minimize, as much as reasonably possible, its transmission.

Road Safety & Traffic Management

During construction, the dominant vehicle movement patterns will be in relation to the transportation of construction material and equipment over the 16-months construction period.  Access to the site is via the existing regional road 171 running north-south along the site east boundary. Increases in traffic related to the transportation of project components may represent a safety risk for the other road users and communities adjacent to the roads being used.  The project ESIA has identify the road network and estimated road traffic; this information will be used by the project to develop a traffic management plan to bring in equipment and workers along with the associated impacts and mitigation. AMEA’s IMS includes a Traffic and Transportation Management Procedure which covers the company’s Safe Driving Policy, driver requirements, logistics subcontractor’s requirements, onsite and offsite traffic management measures, site access, vehicle identification and maintenance, COVID-19 measures, and monitoring, auditing and reporting requirements.  As per ESAP 13, KSP shall undertake a Transportation Risk Assessment and guided by the findings, the IMS Procedure and the project ESMS manual, develop a Project Traffic and Transport Management Plan.  The plan will define transport routes to be used for equipment deliveries based on the risk assessments undertaken to evaluate road traffic and conditions with the aim of minimizing impacts.  It will also define a safety inspection program for the project (especially for local subcontractors) and implement ongoing monitoring of vehicles and proper use of safety measures.

Security Personnel

A permanent fence will be erected around the perimeter of the site.  Security and access control to the site will be provided on a 24-hour basis by a third-party security company retained by the EPC and O&M contractors during construction operations.  Security guards will not be armed.  AMEA is committed to managing the project’s use of and relationship with third-party security personnel to ensure that security provision is managed properly to safeguard both the security and human rights of communities, workers, and other stakeholders impacted by its operations, in line with PS4 requirements.  AMEA’s IMS includes a Security Assessment and Management Procedure covering assessment of security issues, proposed management measures, managing private security, engaging with public security forces, and monitoring and reporting.  As per ESAP 14, the project will develop a Project Security Risk Assessment and a Security Management Plan for the construction and operations phases based on requirements of the IMS Security Assessment and Management Procedure, the findings of the Security Risk Assessment and consistent with PS4 requirements including IFC’s “Good Practice Handbook on the Use of Security Forces: Assessing and Managing Risks and Impacts” and the Voluntary Principles on Security and Human Rights.  The Security Management Plan will ensure relevant security procedures will be communicated to the surrounding communities to seek a common understanding regarding security and to minimize potential for conflicts.  Similarly, the security management plan will ensure any security related grievances can be reported via the CGM and determine the need for a memorandum of understanding to clearly define and regulate the relationship between the project and public security forces.  During both the construction and operational phases of the project, KSP will undertake regular audits of the established security provisions as part of the established monitoring and reporting requirements described in PS1 (as per ESAP 2).

The project site is located within the Saharan Halophytic Ecoregion, which comprises a number of saline depressions scattered across northern Africa and are characterized by their hydrophytic vegetation that is generally of low species richness. The site is not located within an internationally recognized areas or Protected Area.  The nearest Key Biodiversity Area - Metbasta Important Bird Area (“IBA”) is located approximately 1 km to the south of the project. This IBA comprises a shallow seasonal wetland, which was designated for a small breeding population of 30-60 breeding Marbled Teal (Marmaronetta angustirostris IUCN Vulnerable). However, according to local ornithological experts, the species occurs irregularly at the site and no recent records of breeding of Marbled Teal have been observed.  A larger seasonal IBA wetland, Sebkhet Kelbia is located approximately 5km to the east and supports a range of breeding and wintering water birds. However, the populations of these water birds recorded at both Sebkhet Kelbia and Metbasta IBAs have reduced in recent years, in part due to lower winter rainfall and upstream impoundment of water by dams.

Although the project site is covered in deep soil, the high salinity makes cropping unviable and the site is dominated by perennial short shrubby halophytes. Botanical surveys completed in September 2020 and April 2021 confirmed the main flora on site as comprising a range of common species, dominated by Arthrocnemum macrostachyum, Salsola tetrandra, Halocnemum strobilaceum and Halopeplis amplexicaulis. No threatened plant species were recorded. Although the site has been grazed historically by domestic animals, the vegetation on site is classified as Natural Habitat, with localized areas that are devoid of any vegetation due to periodic inundation.

Faunal surveys of the project site completed to inform the ESIA recorded a single threatened species on-site – the IUCN Vulnerable dragonfly species Gomphus lucasii, which was observed at the edge of a small pond. The species is also known to occur within the larger seasonal waterbodies in the nearby Metbasta IBA. Autumn and spring bird surveys recently completed on-site did not record any threatened bird species, and the breeding birds observed throughout the site are widespread and common, typical of open low vegetation - such as Lesser Short-toed Lark Calandrella rufescens and Crested Lark Galerida cristata. Wintering water bird populations within the nearby Metbasta IBA fluctuate according to rainfall and resulting wetland water levels – with recent peaks of 60 Greater Flamingo Phoenicopterus roseus in 2016 and 560 Common Crane Grus in 2015.

The ESIA provides a summary of biodiversity-related mitigation measures to be implemented during construction to include protection of vegetation and the provision of small wetland habitats for Gomphus lucasii.  As specified in ESAP 17, the company and its EPC will develop a construction-phase Biodiversity Management Plan (“BMP”) that will be designed to achieve no net loss of Natural Habitat and associated significant biodiversity values (including Gomphus lucasii), with appropriate mitigation measures to preserve the integrity of topsoil and existing natural vegetation on-site and restoration of natural vegetation in areas disturbed during construction.  The attraction of invertebrates to polarizing surfaces of the PV panels will be reduced through the use of non-polarizing edges. Post-construction monitoring of bird mortality will be undertaken both within the project site and along the 8km transmission line. As per ESAP 17, the company and the O&M contractor will develop an operational-phase BMP that includes long-term restoration and management of Natural Habitat on-site and the control of invasive alien species. The O&M BMP will also include a biodiversity monitoring plan, including monitoring of bird fatalities to demonstrate no net loss of Natural Habitats and their associated significant biodiversity values.

The powerlines will pass within 250m of Metbasta IBA. As per ESAP 18, the company will engage with STEG, with the aim to install and maintain bird flight deflectors for the life of the project to include a combination of flapper-style and spiral bird diverters to be installed at 10m intervals (see also ESAP 3 above).

The closest villages to the project site are Al Metbasta and El Bchechma, located approximately 2.2km to the south and 4km to the northeast respectively.  Other villages in the wider area include Bir Jdid, 6.5km, El Ghabet, 7.8km, El Dallousi, 8.4km, and El Alam, 11km from the site. There are also a few single-family dwellings in the area, with the closest being Al Malaji, about 4.3km from the project site.  AMEA has a Communication, Participation and Consultation Procedure, as part of its IMS, that outlines the requirements for internal and external communications as well as requirements for grievance mechanism with a no- retaliation policy for both internal and external grievances. KSP has developed a draft Stakeholder Engagement Plan (“SEP”), which has identified stakeholders affected by the project, provided a summary of past stakeholder engagement activities, and presented a future stakeholder engagement strategy and plan.  To date, stakeholder engagement activities (informant interviews, focus group discussions including with youth groups and herders and other meetings) has been conducted as part of the ESIA process in five villages: (i) El Alam, (ii) El Dalloussi, (iii) Bir Jdid, (iv) El Bchechma, and (v) Al Metbasta (October 2020 and February 2022), and with NGOs (May 2021).  In addition, an ESIA disclosure meeting was held on March 2022, with local government entities in the governorate of Kairouan. Issues raised during these engagement activities relate to equitable access to employment and other economic opportunities and consideration of corporate social responsibility programs. Although the ESIA has summarized the findings of the engagement activities, no dates, minutes and attendance registers of the community meetings have been recorded.  During community meetings carried out as part of the appraisal site visit, the consultant noted that the surrounding communities were familiar with the project formal disclosure of the project and the ESIA with these communities as been conducted during multiple meetings conducted in February, May and June 2022 with the local communities as part of the project ongoing stakeholder engagement process. 

As per ESAP 19, the project will update the SEP to account for further engagement and sensitization activities to be undertaken as part of the disclosure of the ESIA and prior to the construction phase with the nearby villages of: (i) El Alam, (ii) El Dalloussi, (iii) Bir Jdid, (iv) El Bchechma, (v) El Ghabet and (vi) Al Metbasta, in line with IFC’s PS 1 requirements including Informed Consultation and Participation. Minutes and attendance registers of all engagement activities will be taken and appended to the SEP. A full time Community Liaison Officer will be retained to manage stakeholder relations between the project and the communities and to support the project’s social manager.

AMEA will also develop a Community Development Plan focusing on socio-economic development projects during the operation phase.

Community Grievance Mechanism (“CGM”):

The SEP provides an outline of a CGM that allows for submission and management of grievances (including the lodging of anonymous grievances), reporting, and feedback loops.  Per ESAP 20, the project will establish and maintain a project level CGM prior to the start of the construction phase and for the duration of the project in line with PS1 requirements.  The CGM will be accessible for all types of complaints including those regarding GBVH and gender-based discrimination, in a sensitive and confidential manner and allow for external redress using relevant independent parties where a resolution cannot be achieved internally.  The Community Liaison Officer will also serve as a grievance officer and will act as the interface between EPC contractor and the local stakeholders on community matters including the recruitment of local workers and management of grievances as a result of the EPC actions and activities.

KAIROUAN SOLAR PLANT (SARL LLC)

31, Avenue Alain Savary 1002 Tunis le Belvédère - TUNISIA

Mr. Vito Saluto, Head of ESG

AMEA Power LLC 

Marina Plaza Offices, Level 33, Dubai Marina, PO Box 37669

Dubai, United Arab Emirates

Mobile: +971 52 104 22 93 

Website: www.ameapower.com