With regards to PS7 (Indigenous Peoples) and PS8 (Cultural Heritage) no Indigenous Peoples have been identified within the CTT project area of influence and no impacts to cultural resources have been identified to date. The project’s EPC contractor is required to develop a chance finds procedure in the event that archeological/ cultural resources are identified during construction or operations per environmental and social action plan (‘ESAP’) #2a.                                                  

This is a Category A project according to IFC’s Policy on Environmental and Social Sustainability in consideration of potentially significant and diverse environmental and social risks related to the project construction and operations.

Key environmental and social considerations relate to i) ensuring the contractors comply with the environmental and social management system and associated obligations and plans for construction including aspects related to occupational health and safety; ii) contractor compliance with Performance Standard 2: Labor and Working Conditions; iii) air emissions, iv) liquid effluent discharges, v) community health safety and security, including emergency response for all project components; vi) community health and safety impacts, vii) operations are in accordance with good international industry practice (‘GIIP’), viii) biodiversity, ix) 10 barge deliveries over a 7-10 month period during construction, x) population influx and xi) limited involuntary resettlement. The CTT plant will be located within the long established oil field area, adjacent to Sasol’s central processing facilities and the impacts and risks of the plant during normal operations are unlikely to pose significant risk to the surrounding environment or communities.

Globeleq’s management systems and supporting procedures refer to and have been developed to align with the Performance Standards, World Bank Group (‘WBG’) general EHS guidelines and applicable WBG industry sector guidelines.                                                  

Environmental and Social Assessment and Management System: A CTT environmental and social impact assessment (‘ESIA’) was completed in March 2019 to identify and manage potential environmental and social impacts throughout the project lifecycle: development, operations and decommissioning. The ESIA scope includes the 25km VTL. The project ESIA was subsequently approved by the Republic of Mozambique Ministry of Land, Environment and Rural Development in December 2019 in compliance with the Republic of Mozambique’s regulatory requirements for environmental impact assessment (decree 54/2015). The approval recommends full compliance with all mitigation measures contained in the ESIA and environmental monitoring management plans. The ESIA has been undertaken in a manner consistent with the PSs, incorporating the WBG general EHS guidelines and sector specific guidelines, including the WBG EHS industry sector guidelines for thermal power plants (2008), electric power transmission and distribution (2007) and construction materials extraction (2007). The project ESIA drew from baseline information collated as part of the ESIA development with specific provisions for site selection, management, and decommissioning of ancillary facilities having been included. A cumulative assessment was undertaken as part of the ESIA and considered the CTT project impacts as well as other proposed projects within the area and identified the various cumulative and residual impacts that may result. The cumulative impact assessment concludes the CTT project will have a low impact in terms of its residual impacts contributing to cumulative impacts on the surrounding area. The CTT ESIA and relevant assessment studies accompany this disclosure.

As required by Globeleq’s management system, described further below, the ESIA findings feed into Globeleq’s project decision-making process and engineering processes, which include the requirement for a completed and regulatory approved ESIA ahead of Globeleq’s internal project approval. Consistent with these requirements the project shall undertake a HAZOP study of the power plant as part of the EPC contract detailed design stage, per ESAP #1a. CTT shall also develop a project risk register for the construction and operations phases of the project, per ESAP #1e.

Policy: Globeleq is committed to environmental, social and health and safety management practices that prevent, minimize and otherwise mitigate any negative impacts in areas where they operate. Globeleq is committed to respecting and protecting human rights and improve the quality of life of those affected by company operations. Globeleq have articulated these commitments having developed and implemented five overarching E&S policies applicable to all operated assets addressing i) health and safety, ii) environment, iii) social and local socio-economic development, iv) employment and labor, v) security. As in all other aspects of its business, and as defined by its corporate policies, Globeleq’s policies make clear commitments to continuously improve environmental and social performance.

Globeleq’s corporate E&S policies will apply in full to the CTT project and form the basis for all activities undertaken as part of the project development and subsequent operations. The Globeleq policies apply to all contractors and sub-contractors performing work on behalf of the CTT project.

Environmental and Social Management Systems: At the corporate level, Globeleq has developed an integrated management system (‘IMS’) that covers health, safety, environment, security and social (‘HSESS’) aspects. The IMS describes the system by which HSESS risks are managed and articulates the organizational requirements to implement the management system across the Globeleq portfolio for both project development and operations. Contractor and sub-contractors are required to meet the requirements of the Globeleq IMS. The Globeleq IMS will be the governing management system for the project construction and operations. The IMS explicitly incorporates the requirements of PS1 including the expanded requirements of social management and stakeholder engagement and is aligned with IFC’s ESMS Implementation Handbook (2015). It is broadly aligned with the requirements of ISO14001:20153 Environmental Management and ISO 45001 Occupational Health and Safety management and includes requirements in the following eight areas: i) policies, ii) identification of risks and impacts, iii) management of risks and impacts (management program), iv) defining roles and responsibility for implementation, v) emergency preparedness and response, vi) training, vii) communication (internal and external) /document control, viii) monitoring, auditing and review.

Management Programs: At the project level, the Globeleq IMS will fully apply to the CTT project. A comprehensive construction management plan (‘CMP’) has been developed to support the implementation of the IMS and the imposed project compliance conditions as described in the project ESIA.

Supporting the project CMP, project specific management ‘sub’ plans have been developed providing detailed information on the implementation of the project HSESS conditions. The management plans define the project’s desired outcomes and actions to address the issues raised in the risks and impacts identification process. These management plans are aligned with GIIP, are consistent with the Performance Standards and relevant WBG EHS Guidelines. Specifically, the CMP sub-plans include: i) health and safety, ii) emergency preparedness and response, iii) community health, safety and security, iv) traffic and transportation, v) abnormal loads transportation (marine and land), vi) site clearance and rehabilitation, vii) water resource management, viii) waste management, ix) pollution prevention and control (addressing noise, dust, management of hazardous materials and effluent discharges), x) cultural heritage (including chance finds), xi) biodiversity management, xii) stakeholder engagement plan, xiii) influx management, xiv) labor management plan, xv) facilities and workers accommodation (including pest management) and xvi) a Resettlement Action Plan (RAP). The project has established a framework decommissioning E&S plan consistent with the regulatory requirements of Mozambique and PS1 requirements.

At the point of IFC’s disclosure the CTT project is in the process of selecting an engineering, procurement and construct (‘EPC’) contractor via competitive tender. Previous E&S performance is a key EPC contractor bid evaluation consideration. Globeleq’s HSESS policies and IMS fully apply to the CTT project EPC contractor, with relevant E&S project plans and studies having been included as part of the bid package including the project ESIA, Globeleq IMS, the project CMP and sub-plans.

As defined in the project CMP and supporting sub-plans, the EPC contractor is required to prepare, implement, and regularly update an EPC contractor HSESS construction management plan (C-HSESS CMP). The C-HSESS CMP will represent the unique reference document in which the EPC contractor defines in detail all organizational, technical provisions, and procedures required to implement and satisfy the obligations outlined in the project CMP and supporting plans and sub-plans, which include i) a contractor construction environmental and social management plan, ii) an environmental social and health & safety plan, iii) a local procurement plan for goods and services, iv) a labor management plan including a project labor agreement (to be developed by CTT– see PS2), v) facilities and workers accommodation (including pest management) and vi) an occupational health and safety management plan. CTT will ensure the required C-HSESS CMP, as defined in the project CMP, plans and sub-plans are developed and completed per ESAP #2a. Requirements for implementing the Resettlement Action Plan and stakeholder engagement will remain with CTT during the pre-construction and construction phase of the project.

To ensure sponsor and contractor project documentation alignment the project has committed to develop a pre-mobilization action tracker and a site set-up audit checklist. The action tracker and audit checklist will monitor implementation of HSESS construction management plan requirements during site establishment to ensure all actions as indicated in the construction management plan are completed and will form part of the project’s reporting requirements per ESAP# 4a.

For operations, the Sponsors have elected to operate the CTT power plant utilizing an in-house operations and maintenance (‘O&M’) organization. The Globeleq IMS will apply to the project during operations phase of the project.

Monitoring and Review: Globeleq have committed to monitor the implementation of all its HSESS policies and procedures and all related E&S aspects of the project, including contractor and sub-contractor performance, throughout the project life cycle, and will report the performance and progress to all levels of its management, including its board and shareholders, as well as other key stakeholders per ESAP 4a.

The CMP defines CTT project monitoring and review requirements. The CMP requires all non-compliance findings identified by the CTT team and/ or the EPC contractor are registered and summarized in a non-compliance report, to include photo evidence and proposed mitigation. Resulting corrective actions are to be reported and tracked by the contractor through a single project HSESS corrective action plan (‘CAP’). The CAP will be established and maintained by the selected contractor and will include all contractor, and sub-contractor actions, along with timeframes for closing out non-compliances. The CAP will be reviewed on a weekly basis by both the Contractor and the CTT project to confirm and agree closed actions.

The CMP defines the CTT project and EPC contractor reporting and management of change requirements. The EPC contractor is required to develop a management of change procedure considering HSESS implications when planning for changes in design, processes and activities. The CMP requires the EPC contractor develops an HSESS risk register and update the environmental aspects and impacts register for all changes in design and activities and prior to the introduction of any change in accordance with methodology set by the CTT project. The contractor must notify the CTT project of any change which has the potential to impact the project and management of HSESS.

In cases where the change involves a new worksite or other activity not previously assessed as part of the ESIA process, the EPC contractor will undertake an initial environmental & social risk assessment in line with the provided methodology. The risk assessment will be provided to the CTT sponsor and will be approved prior to commencement of works. When selecting the preferred alternative, the EPC contractor will adopt a mitigation hierarchy approach to address adverse environmental or social impacts and issues to workers, affected communities, and the environment from the worksite. This change management procedure, as defined by the project CMP, will be developed and implemented per ESAP #2a.

The VTL will be constructed and operated by SNTE consistent with the legally binding requirements of the project ESIA and ESMP, as approved by Ministry of Land, Environment and Rural Development in December, 2019. At the point of IFC’s disclosure, SNTE is in the process of selecting an EPC contractor via competitive tender. The project ESIA and ESMP were included in the contractor specifications for VTL tender package. The CTT project is financing the VTL line construction. As part of IFC’s financing, CTT will develop a VTL audit protocol to assure the VTL is constructed in a manner consistent with the project requirements as defined in the ESIA and ESMP, per ESAP #4c.

Organizational Capacity and Competency: At the corporate level, Globeleq has established an environmental, social, safety and governance board committee comprised of three permanent members, of which two are Globeleq board members and one shareholder. Additional attendees to the board committee are on an invitational basis. The committee meets a minimum of three times per year and, as articulated in the board committee mandate, has established standard reporting requirements which are onwardly reported to the Globeleq board. Globeleq maintains an organizational structure that defines roles, responsibilities, and authority to implement the ESMS. Specific personnel, including management representatives, with clear lines of responsibility and authority have been designated, with the structure undergoing periodic reviews.

The CMP identifies key company personnel required to oversee the EPC contractor’s implementation of the project’s HSESS requirements and all works on site, defined as the project implementation team. Key E&S related personnel include i) a health, safety and environment manager, ii) a social manager and iii) if required a community liaison officer to be in place for the duration of the CTT project development. These positions will report to a construction director via a construction manager. The social manager will be responsible for project interface with external stakeholders, ensuring alignment with project requirements for social aspects, undertake EPC contractor labor training and resettlement action plan implementation. As part of IFC’s investment the CTT project will secure these E&S positions prior to EPC contractor mobilization to site, per ESAP #3a.

Regarding the power plant EPC contractor capacity, the CMP defines the roles and responsibilities of the functions and the minimum qualifications, including: i) a site manager/ construction manager, ii) health and safety manager, iii) environment manager, iv) health and safety officers, v) environmental and social coordinator, vi) social officer, vii) human resources (‘HR’) manager, viii) industrial relations manager, ix) site security coordinator, and x) EPC site supervisors. As part of IFC’s investment the CTT project will ensure the project EPC contractor has in place these E&S positions, as defined in the project’s CMP, prior to EPC contractor mobilization to site per ESAP #3b.

Emergency Preparedness and Response: Complementing the CMP, an emergency preparedness and response plan has been developed addressing a range of potential events including fire, injury, hazardous spills, severe weather conditions, emergency evacuation and risks posed by natural hazards (e.g. geological, landslide, seismic hazards) and maritime incidents. The emergency preparedness and response plans sets the project’s requirement for the EPC contractor to establish a project emergency preparedness and response procedure that reflects the specific risks identified by the project. The project requires the EPC contractor’s emergency preparedness and response procedure is in place prior to mobilization to site, per ESAP #2a. As part of IFC’s financing the project will develop an emergency preparedness and response plan for the operations phase of the project, as defined in the project CMP, per ESAP #2b.

Gender Based Violence: The contextual risk for Gender Based Violence (‘GBV’) in Mozambique is considered high. The ESIA also identified that GBV is common in the communities within the project area of influence. An influx of project workers and job-seekers into the area and access to disposable income may increase GBV risks during construction. With support of the World Bank, Globeleq and the TTP have retained the services of a GBV specialist to undertake a GBV risk assessment of the TTP and CTT projects, including a mapping of GBV services and response providers to GBV Survivors in the projects’ area of influence. Based on the findings, a GBV prevention and response action plan will be prepared and the recommended measures put in place before construction mobilization starts per ESAP #1b and ESAP #1c. The plan will inform the development of relevant project policies, procedures (including the labor and community grievance mechanisms), plans and the workers code of conduct.                                                  

The CTT project will employ a peak construction workforce of ~800 during the anticipated 24-month construction period. A majority of these workers will be Mozambican nationals employed by the EPC contractor and sub-contractors. A limited number of expatriate staff will be retained for project management and specialized construction related work. Whilst qualified local community members will be prioritized for employment opportunities, it is expected that a large proportion of the required workforce will be sourced from outside the project area. Up to 70 workers will be employed during the O&M phase of the project.

Human Resources Policies and Procedures: Globeleq has an approved corporate employment and labor policy which defines its approach to managing workers and is consistent with the requirements of PS2. As part of the project documentation, Globeleq has developed a labor management plan (‘LMP’) which articulates the project’s commitments to labor and working conditions and sets out minimum requirements on labor management for the construction phase, including i) a worker code of conduct, ii) recruitment, iii) local content, iv) induction, v) worker disciplinary management, vi) demobilization, vii) grievance management, and viii) communicable disease prevention.

The project will also enter into a project labor agreement (‘PLA’) with Sindicato Nacional dos Trabalhadores da Indústria Construção e Minas de Moçambique (‘SINTICIM’), a labor union, as per the collective bargaining procedures in Mozambique. The PLA will be similar to the existing agreement between SASOL and SINTICIM, defining working conditions and terms of employment including i) salary grades, ii) overtime conditions, iii) working hours, iv) leave requirements, v) medical assistance and worker insurance provisions, vi) benefits and incentives, vii) induction requirements, viii) union membership requirements and ix) demobilization requirements. All workers will receive a written contract of employment which either makes reference to the PLA or, for workers not covered by the PLA or opt out of union membership, have their terms and conditions of employment defined in their contracts.

The project intends to provide accommodation for up to 550 workers sourced from outside the project area at an existing worker’s camp close to the site for the duration of the construction phase. A facilities and workers accommodation plan (‘FWAP’) has been developed outlining the project requirements for management of construction accommodation and provision of basic services and welfare facilities. These are consistent with PS2 requirements and the IFC/ EBRD guidance note on Workers Accommodation: Process and Standards.

Per ESAP #5a-d, guided by the requirements defined in the LMP and consistent with the requirements of host nation law and PS2, the CTT project shall develop i) an HR manual (with relevant policies and procedures including in relation to the demobilization of the project workforce following completion of construction), ii) a workers code of conduct, iii) a PLA defining working conditions and terms of employment, and iv) a labor grievance mechanism. The development of the project HR policies, procedures, code of conduct and the labor grievance mechanism will be informed by the project’s GBV action plan per ESAP #1c. These HR requirements including the labor grievance mechanism will apply to all project workers including those employed by any sub-contractors for all phases of the project and be made readily accessible and clearly communicated at induction and through the provision of additional sensitization and training. The sponsor will undertake regular audits of the contractors’ LMP requirements as part of the established monitoring and reporting requirements described in PS1, per ESAP 4a.

Occupational Health and Safety (‘OHS’): The activities undertaken for any construction project present inherent health and safety (‘H&S’) hazards. To address these risks, the CMP commits the CTT sponsor provides a safe and healthy working environment, defining the OHS requirements to be implemented by the EPC contractor. The CMP clearly defines the role and responsibility of the sponsor to i) review all OHS documentation prior to use to approve as fit for purpose, ii) undertake regular OHS audits of the EPC contractor works to verify compliance with the Globeleq OHS policy and the requirements of the CMP and supporting sub-plans and iii) undertake health and safety reporting as described in PS1.

Similarly, as defined in the project CMP, the EPC contractor will be obliged to develop an OHS management plan for onshore works and tasks related to barge shipments and works at the temporary jetty site per ESAP #2a. The EPC contractor OHS management plan will be required to meet the minimum requirements of the CMP, relevant supporting sub-plans and host nation regulatory requirements. In addition, the EPC contractor will be obliged to make all reasonable and practicable steps to provide a safe and healthy environment for persons to work in and to ensure that the public are adequately protected. The EPC OHS management plan will form a part of the overall EPC contractor project management system. The successful EPC contractor is required to operate an internationally accredited OHS management system consistent with GIIP, namely OSHAS 18001 / ISO45001.

The CMP obliges the contractor demonstrates detailed working procedures, method statements, directives or instructions for implementing control measures are in place, including i) sun exposure, ii) night work, iii) signage and marking, iv) working at height, v) chemical product handling, vi) working in confined spaces, vii) excavation works, viii) earthmoving, ix) work in explosive atmospheres, x) hot work, xi) scaffolding, xii) cranes and load lifting, xiii) material handling, xiv) working with machinery, xv) electrical safety, xvi) noise prevention, xvii) blasting, xviii) lone working, xix) substation building works, xx) laying high voltage lines, xxi) material transport (unloading and storage), xxii) maritime activities (including third party maritime activities) and xxiii) traffic including offsite traffic management.                                                  

Resource efficiency: The plant design utilizes CCGTs which will achieve efficiencies >52% over a wide operating output range of 100 MWe to the and the maximum power output of the plant. Plant operations and maintenance specifications will include routine and required maintenance to ensure enduring optimal performance.

Greenhouse gases (‘GHG’): Complementing the project ESIA, a greenhouse gas assessment (‘GGA)’ has been prepared quantifying the project’s GHG emissions and potential impacts. The report is prepared referencing Performance Standard 3 and in accordance with the ‘GHG Protocol Corporate Accounting and Reporting Standard’. The GGA estimates GHG emissions associated with the CTT project will be 1,088,575 tCO2e per annum for the first 5 years (2021-2025), and 1,323,827 per annum for the remaining 20 years (2025-2045) of the project’s design life. The GGA estimates the CTT project will contribute between 1.4% and 1.6% to Mozambique’s annual GHG emissions for the first 5 years and between 1.4% and 1.9% for the following 20 years.

The GGA contains high level action plan for the management of GHG emissions during the site preparation and construction, operational, and decommissioning and closure phases. Mitigation measures for GHG emissions during the construction stage have been included in a pollution prevention and control plan and traffic & transport management plan. The proposed GHG emission action plan is consistent with the requirements of PS3.

Air Quality: The project ESIA includes an air quality impact assessment which incorporates relevant sources that may contribute to air pollution within the project airshed. Air quality in the project area is not degraded according to WHO Air Quality methodology. The methodology used to assess the impacts of the CTT project to the ambient air quality in the area of influence (establishment of the baseline air quality, dispersion modelling), as well as the proposed measures to avoid or reduce the impact on air quality is consistent with PS3 requirements and WBG EHS guidelines requirements.

During construction, mitigation measures related to dust, air emissions, including CO, NO2, SO2, PM and VOCs during construction phase are included in the traffic & transport management plan and implemented as part of the EPC contractor management plans, per ESAP #2b. Emissions guidelines, consistent with WBG EHS guidelines have been included in technical specifications for the EPC contract.

During operations, project air quality impacts due to emissions from PM10, NO2 and SO2 has been assessed as low post mitigation and are within WBG EHS guideline requirements. The project CMP requires the project’s detailed design, to be undertaken as part of the EPC contract, will ensure the plant is designed to operate within the emissions limits defined by the WBG general EHS guidelines. The project ESIA defines mitigation measures including increased stack height, application of control technologies such as selective catalytic reduction, selective non-catalytic reduction, catalytic combustion and wet low emissions. Such mitigation measures, as defined and tracked in the project ESIA mitigation register, will be included as part of the project’s detailed design phase, a requirement of the project CMP.

As defined by the project operations management plan CTT is committed to developing an operations air quality monitoring plan which reflects the CTT final design to collect, analyze, review and compare with the operating standards at regular intervals to identify necessary corrective actions and ensure enduring consistency with the project’s emissions requirements, per ESAP #2b.

Noise: The project ESIA considers noise impacts during both the construction and operations phases of the project supported by a noise modelling assessment. For the project’s construction phase, the ESIA concludes that no households will be affected.

For operations, the ESIA concludes that no households will be affected by the 55-dBA daytime limit or 45-dBA nighttime limit and therefore meet the requirements of the WBG general EHS guidelines, table 1.7.1. Furthermore, the noise modelling confirms that no households will be subjected to an increase of 3-dBA, per the requirements of the WBG general EHS guidelines on noise (section 1.7).

Water consumption (abstraction): Raw water will be required by the CCGT plant for several uses, including demineralized water for process use, firefighting water and potable water. Water will be extracted from an underground aquifer through an existing dedicated project well located within the project fence line. Water requirements are to be reduced to the minimum as articulated in the project water management plan. It is expected that a continuous pumped flow of ~30m3/h will be sufficient for the operation of CTT. As described in the project’s water supply assessment, there are no anticipated impacts to community water resource availability. A water treatment plant will be installed in order to produce the required qualities of water (demineralized, potable, service), to be defined as part of the EPC contract. Rainwater will be collected and re-used as raw water where practical, further minimizing the extraction of groundwater. The project has developed a water resource management plan, complimenting the overarching construction management plan.

Pollution Prevention of surface and ground waters: As described in the project ESIA, the proposed CTT plant site is situated within the Govuro River catchment basin and is subject to cyclones that generate strong winds and heavy rainfall. The project ESIA identifies project activities which may impact local water resources and ground water quality, the significance of which is considered low post mitigation. Mitigation measures include construction of storm water channels, sediment traps, separation of clean and dirty storm water, and the containment and correct disposal of potentially contaminated water. As per the CMP, all wastewater discharged from the site is required be consistent with host nation law and the WBG general EHS guidelines and will be subject to an operations monitoring program as defined in the project operations management plan, per ESAP #2b.

Similarly, as part of the CMP the CTT project has a complementing pollution prevention and control plan defining specific requirements for i) water and groundwater protection, and ii) monitoring and reporting on water and groundwater pollution prevention. The EPC Contractor will be responsible to prepare procedures which address the control of erosion, sediment and drainage as set out in the project’s site clearance and rehabilitation plan.

Solid waste & effluent discharges: The project will generate various types of solid and liquid waste during construction and operations. Per the project ESIA, solid waste will be segregated and temporally stored on site until final disposal at official registered landfill sites. Wastewater treatment solutions will be defined for all locations where employees regularly work and be in compliance with WBG EHS Guidelines. These will consist of portable toilet facilities or septic tanks that will be serviced on a weekly basis (minimum) to ensure there is no risk of discharge to the environment. As defined in the project’s pollution prevention and control sub-plan the EPC contractor is required to define wastewater treatment solutions for all locations where employees regularly work. These will consist of portable toilet facilities or septic tanks that will be serviced on a weekly basis (minimum) such that there is no risk of discharge to the environment. These elements are subject to the CTT audit process, as described in the project CMP, per ESAP #2a. The final option will be selected as part of the detailed design to be undertaken by the EPC contractor. During construction, project specific treatment requirements have been defined for sewage effluent and effluent discharges via the project pollution prevention and control plan.

The project pollution prevention and control sub-plan defines requirements for solid waste management, including risk assessment, monitoring and audit, reporting for each waste stream (including sub-contractor waste streams). The pollution prevention and control sub-plan requires the EPC contractor develop a site waste management procedure prior to the start of any works on site. As part of IFC’s investment the project shall ensure the EPC contractor develops an auditable change of custody procedure for hazardous and non-hazardous wastes, per ESAP #4d. The EPC contractor will be required to develop a barge waste management procedure to ensure all barge waste is dealt with in accordance with MARPOL convention requirements per ESAP #2a. Waste arising from beach landing area will be also part of the overall project waste management provisions.

Process water effluent: Process water and brine from the demineralization plant will be reinjected into deep and confined karst aquifer. Water reinjection is considered as part of a dedicated effluent discharge options assessment which concludes injected water will dilute over time with a horizontal migration of the plume between 300-500m from the injection well over a 100-year period. Consequently, the study concludes water reinjection has limited impact potential on the quality or temperature of the aquifer and a low risk to human health of downstream water users. As part of IFC’s investment the project will incorporate effluent discharge data, as determined by detailed design, into the operational management plan which includes groundwater monitoring requirements, per ESAP #2b and #2c.

Hazardous materials: Various hazardous and non-hazardous materials will be used for equipment maintenance during construction phase and larger quantities of such materials and chemicals will be used to treat boiler water during the project operations phase. For each materials/ chemicals a materials safety data sheet will be available on site and in areas where such materials/ chemicals are used or stored. Personnel working with these materials and chemicals will be instructed and provided with protective personal equipment. The CTT project has developed a construction waste management plan. The EPC contractor is required to develop a method statement for management of hazardous waste which shall include an auditable change of custody procedure consistent with host nation law on hazardous waste management (Decree No. 83/2014) and WBG general EHS guidelines, per ESAP #2a and #2d. As part of IFC’s financing the project shall incorporate develop an operations stage hazardous waste management plan, as defined in the project ESIA and per the requirements of the project operations management plan and project HAZOP (ESAP #1a), per ESAP #2b.

Electro-magnetic fields: The project ESIA considers health impacts as part of the project development and operations. The project defines a 100m partial protection zone from any project electro-magnetic field generating element, and consistent with GIIP. The partial protection zone around the transmission line and CTT will be maintained by co-operative agreements with the relevant local community leaders/ chiefs and government departments. If displacement should occur this will be done in line with project compensation procedures defined in the project RPF.

Pesticide Use Management: Pesticides and herbicides will be used during project, e.g. for vector control. All personnel responsible for spraying pesticides will wear appropriate PPE and receive annual medical check-ups.                                                   

Community Health and Safety: The CTT plant site is located in a rural area over 2km from the nearest community, Mangugumete. Other sites required as part of the project construction phase include i) the beach landing site options at Inhassoro town, which is in area where there are some housing structures and commercial enterprises including tourism establishments, and ii) the transportation route from jetty to the site, which passes through Inhassoro town and several villages and settlements.

During construction, the dominant vehicle movement patterns will be in relation to the transportation of construction material and equipment. A traffic impact assessment was undertaken as part of the project ESIA. The key aspects of the assessment considered the beach landing and the transportation routes. A final decision on the routes, timing, nature of any upgrades and installation of structures to facilitate safe movement of abnormal loads will be made by the EPC contractor in liaison with the relevant transportation authorities in Mozambique. Based on the findings of the assessment, CTT has prepared a traffic management plan and an abnormal loads transport plan with appropriate measures to manage potential transport related impacts, including i) driver training, ii) drugs and alcohol testing for drivers, iii) speed controls, iv) posting traffic marshals at high risk locations, v) signposting, and vi) undertaking community awareness programs. The traffic management plan and an abnormal loads transport plan will be included as part of the EPC contract and cascaded down to sub-contractors, as required. Measures to undertake continuous monitoring and periodical audits of the implementation of the plan will also be developed and implemented.

A large proportion of the required construction workforce will be sourced from outside the project area and housed at an on-site workers camp for the duration of the construction phase. The influx of migrant workers and possibly, other groups of people in search of economic opportunities created by the project, into local communities (the area has already seen a significant increase in population partly as a result of presence of the SASOL facilities nearby), may lead to a number of negative social impacts including i) increased pressure on local resources, infrastructure and social services which are already insufficient for the local communities; and ii) increased social pathologies such as drug and alcohol abuse, sex workers, GBV, and increased incidence of sexually transmitted diseases such as HIV/AIDS and other communicable diseases. These risks and impacts have been assessed in the ESIA, and an influx management plan and a community health, safety and security plan has been developed. These plans include i) measures related to maximizing local recruitment, ii) HIV/AIDS and STI awareness and prevention program for site workers as well as local communities, iii) malaria and vector controls programs; requirements for adequate on-site medical facilities, iv) a community grievance mechanism and v) provisions for periodical monitoring of social related effects of the influx of migrants. The implementation of these plans, together with the code of conduct, per ESAP #5b, and the prevention and response GBV action plan, per ESAP #1c, will help manage the risks and impacts of population influx.

Security Arrangements: The project has developed a community health, safety and security sub-plan which explicitly refers to the security requirements articulated in PS4 including both private and public security forces. The sub-plan establishes the minimum requirements for the project’s EPC contractor to meet as part of the project construction phase. 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 contractor. Security guards will not be armed.

The project 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. As part of IFC’s financing the project will undertake a security risk assessment and develop a security management plan, code of conduct, a memorandum of understanding and relevant supporting procedures for the construction and operational phases of the project in a manner consistent with the requirements of PS4, as guided by IFC’s “Good Practice Handbook on the Use of Security Forces: Assessing and Managing Risks and Impacts” and GIIP, namely the Voluntary Principles on Security and Human Rights, per ESAP #1d and ESAP #2e respectively. 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 community grievance mechanism 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, the sponsor will undertake regular audits of the established security provisions as part of the established monitoring and reporting requirements described in PS1, per ESAP #4b.                                                   

Terrestrial and aquatic biodiversity: The CTT project area overlaps the Southern Swahili coastal forests and woodlands ecoregion. The terrestrial components of the project will be located in modified habitat. No critical habitat requirements apply to the terrestrial components of the project. Proposed project components likely to impact terrestrial and aquatic ecology include i) the development of the power plant site (20 ha) and the 25 km VTL transmission line, ii) the establishment of a temporary beach landing site to facilitate large equipment delivery during construction; and, iii) the upgrade of the road access route required to transport heavy equipment from beach landing to the project site.

The VTL transmission line connects the project to the national transmission system and will pass through a sparsely populated rural area with small trees and shrubs. No critical habitat has been identified along the VTL route. Heavy equipment will be transported approximately  41.8 km from the temporary beach landing site to the CTT project site using existing public roads. Approximately 11.3 km from the landing site, the public road passes over the ~8m  wide Govuro river via an existing public bridge. At the point where the public bridge crosses the Govuro river, habitat is comprised of permanent and seasonal wetlands and is not assessed as critical habitat.

Terrestrial and aquatic biodiversity risks and impacts have been assessed as part of the project ESIA and additional terrestrial impact assessment & aquatic ecology impact assessment study, both of which are disclosed alongside this ESRS. The impact assessment studies define specific mitigation measures to be included in the project environmental and social management plan, as articulated in the project’s CMP and biodiversity management plan (‘BMP’).

Several birds of conservation concern have been recorded in the region, including vultures, various other raptors, cranes and flamingo. These species are known to be susceptible to transmission line collision/ electrocution. The project impact assessments determine the risk of bird collision and/or electrocution is expected to be a minor impact. As part of IFC’s investment the project shall update the project BMP to reflect design mitigation determined during EPC detailed design stage and subsequent operational monitoring measures consistent with WBG EHS guidelines for electric power transmission and distribution, per ESAP 2f.

The project has identified project transport vehicles and loads will exceed the carrying capacity of the existing public bridge crossing the Govuro river. The ESIA considers two Govuro river crossing options adjacent to the existing bridge, both of which are temporary and would be removed and rehabilitated following construction. The final Govuro crossing option will be selected as part of the EPC detailed design. Any changes to the crossing options defined in the project ESIA shall be undertaken as part the project’s change management process and incorporated into the relevant construction management plan per ESAP#2a.

Marine Biodiversity: The barging route lies between Bazaruto Bay and the port of Beira, in an area of overlap between the coral, swamp and parabolic coastal dune marine ecosystems known as the Delagoa Bioregion. The known species of interest in the wider Bazaruto Bay area include the loggerhead turtle (Caretta caretta – Endangered) the leatherback turtle (Dermochleys coriacea - Vulnerable), dugong (Dugong dugon - Vulnerable), and the Indian Ocean humpback dolphin (Sousa plumbea - Endangered). Sensitive habitats are present in the barging route area of influence, which include seagrass meadows and coral reefs. Critical habitat screening as part of marine biodiversity assessment proposed that Indian Ocean humpback dolphin and 6 species of marine gastropod (shellfish) which occur in the broader study area may meet Critical Habitat requirements. The area is thus treated as Critical Habitat but no significant impacts on any of these species is expected. Net gain will be delivered via additional conservation actions. The nearest marine protected site is Bazaruto Archipelago Marine National Park (‘BANP’) located ~10km to the east, an important bird and biodiversity area and special protection area for dugong. Barging operations will not interact or enter into the BANP marine protected area. No direct impacts are therefore expected on this marine protected area as a result of the project activities. Suitable turtle nesting habitat may be present 10-15 km south of the barge landing area at Inhassoro where dune systems are evident.

Project marine based activities are limited to the transshipment of oversized equipment required for the project’s construction. Barges are loaded in the port of Beira and will travel directly to the temporary project landing site. A maximum total of 10 barge deliveries will be required over a 7-10 month period.

Impacts arising from barging activities have been considered as part of the project ESIA and dedicated marine impact assessment, both of which accompany this disclosure. To address any potential impacts arising from the 10 barge deliveries over a 7-10 month period during construction, the project’s marine impact assessment determined the extent and presence of sensitive habitats in the project area by remote sensed imagery. The impact assessment determined the increase in project related vessel traffic is minor in relation to baseline marine traffic intensity. However, the limited number of barging operations required as part of the project construction may have the potential to impact marine mammals and supporting habitat which have been recorded throughout the Bazaruto bay area.

To mitigate, micro-routing of the barging path was undertaken as part of the marine impact assessment to avoid identified areas of sensitivity. The project further determines additional mitigation measures for the barging operations, which include: i) barging speed limits of <5 km/h within the Bazaruto Bay area (dugong cruising speeds are ~10 km/h, with burst speed 22 – 25 km/h), ii) a certified marine mammal observer (‘MMO’) will be present on all barge movements, and will have authority to influence the speed and direction of vessel movements where any potential risks to marine mammals or other marine life are identified, iii) barging operations will be routed via specific barge and vessel lanes delineated by non-styrofoam buoys.

The final approach will require the barge to transition across a narrow coastal strip of seagrass, common with nearshore environments in the area. In order to mitigate impacts from propeller action, the barge will be positioned and pulled into the temporary jetty via a cable mooring system, thus removing vessel propeller disturbance that may otherwise cause an impact to the nearshore seagrass meadows.

The impact assessment indicates that potential impacts are low post mitigation and are therefore considered to be temporary, limited in number, site-specific, reversible, and readily addressed through mitigation measures consistent with GIIP.

The coastline is dynamic and prone to cyclone events. As part of the project detailed design, ground-truthing will be undertaken (to include dive and camera surveys) prior to the commencement of barging operations to determine the need (if any) for any further barge micro-routing adjustments determined in the marine impact assessment per ESAP #2g. Outcomes of the ground truthing exercise shall incorporated into the revised Biodiversity Action Plan per ESAP #2f.

Ecosystem services: Five priority ecosystem services were identified as part of the project ecosystem service impact assessment, which accompanies this ESRS, namely i) food - subsistence crops, ii) food – sea and, iii) river and coastal fisheries; iv) biomass fuel (wood and charcoal); and, v) fresh water supply. Mitigation measures are defined in the impact assessment and incorporated into the project management plans. The impact assessment concludes the impacts to ecosystem services is low. Similarly, impacts arising from the marine transshipment route is expected to be negligible due to the 10 barge deliveries over the 7-10 month barging operations period.                                                   

Stakeholder Engagement: Globeleq has developed a project specific Stakeholder Engagement Plan (‘SEP’) in line with Mozambican laws and consistent with the requirements of PS1. Stakeholder engagement activities undertaken as part of the ESIA process included scoping level consultations (in February 2015), community social surveys, focus group meetings and key informant interviews during the baseline data collection (in 2018) and ESIA public disclosure meetings held in Inhassoro, Maimelane, and Inhambane (in January 2019). Stakeholder engagement has also been undertaken as part of the RAP development process (undertaken during 2019 and 2020), relating to the VTL transmission line routing, census and asset surveys and with fishermen and tourism operators in relation to the temporary jetty and barging operations. Issues raised during these engagement activities relate to access to employment opportunities, transportation routes and road safety, the temporary beach landing sites including potential impacts to marine life and tourism and fishing activities, population influx and impacts on communities, ongoing information regarding the project, land acquisition and resettlement and provision of electricity as a project benefit. All meeting minutes and attendance registers are maintained. The sponsor shall update the SEP to account for further engagement and sensitization activities to be undertaken with tourism operators and fishermen and fishermen’s associations, on the selection of the beach landing site, the compensation arrangements and claims procedure, the community grievance mechanism and in relation to the construction of the temporary jetty and barging operations, as per ESAP #7. A full time Social Manager will be retained to manage stakeholder relations between the project and the communities.

As part of maintaining good community relations, the sponsor will also develop a Community Develop Plan focusing on socio-economic development projects during the operation phase.

Community Grievance Mechanism (‘CGM’): The Sponsor will establish and maintain a project level CGM prior to the start of the RAP compensation package disclosure process and for the duration of the project. The SEP provides an outline of a CGM that allows for submission and management of grievances (including the lodging of anonymous grievances) and reporting and feedback loops, which are consistent the requirements of PS1. Where a resolution cannot be achieved internally, the CGM will allow for external redress using independent parties. The CGM will also provide recourse for any claims for compensation that were not identified during the RAP process including those in relation to project site. The Social Manager will also serve as a grievance officer and will act as the interface between EPC contractor and the communities on community matters including the recruitment of local workers and management of grievances as a result of the EPC actions and activities. CTT will strengthen the structure and functioning of the CGM in line with the GBV action plan, per ESAP #8.                                                   

Electricidade de Moçambique

E.P., Av. Zedaquias Manganhela n.267

Predio JAT IV- 4 Andar

Maputo

Moçambique