This is a Category B project according to IFC’s Policy on Environmental and Social Sustainability (2012). Based on information reviewed by IFC, the proposed project will have limited adverse E&S impacts that are few, site specific, largely reversible, and readily addressed through existing mitigation measures and good international industry practices (GIIP).

Key E&S issues associated with this project include:

• The company's capacity and management systems to assess and manage E&S risks and impacts for the facilities/sites covered under the project;
• Consistent management of labor and working conditions for employee and contract workers including working hours, overtime, grievance redress, retrenchment, gender-based violence and harassment and occupational health and safety (OHS) policies and practice;
• Resource efficiency and pollution prevention measures;
• Monitoring and management of air emissions, waste and wastewater and hazardous materials;
• Emergency planning and response, including the COVID-19 pandemic;
• Impacts on nearby community health and safety;
• Potential impact on soaring birds by transmission lines or during foraging on existing landfills;and
• The company's stakeholder engagement activities related to E&S aspects and community grievance mechanism.

NCWI does not have a documented corporate or site-specific environment and social management system (ESMS). Only the Shenzen Lisai facility, where NCWI is the developer and operator of both the landfill and the LFGE facility, has an ESMS certified to ISO9001, ISO14001, and ISO45001, which based on the site visit and document review, was found to be under implementation. The company does not have a dedicated E&S organization at the corporate level nor at project sites. While NCWI’s investment department is responsible for the regulatory permitting for each project, E&S aspects during O&M are overseen by the project manager.

The company undertakes environment impact assessment (EIAs) as per regulatory requirements. Thirteen projects out of the 24 covered under IFC financing, that are either operational or under construction, have undertaken EIAs as per regulatory requirements. In absence of a corporate ESMS and E&S organization, the EIAs have been undertaken against different emission and discharge standards instead of the applicable national emission and discharge standards. The national EIA regulation does not require a social impact assessment. Therefore, while significant social impacts are not expected from the LFGE projects, they will be assessed as part of the PS compliant Environmental and Social Impact Assessment (ESIA) for future projects (under ESAP #2). For the existing projects, potential social impacts will be assessed as part of the gap analysis and supplemental assessments required under ESAP #1.

The company will, for each project site covered under this IFC financing, develop and implement a corporate and site specific ESMS that meets IFC PSs; undertake ESIAs that meet IFC PSs for the project for which EIAs have not yet been undertaken (ESAP #2);review the 13 existing EIAs, identify gaps with the national EIA regulation and standards applicable to LFGE projects, IFC PSs and WBG EHS Guidelines, and address the gaps in supplemental assessments and/or the site specific ESMS (ESAP #1).The ESIAs prepared under the proposed investment and the existing EIAs, will be disclosed together with this ESRS and locally by the company as part of the public consultation and disclosure process. The ESRS will be updated, as needed, to incorporate findings from any supplemental assessments, which will also be disclosed when completed. The PS-compliant ESIAs (or the supplemental assessments) will include, in addition to the land acquisition studies discussed below, all the studies and engineering measures required for the power lines as discussed below under PS6 on Biodiversity Conservation and screening of risks and impacts on indigenous peoples and cultural heritage.  The company is also considering the setup of three potential LFGE sites located in Nanning, Pubei and Dashiqiao. Nanning and Pubei are both in the Guangxi Zhuang Autonomous Region where there are populations of various ethnic minority groups including the Zhuang, which is the largest ethnic minority group in China by population size. Adjacent to the east of the Dashiqiao site is the Yingkou City Huzhuang Hui Minority Cemetery, and with the Shiqiaozi Man Minority Village located about 790 m north. Therefore, in the vicinities of the three potential sites, there are populations of the Zhuang, Hui, and Man ethnic minority groups. Although the screening carried out at appraisal seems to signal not likely to be impacts on such groups, if those project sites are developed under IFC’s proposed investment, risks and potential impacts, including applicability of PS7 on Indigenous Peoples, will need to be assessed as part of the relevant ESIAs (ESAP #2).

As part of the site specific ESMS development process, the company will undertake a compliance review against applicable regulatory requirements and implement corrective actions where non compliances are identified (ESAP #1). The company will also put in place an appropriate E&S organization at the corporate and at each IFC funded LFGE project site which will be comprised of at least one dedicated and qualified EHS officer and a Stakeholder Engagement officer at the corporate level (ESAP #3). Other actions under ESAP #1 and ESAP #2 require that the company will: develop a construction stage E&S management plan; put in place procedures regarding groundwater monitoring as discussed under PS3 below; develop and implement a land acquisition and involuntary resettlement policy and procedure to ensure that any land acquisition and/or involuntary resettlement that has occurred for the project and any new land acquisition carried out for the project meets IFC PSs and that gaps are closed through implementation of RAPs/LRPs; and put in place procedures to identify and review any historical/legacy resettlement issues or compensation claims for both the project sites and transmission lines.

NCWI will, for locations where there is potential for cumulative impacts from third party developed waste to energy projects (WtE) projects including Liling, Ankang, Shanghang and Wuping, disclose the cumulative impact assessment studies of the respective WtE projects, per national requirements and aligned with IFC’s PS1 requirements; implement an air emission monitoring program at each of the sites and disclose publicly the monitoring results; and disclose the ESIA air quality modeling results (ESAP #2).                                                   

 NCWI Corporate employs a total of 486 regular (up to November, 2021), full-time individuals, inclusive of Nanjing and Shenzhen Headquarters and the LFGE project site’s management staff. Each project site has a General Manager  who is hired under NCWI corporate and rotate between projects as needed. Additionally, at each LFGE project site, NCWI typically employs about 8-10 full-time individuals for daily operations and 3-4 temporary workers for installing the landfill membranes on an as-needed basis.

CWI Group has a HR handbook that is also applicable to NCWI. The company has a corporate HR department. HR policies are applicable to corporate employees and full-time employees (direct workers) at each project site. The HR Policies however do not cover temporary workers at project sites, directly hired by the company. The IFC review identified some non-compliances with national laws including excessive overtime without overtime wages, absence of signed contracts for construction and other temporary contract workers, and absence of occupational disease and health pre-assessment, registration or monitoring programs. The non-compliances will need to be corrected as part of ESAP #4.

Due to the small number of employees at the project sites and the company’s corporate, there is no workers’ organization for NCWI at the corporate level or at the level of the project sites. Based on the information available, only Shenzen Lisai site has a union since there are 77 employees and a worker’s union is required by local government. The company does not restrict the right of the workers to associate.

At end of life of a LFGE project, the locally employed full-time employees at each site are allowed to either rotate to another project site or to leave the company. NCWI does not have a formal retrenchment policy in place. The company has a grievance mechanism which, based on the review, appears to be implemented for direct workers. The company has procedures to prevent child labor and forced labor. The HR handbook does not specifically mention non-discrimination and equal opportunity but commits to merit-based recruitment. The company does not have a structured occupational health and safety (OHS) management system.

Insulation used at LFGE project sites has asbestos containing materials (ACM). Based on the information collected during IFC’s review, personnel were not aware of the health risks associated with ACM, and no health testing and workplace air quality testing are done. The company at the corporate level and at the level of project sites does not have a contractor management procedure to monitor and manage contractors with respect to their labor management. Based on information provided during IFC’s review, the company indicated that it does not hire migrant labor. Contracted workers do not have access to a grievance mechanism.

NCWI will implement measures to demonstrate compliance with working hours and overtime compensation requirements under national regulations, for all the direct workers including temporary workers(ESAP #4). Furthermore, for IFC funded projects and under ESAP #4, the company will update its HR Policies and Procedures to include: a grievance redress mechanism aligned with PS2 provisions; contractor management procedures in line with PS2 and national requirements including (a) provision of access to an appropriate, anonymous and confidential grievance mechanism for all workers including permanent employees, temporary workers, short term workers and contract workers, and (b) accommodation standards in line with IFC’s PS requirements and relevant guidance; a formal retrenchment policy; and gender-based violence and harassment (GBVH) prevention and redress policies and procedures.  In addition, the company will develop and implement a structured OHS management system for construction and operation phases including job hazard analysis, workplace monitoring, occupational health monitoring, and phase out of ACM use (ESAP #5).                                                  

 LFGE projects capture methane in the landfill gas and convert it to CO2 while also generating electricity. This has a positive impact on resource efficiency and contributes to GHG emission reduction. The project’s gross carbon emission (for all 24 sites taken together) is estimated as 1,903,000 tCO2e per year, but with methane capture, the project is estimated to reduce about 3,428,900 tCO2e GHG.

Each of the project sites require 0.5 m3 of makeup water per day for equipment cooling and limited quantity for domestic use. Bottled water is provided for drinking.

As there is no applicable air emission national standard for internal combustion engine power generation facilities, NCWI requires facilities to comply with either standard for gas boiler or thermal power plant emission standard for gas turbines. Both these standards are more stringent than the applicable WBG EHS Guideline values. Nanning site refers to general air emission standard in which NOx emissions may be higher than WBG EHS guideline values. NCWI will, as part of the site specific ESMS, implement measures to demonstrate that air emissions at the Nanning LFGE facility is within applicable WBG EHS Guideline values. Construction and operation stage noise meets WBG EHS Guideline values. However, in absence of monitoring data, project facilities are unable to demonstrate compliance with the applicable standards. The company will, as part of the corporate and site specific ESMS, put in place a monitoring and reporting procedure to demonstrate compliance with applicable air emission and noise standards, including applicable and relevant WBG EHS Guidelines values (ESAP #2).

Wastewater from the project sites is typically limited to domestic wastewater and condensate from the pre-treatment of LFG. The domestic wastewater is diverted to on-site septic tanks that are cleaned out regularly or to any wastewater treatment facilities present at the landfill site. The condensate is usually disposed of by spraying it on the landfill body and therefore it is ultimately collected and treated with leachate in the leachate treatment facility of the landfill.

The types of hazardous waste generated at the project sites include waste engine oil, waste activated carbon, and waste desulfurization catalyzers. In the absence of a corporate or site specific ESMS, project sites have adopted variable practices related to handling, storage, and disposal of hazardous waste. Under ESAP #2, the company will as part of the corporate and site specific ESMS put in place procedures for hazardous waste management that meets WBG EHS Guidelines.

Based on the information available during IFC’s review, a risk was identified and relevant to potential presence of ACM in piping insulation material. Onsite staff interviewed were not aware of the risks and management of ACM in the workplace, and no management plan for ACM was found. This risk will be addressed through the development and implementation of an ACM Risk Identification and Management Plan, under ESAP #5.

Landfills where the project is already operational or is under construction all have a containment lining and leachate collection and treatment facilities. The footprint of NCWI’s operations at each site is small compared to the landfill’s footprint and does not involve activities that can cause material soil or groundwater pollution. The company will: (a) at the Liling, Wafangdian and Gaizhou remote project sites, where groundwater from onsite wells is being used for domestic purposes other than drinking, get the water tested and allow their use only if found fit for such use; (b) for future projects, put in place procedures as part of its corporate ESMS to rule out historical pollution before signing the development agreement; and (c) obtain groundwater monitoring reports from the landfill self-disclosed environmental monitoring information in regulator’s environmental permit database, or from the landfill authorities where public information is not available. Where the landfill operator is not monitoring groundwater, the company will implement a groundwater monitoring program to monitor groundwater quality upgradient and downgradient of the project site and confirm that no contamination is potentially attributable with the LFGE operations.                                                  

Limited traffic increase is expected during the 4-8 month project construction period. No increase in traffic expected on account of each of the LFGE projects during operation phase. Each project site has limited use of heavy equipment during the construction stage, which is undertaken within existing landfill roads and therefore does not adversely impact vehicular traffic in the local communities.

In general, the installation of HDPE membrane at the landfills by NCWI has an ameliorative impact on control of odor and vectors. Furthermore, given the small project scale with respect to the landfill operation and its location within existing landfills, no significant impacts to community health and safety are expected from the operations of the LFGE facilities.

The project sites and landfills have access control measures (fencing and guardhouses) to prevent members of the community accessing the project sites. There are no armed security personnel hired at the landfills or the project sites.

NCWI will, as part of the corporate and site specific ESMS under ESAP #2, develop and implement an emergency preparedness and response plan for each project, covering construction and operation phases including any community health and safety risks.                                                   

 The projects are located throughout China within a mix of peri-urban and rural landscapes. The project sites themselves consist primarily of modified habitats with some adjacent habitats consisting of natural habitats, mainly consisting of forests or waterways.

While no critical habitat associated with any of the sites were identified, a screening of species predicted to occur at the proposed sites identified species of IUCN Vulnerable listed raptors which may be present from time to time if they are attracted to the landfills for forage. The LFGE sites and operations are unlikely to have an impact on these species; however, soaring bird species may be impacted by powerlines due to collision and electrocution risks. As part of the ESIAs or the supplemental assessments required under ESAP #1 and ESAP #2, the company will ensure that bird surveys are carried out for each of the project sites, especially for sites which are located in the proximity of Important Bird Areas, and relevant design measures for avian-safe power lines are implemented.