Performance Standard (PS) 5 does not apply given the barren and desertic nature of the land that is government owned and has been designated for industrial development. The area is not used by local communities in any form or capacity and no land legacy impacts were identified. PS7 is not applicable as no Indigenous Peoples (IPs) have been identified in the project area. Similarly, PS8 is not applicable as there are no registered cultural sites in the project area nor have cultural heritage values been identified. A Chance Find Procedure will be developed, as part of the EPC ESMS, to manage any cultural heritage that could be uncovered during construction.

This is a Category A project as per IFC's 2012 Policy on Environmental and Social Sustainability as the project has the potential to cause significant adverse E&S risks and/or impacts that are diverse, irreversible, or unprecedented. The categorization is mainly derived due to biodiversity risks in the Project area (and wider landscape) associated with globally important numbers of migratory soaring birds concentrated at the Gebel El Zeit IBA and surrounding area. As such, the key E&S issue for the project concerns the avoidance, monitoring, and management of potential adverse impacts including cumulative impacts on migratory soaring birds during construction and commissioning and particularly during wind farm operations.

Other key E&S risks associated with the project include: i) E&S and OHS performance during construction and operation by the project participants (AWPC, EPC, sub-contractor, EETC, WTG supplier and O&M contractors); ii) fair treatment and safe working conditions for employees and contractors alike, including adequate adoption and implementation of relevant human resource (HR) policies and procedure, transparent and non-discriminatory recruitment and an effective worker grievance mechanism; iii) supply chain risks including forced and child labor; iv) community safety (including harassment and gender-based violence) due to labor influx, accommodation needs, road traffic safety and presence of security forces; and, v) stakeholder engagement and grievance management, with particular focus on the Bedouin community.

Environmental and Social Assessments Management Systems and Policies.

AMEA Power has a corporate-level integrated quality, health and safety and environment (QHSE) management system (MS) certified (as of March 2021), to ISO 90001, ISO45001 and ISO14001, respectively. As part of the corporate integrated QHSE MS, AMEA has a suite of 12 policies that it applies to its projects and operations as committed therein, which are: quality policy, health and safety policy, environmental policy, social sustainability policy, people policy, gender equality policy, security policy, anti-modern slavery policy, anti-corruption policy, anti-money laundering policy, whistleblowing policy, and a code of conduct. The E&S policies are aligned with IFC PSs and commit AMEA to compliance with all applicable E&S laws and regulations, and constitute a voluntary commitment to which AMEA subscribes, this includes the ISO management system and IFC PSs, as stated in some of their policies (e.g., security and gender).

As part of its commitment with sustainability, AMEA also joined the United Nations Global Compact (the “UNGC”) initiative in June 2021 and formally adopted the UN Global Compact Ten Principles in the fields of human rights, labour, environment and anticorruption.

AMEA has developed an Environmental and Social Management System (ESMS) Manual for the AWPC, which sets overarching ESHS commitments and obligations including a Project-specific ESHS policy, an E&S organizational structure, a framework for the project ESMS and associated E&S management plans, communication, training, monitoring, and audit requirements. To this effect the ESMS manual requires the EPC and O&M contractor to develop and implement 4 overarching documents which includes an ESMS manual, QHSE policies and a legal and a permit register supported by a comprehensive set of management programmes. Similarly, it also requires ISO certification and 5 management system umbrella plans on project, quality and contractor management plus a communication plan and a document control system.

AMEA has also developed a QHSE Employers Requirements document that requires the EPC contractor to conduct HSE monitoring, auditing, and reporting. In addition, the EPC contractor needs to report monthly on the QHSE Statistics of the Project, including agreed KPI’s, incident rates, number of training hours, non-conformities, environmental incidents, security issues, labour and working grievances, and compensation claims.

As per the E&S action plan (ESAP #1a), AWPC will formalize the ESHS policy in a language compatible with the Project workforce (Arabic, English, and Chinese), include it in all relevant documents produced for the project, as well as in all required trainings and post a signed copy across the Project site. Similarly, key documentation and training materials will be developed in a language understandable to project personnel, as required for the roles they perform.

Identification of E&S Risks and Impacts

The Project E&S risks and impacts identification comprise of the Amunet Environmental and Social Impact Assessment (ESIA) for the wind farm and the OHTL ESIA, a Stakeholder Engagement Plan (SEP), a Critical Habitat Assessment (CHA) in accordance with PS6, and a Draft Biodiversity Action Plan (BAP), which includes an offset feasibility assessment. Collectively, these documents are considered the E&S disclosure package. Following multiple exchanges and updates during the project E&S appraisal, IFC consider the E&S disclosure package commensurate to the risks and impacts for a wind project of this scale and nature.

The project has completed two separate ESIAs, one for the wind farm project and the other for 220 kV OHTL (the project’s associated facility). The ESIAs were conducted in accordance with IFC PSs and national legislation. In accordance with the national legislation, the wind farm project is classified as environmental Category C (a high-risk project) requiring a detailed Environmental Impact Assessment (EIA) and a public consultation, which was completed and obtained environmental approval from the Egyptian Environmental Affairs Agency (EEAA) up to a tip height of 120 meters. The WTG specification has since changed, increasing the wind turbine tip height from 120m to 180m. As a result, the wind farm ESIA has been updated and resubmitted to EEAA with approval granted on 27 September 2022. AWPC will ensure that other required permits and any conditions therein are in place prior to construction commencing (including EPC and O&M required permits). To this end, as per (ESAP #1b), AWPC will request the EPC to develop a commitment action register and tracking system to ensure all legal requirements together with any permits and approval conditions, as well as any control measures, actions, or recommendations given in the ESIA, the ESDD report, IFC ESAP, corrective actions raised during audits or lender independent monitoring visits, etc. AWPC will monitor compliance and ensure that all actions are tracked and satisfactorily closed out and record and report any noncompliances to lenders

Similarly, prior to mobilization, AWPC together with the EPC will undertake a Pre-Construction Survey (PCS), to fully document the existent conditions of the concession prior to construction of platforms, roads, facilities (offices, sub-station, welfare, etc.,), batch plants, quarries, borrow pits, etc. The PCS will pay particular attention to any pre-existent infrastructure (e.g., abandoned oil wells, roads, existent access tracks, waste dumps, OHTL, etc.,) and any locations where construction will be undertaken and recommend control and clean-up measures required to be implemented.  This will entail American Society for Testing Materials (ASTM) Phase I and II Environmental Site Assessment (ESA) approach or equivalent, for areas suspected of land or groundwater contamination (e.g., at abandoned oil wells).  The PCS will be submitted for lender review once completed and will be used to guide the reinstatement of temporary sites, back to pre-construction conditions (ESAP #1c).

The Project falls within a wider area for wind farm projects development, which is subject to an overarching Strategic and Cumulative Environmental & Social Assessment (SESA) that was produced in 2018 by the international consultants Lahmeyer on behalf of RCREEE and in partnership with several GoE agencies. As set in the SESA and associated environmental approval, the Project requires implementing an ATMP and shut-down on demand (SOD) program during the operations phase. The ATMP and SOD will be primarily implemented by RCREEE, on behalf of AWPC, as with other wind farm projects in the area. The efficacy of the ATMP and SOD implementation for the Project will however remain the project companies responsibility. The ATMP and SOD preparedness and response measures are defined under PS6.

E&S Management System and Programs

As per AWPC ESMS Manual, the EPC is equally required to develop 8 health and safety (H&S) related plans that include site mobilization, an OHS plan, emergency preparedness, hazardous material management, traffic and transportation management, community H&S and influx, training, Covid-19 management and separately a Security Management Plan.

On E&S, 13 related plans need to be developed by the EPC, which include: noise, air quality, soil and groundwater, water, waste (including wastewater), biodiversity, labor and working conditions, gender equality, worker grievances, stakeholder grievances, employment and procurement, worker accommodation, and cultural heritage.

As per (ESAP #1d) AWPC will require time-bound development of the EPC ESMS manual together with all required staffing structures, document control systems, policies, documents, registers, and management plans mentioned above and, will submit them progressively to AWPC. Once AWPC is satisfied that all required documentation meet IFC PS’s, applicable WB EHS guidelines and GIIP, these documents will be submitted for Lender approval, a minimum 60 days prior to construction commencing.

As per (ESAP #1e) AWPC will be required to update their ESMS Manual to reflect the increase of tip height, better align their ESMS Manual with IFC ESMS Implementation Handbook and incorporate Good International Industry Practices (GIIP), as per IFC Good Practice Note on Managing Contractors' Environmental and Social Performance. Similarly, AWPC will incorporate the concept of adaptive management into their updated ESMS, whereby resourcing can be reinforced to overcome any unforeseen challenges.

For the Project’s O&M phase, as per (ESAP #1f), AWPC will develop and implement an Operations Environment & Social Management System (OESMS) and a program acceptable to IFC and consistent with the project ESIA, IFC PSs, and national requirements to: i) define a development and review schedule for the ESHS management plans applicable to the O&M phase (e.g., pollution prevention, water management, hazardous materials, waste management, emergency response, community health, safety and security, environmental monitoring, stakeholder engagement, etc.,); ii) address monitoring, mitigation and reporting requirements associated with preparedness and efficacy of ATMP and SOD implementation such as the provision of communication equipment, staffing, and a third-party auditing role to assess the delivery and responsiveness of the ATMP & SOD; and, iii) address performance management, KPI monitoring and reporting on ESMS supporting plans plus CHA, CEA, and BAP implementation. AWPC will require time-bound development of the OESMS together with all required staffing structures, document control systems, policies, documents, registers, and management plans and, will submit them progressively to AWPC. Once AWPC is satisfied that all required documentation meet IFC PS’s, applicable WB EHS guidelines and GIIP, these documents will be submitted for Lender approval, a minimum of 6 months prior to the commencement of operations.

In relation to the design, construction, and O&M of the OHTL, as per (ESAP #1g) AWPC will engage EETC on the project and ESIA requirements to build and operate the OHTL in compliance with IFC PSs and applicable World Bank Group (WBG) EHS guidelines and good international industry practice (GIIP). Similarly, AWPC will monitor the construction of the OHTL and record and communicate any E&S and OHS risks or issues to EETC, for the observations raised to be rectified.  AWPC will pay particular attention to the procurement (based on advice from a qualified ecologist/ornithologist consultant) and timely installation of the bird divertors.

E&S Organizational Capacity and Competency

AWPC site based team will comprise of a QHSE manager supported by a QHSE officer, a social specialist, and a community liaison officer. AWPC will be remotely supported and guided by AMEA Environmental, Social, and Governance (ESG) manager, for the implementation of the AWPC ESMS.  From the EPC contractor side, the on-site project team will comprise of a qualified Health, Safety, Security, and Environment (HSSE) Director, an H&S Manager supported by a number of H&S Officers, an Environmental Manager supported by a number of Environmental Officers, a Social Manager supported with a Social Specialist and Community Liaison Officers (CLOs), an IFC PS Compliance Advisor (provided by international and national consultants), a Security Manager, and an HSSE Trainer. As required by the tender documents, the EPC contractor and subcontractors will maintain a HSE officer to worker ratio of 1:50 as the Project workforce ramps up.

As per (ESAP #1h) any reduction to AWPC or EPC HSSE organizations, as outlined above and as  presented in Dubai meetings on 27 and 28 July 2022, will require Lender approval and AWPC will reinforce the project organization by: i) requesting the EPC to appoint two full-time qualified human resources (HR)/labor specialists, one fully conversant in Chinese and English and a second fully conversant in Arabic and English; ii) recruiting a full-time translator (conversant in Chinese and Arabic) to support AWPC social specialist; iii) providing corporate support from AMEA HR manager and/or a qualified HR/labor consultant to undertake labor audits and offer advice and guidance to the project; iv) extending the scope of the lender independent E&S consultants to include a labor specialist within their team to participate of the construction and operational phase monitoring visits; v) contracting a nationally recognized wind-wildlife consultancy (through RCREEE) to finalize biodiversity protocols and implement SOD and PCFM; and, vi) recruiting a dedicated and qualified biodiversity manager who will support the QHSE Manager and be responsible for the overall management and reporting of all mitigation and monitoring activities detailed in the construction and operations phase Biodiversity Management Plans (BMP). The latter will ensure that these activities comply with project specific protocols as well as requirements detailed in the CEA and CHA.

EHS Training

The AWPC ESMS Manual requires the EPC contractor (during construction) and O&M contractor (during operation) to administer training program to the project workforce comprising of site induction training, on-job specific training, regular toolbox talks on E&S, emergency response training, and maintaining training records.

Emergency Preparedness and Response

An emergency preparedness and response plan will be developed by the EPC contractor as part of the Project ESMS management plans described earlier (ESAP #1d). The project ESIA and hydrological risk assessment show there is a potential flash flood risk at the Project site. The potential sources of flooding are five main wadis that traverse the site with surface water flooding from the shallow ephemeral channels. The national authorities have constructed three dams to mitigate flash flood risks, after the 2016 floods. As assessed by the hydrological risk assessment and subject to data limitation on flood levels in the five wadi channels, there is now a lower risk of flash floods.

As per (ESAP #1i) AWPC will ensure the EPC undertakes a more detailed analysis based on a 100-year storm event to confirm that the dams provide mitigation to the design storm event and any site drainage is designed accordingly. AWPC will support the EPC to develop a flood management response plan to establish protocols for flash floods. The plan will include setting out measures for the safe evacuation of site operatives and liaising with the authorities to manage risks to the coastal road, with particular attention to establishing safe working procedures between October and May in case of flooding. As part of the flood management response plan, the Project will demonstrate consultation with the respective authorities on the design criteria of the retention basin, resilience to climate change variation, and operating and maintenance regime to ascertain the structural integrity of the three dams and any residual risks.

E&S Monitoring and Reporting

The Project’s ESMS Manual sets out the main requirements for monitoring, inspection, and auditing, both for AWPC and the EPC contractor, and O&M contractor. AWPC ESMS requires the EPC contractor to undertake daily site tours, weekly site inspections, and monthly ESHS reporting with quarterly audits led by AWPC QHSE Manager. The ESMS Manual also specifies communication requirements, which include QHSE weekly meetings with the EPC contractor and subcontractors and monthly meetings to be organized by the AWPC construction manager involving the AWPC, EPC contractor and sub-contractors QHSE teams.

Human Resources and Terms of Employment

AWPC will employ 15 workers for the project during construction which will be over a period of 30 months starting in March 2023. AWPC has recently recruited the QHSE manager. A social specialist and a CLO have been employed in Ras Ghareb since August 2021. The EPC contractor will employ up to 1500 workers during peak construction which will mainly be a combination of local and national workers. Expatriate personnel will be restricted to management and supervisory positions. The breakdown will largely depend on the availability of skills within the local area with priority given to the local communities (including Bedouins and Ras Ghareb City residents). The turbine supplier Envision currently employs 571 workers in Jiangyin Industrial Park, where turbines will be assembled before shipment to Egypt and will support the EPC with the provision of skilled employees, including a project manager, a site manager, 8 people for mechanical installation, 8 people for electrical installation, and 3 people for EHS and logistics. During O&M it is anticipated that the number of personnel required will be approximately 60.

As per (ESAP #2a) AWPC will develop a fit-for-purpose HR management policy and plan for the Amunet project based on AMEA corporate-level HR policies and procedures, national and international labor laws and aligned with IFC PS2. The HR management plan will be contractually binding and cover all project workers including workers directly engaged by AWPC the EPC contractor and the WTG supplier, as well as workers engaged through third-party employers, and supply chain workers. Due consideration will be provided in relation to all topics covered in IFC PS2 in particular contract information; type of employment contracts; ethical recruitment and use of recruitment intermediaries; non-discrimination; discipline; working hours and level of wages; leaves and benefits; sexual harassment, gender-based violence (GBV); freedom of association and the right to collective bargaining; retrenchment; grievance mechanism; forced and child labor; and, life and medical insurance.

Non-discrimination and Equal Opportunity

AWPC already has a corporate policy on gender equality that commits the company to encouraging diversity and inclusion. The policy applies to its own workforce and those of its contractors, suppliers and affected communities, forbidding any form of discrimination, violence or harassment.

As per (ESAP #2b) AWPC will include a commitment to non-discrimination and equal opportunity in its ESMS manual and a requirement for the EPC to include similar provisions related to non-discrimination and equal opportunities in their operations and across their sub-contractors and suppliers, in alignment with IFC PS2.

As per (ESAP #2c) AWPC will require all Project participants to develop and implement a local recruitment process that is transparent, maximizes local employment, provides equal opportunities, is non-discriminatory, prohibits child and forced labor and considers retrenchment. All workers will have signed contracts (no casual workers will be allowed for the construction or operations phase), with the terms and conditions clearly explained to them (in a language they are fully conversant in), including the temporary nature of their jobs, their rights to collective bargaining, the payment structure including any overtime work undertaken, with due consideration to fatigue management. AWPC will ensure that all project workers, including contractors and subcontractors, are informed about their rights to non-discrimination and equal opportunity. All community members, including women and Bedouins, will be allowed and encouraged to apply, and will be evaluated for all the jobs advertised by the project.

Child Labor, Forced Labor, and Supply Chain

As part of its corporate HR policies, AMEA openly commits to not tolerate forced labor and child labor in its operations inclusive of its third-party suppliers, contractors and other business partners. In addition, AWPC ESMS Manual already includes a commitment to not employ workers below the age of 18 years of age or allow forced labor. As per (ESAP#2d) AWPC commissioned a suitably qualified third-party consultant to conduct a labor audit of its EPC and WTG suppliers’ manufacturing and assembly facilities that will be used to supply the WTGs. The consultants did not find any evidence of child labor or forced labor at the sites visited. However, a few labor non-compliances were identified (i.e., large use of dispatched workers1, exceeding local limits for working hours and overtime, delay in payments to resigned workers and a few safety observations). Should the EPC contractor, the WTG Supplier or the O&M contractor use employment agencies or brokers, AWPC will develop an “Employee Agency Procedure” in compliance with Egyptian National Law and PS2 requirements. This procedure will include requirements for vetting and undertaking semi-annual monitoring of licensed employment agencies for the EPC Contractor, WTG Supplier and O&M Contractor and allowing access of all workers to an independent grievance mechanism (ESAP #2e). Any identified non-compliances will be required to be entered into AWPC commitment action register and tracking system (ESAP #1b) and tracked until all noncompliances have been satisfactorily closed out.

AWPC will also need to ensure that the contractual arrangements with the EPC contractor, WTG supplier, subcontractors and supply chain formally reference AMEA’s anti-modern slavery policy, and to develop a robust procedure to monitor the compliance of all contractors, sub-contractors and suppliers with AMEA HR policies, AWPC HR Management Plan and ESMS Manual, IFC PS2, and all other statutory requirements, in particular around child labor and forced labor as per (ESAP #2f).

AWPC will also be required to adopt a robust supplier mapping, verification and traceability program as part of its supply chain management system. Supply chain management requirements will be incorporated in the procurement policy and processes for the project and will require the adoption of the supplier code of conduct that clearly includes the prohibition of child and forced labor in all purchasing procedures (ESAP #2g). AWPC will be required to monitor for compliance with its supply chain program by undertaking document review, spot checks and carrying out worker interviews throughout construction and operations and during AWPC quarterly led audits, and indirectly by ensuring that the EPC contractor and WTG supplier take clear commitments against child labor and forced labor in their own operations and supply chain, providing explicit reference to it in all their contractual arrangements, and adopting similar procedure to monitor the compliance of their own contractors and suppliers.

Grievance Mechanism

As per (ESAP #2h) AWPC will develop a formal worker grievance redress mechanism (GRM) and associated procedure in alignment with PS2. The worker GRM will clearly outline AWPC and the EPC contractor’s role and responsibilities towards the implementation of the GRM including raising grievances, resolution process, a non-retaliation policy, induction training, and regular refresher training. The GRM will be made available to all project workers (including third-party workers), irrespective of their employer and employment status, and will be communicated to the workforce (in a language the workers understand). The GRM will include specific considerations related to harassment and gender-based violence and will allow for the submission of anonymous complaints guaranteeing confidentiality and allowing for multiple entry points to raise and address allegations based on the preference of the complainant. The GRM procedure will also outline an escalation mechanism for unresolved or disputed grievances. Similarly, AWPC will develop a protocol within their GRM to deal with any OHTL related grievances, request, etc. This protocol will describe how AWPC will relay any OHTL related grievances, request etc., to EETC and will support EETC on a timely response and resolution to the extent possible.

Worker Accommodation

Given on-site worker accommodation facilities are not legally permitted within the Project concession, all workers and staff will be accommodated within the nearby urban settlements. It is anticipated that the vast majority will be accommodated within Ras Ghareb due to its vicinity to the project work site. Expected impacts of non-local worker influx into the Ras Ghareb community include i) increased pressure on local resources, infrastructure and social services; ii) increased social pathologies such as drug and alcohol abuse; iii) GBVH; and iv) increased incidence of communicable diseases. AWPC will require the EPC to develop a worker accommodation plan (in line with IFC/EBRD Guidance Note on Workers Accommodation) and a community health and safety and worker influx plan as set forth in (ESAP #1d) to address above mentioned expected impacts. As per (ESAP #2i) AWPC will ensure that that the EPC assess and mitigate the risks and impacts in relation to worker accommodation inclusive of Covid-19 control measures, accommodation suitability, and life and fire safety (e.g., emergency exits, smoke and CO2 detectors, etc.,). AWPC will also undertake an audit of the project-provided worker accommodation facilities prior to occupancy, followed by quarterly audits thereafter.

Occupational Health and Safety

AWPC has a health and safety policy with a commitment to protect the workforce, assess the risks related to operations, comply with WBG General EHS guidelines and WBG EHS guidelines for wind farms. As set forth in (ESAP #1d), the EPC is required to develop an OHS plan based on a construction OHS risk assessment, a traffic and transportation plan that will be based on a route risk assessment (with particular focus on the transportation of the WTG’s and associated components which will require close coordination with the civil authorities), and a Covid-19 management plan prior to the commencement of any work. As per (ESAP #2j) AWPC will ensure that the construction phase OHS plan, traffic and transportation plan, and Covid-19 management plan are developed in alignment with IFC PSs and national requirements and are commensurate with industry risk, GIIP and include relevant risk assessments and procedures for project activities such as (not an exhaustive list): working at heights, lifting operation, energy isolation, confined space, defensive driver training, prohibition and monitoring for drug and alcohol use, in vehicle monitoring systems (IVMS), no night driving policy, journey management, provision of fit for purpose PPE, job safety analyses, toolbox talks, incident reporting, and a robust permit to work system. The requirements defined within these documents will apply to all project workers, including subcontractors. All workers will complete basic OHS training, and supervisory staff and employees undertaking high-risk activities will complete specific OHS training.

Operations and maintenance work will generally be undertaken by trained technicians engaged by the turbine supplier familiar with the turbines, and specific OHS risks involved with their operation. Similarly, the O&M contractor will develop a site-specific OHS plan (based on an O&M OHS risk assessment) for the operations phase. The O&M OHS management plans will incorporate the requirements from the ESIA, the ESMS manual, and the QHSE Employment requirements and will be aligned with IFC PSs, GIIP, and national requirements and clearly allocate roles and responsibilities for the implementation and monitoring of the plan (ESAP #2k).

The EPC will hire an onsite medical doctor and provide a dedicated and equipped ambulance as per national legal requirements for projects exceeding 200 workers. Other life and fire safety related equipment will include fire extinguishers, first aid kits, smoke and CO2 detectors, and an effective communication system across the site as included in the ERP (ESAP #2l).

Workers Engaged by Third Parties

The bulk of the project workforce will consist of contractor and subcontractor workers. As set forth in (ESAP #2a) AWPC will develop an HR management plan and the EPC a Contractor Management Plan (ESAP #1d) defining their approach to managing the EHS performance of their contractors, subcontractors, and other third parties during the various phases of the project. The Contractor Management Plan will be consistent with the general principles described within IFC Good Practice Note: Managing Contractors' Environmental and Social Performance (ESAP #2m). The use of recruitment agencies, labor brokers and/or outsourced service contractors will be required to follow the guidance of the HR management plan and supply chain provisions as set forth in (ESAP #2a/b/c/e).

The EPC contractor will prepare a demobilization plan to be part of the project ESMS before the demobilization stage of the construction phase and at decommissioning in alignment with IFC PS2, GIIP, and the national labor law (ESAP #2n).

Greenhouse Gases

The project is estimated to generate approximately 2,300 GWh per year based on the P90 (90% probability of exceedance) energy yield assessment, with greenhouse gas emission reductions of approximately 1,108,600 tCO2 equivalents per year using a grid emission factor of 482 gCO2e/kWh.

Resource Efficiency (water)

As per the ESIA, the Project will require approximately 80,000 m3 of water in the first 28 months of the construction phase, equivalent to around 75 m3/day.  Approximately 75% will be needed for construction such as mixing cement and dust suppression, and the remaining 25% for welfare needs. A consultation was undertaken with the Ras Ghareb Water and Wastewater Company, which stated that the required quantities are unlikely to entail any constraints to the existing users and water can be supplied via water trucks. As part of the Project ESMS Manual (ESAP #1d), the EPC contractor is required to develop a water management plan prior to construction, which will include identification of sources of water supply, confirmation that the water quantities used will not create an impact on existent users, anticipated quantities, procedures for onsite management of water supply, minimization of water consumption, etc. During the Project’s operation phase, water needs are considered to be negligible. In the unlikely event that groundwater will be required AWPC will request the EPC to undertake a hydrogeological assessment to ensure the abstraction rates are sustainable prior to any use of groundwater (ESAP #3a).

Air emissions and Noise

Construction activities will result in an increased level of dust and noise from equipment and machinery, which are anticipated to be readily mitigated through the implementation of standard pollution prevention and control measures defined within the Project ESMS Manual. Further, as concluded from the Project ESIA, impact related to air and noise emissions, visual intrusion, and to potential shadow flicker are of minor significance due to the lack of nearby sensitive receptors and distance (9 km) from the nearest community receptors, Ras Ghareb city.

Waste Management

Volumes of solid, liquid, and hazardous waste generated by the project during the construction and operation phase are expected to be low. Solid wastes for the construction phase are anticipated to comprise construction wastes (rock, soils, etc.), packaging materials (e.g., plastics, wooden pallets), and general municipal waste (food waste, recyclables, etc.). Liquid waste anticipated to be generated during the construction phase is mainly wastewater from toilets and sanitation facilities. Hazardous waste for the construction phase is anticipated to be contaminated soils, empty containers of paints/coating material, used oil, etc. Waste generated during the operational phase would be much lower but similar to those for the construction phase and will mainly be associated with site maintenance activities.

Solid waste (hazardous and non-hazardous) and domestic wastewater will be securely stored on site and regularly removed by authorized contractors at a licensed treatment, recycling, and/or disposal facilities. In accordance with PS3. As informed by the ESDD process, the closest suitable solid waste, wastewater, and hazardous waste treatment and disposal facilities are located in Hurghada city, Rash Ghareb city, and Alexandria or Helwan city respectively. As set forth in (ESAP #1d), the EPC will develop a waste management plan that includes the identification of waste disposal facilities for the waste streams generated by the construction and operation phase. As per (ESAP #3b) AWPC will ensure the EPC secure an agreement with the identified disposal facilities after undertaking a due diligence assessment to demonstrate the respective selected facilities are in alignment with PS3, WBG applicable EHS Guidelines, and national requirements, and implement a chain of custody mechanism.

Community Health and Safety

Workers will be accommodated in the surrounding cities.  The EPC contractor will develop a Community Health and Safety and Labor influx management plan as set forth in (ESAP # 1d) to manage health, safety and social-related risks such as i) increased pressure on local infrastructure and social services; and ii) increased social pathologies such as drug and alcohol abuse; iii) GBVH; iv) increased incidence of communicable diseases (STDs, Covid-19); and v) provisions for periodical monitoring of social related effects of the influx of migrants.  This plan shall include an assessment of worker influx at a cumulative level, given other development projects within the project area.

The main road traffic risk associated with the project is related to the transport of the turbines, blades, and wind tower components (abnormal loads) to the site, transport of aggregate, concrete, water, and the daily commute of project personnel. As set forth in (ESAP #2j) applicable control measures to protect local community members from road traffic accidents, in line with GIIPs will be undertaken by all project personnel. In addition to the transportation of goods to the project worksite and given the significant number of workers that will be required to be transported to the site on a daily basis, AWPC will request the EPC to provide transportation to the workforce so as to reduce the risk of collisions with third party vehicles (ESAP #4a).  As per (ESAP #2j) the project will use in-vehicle monitoring systems to monitor drivers’ behaviors and speed limits, for all project-assigned vehicles.

Security Personnel

The project EPC Contractor will hire a private security provider to provide access control, asset, and personnel protection. The number of security guards required to be engaged is yet to be confirmed. As part of the ESMS (ESAP 1#c), AWPC will develop and implement a Security Management Plan (SMP) aligned with IFC PS4 and the Voluntary Principles of Security & Human Rights. The plan will include a Code of Conduct for site security personnel, a security risk assessment including an understanding of the security context within the area of influence based on recent findings from stakeholder engagement activities, as well as incident reporting, and an investigation process. The EPC will ensure that reasonable inquiries are taken to ensure private security personnel are not implicated in past crimes/abuses and are appropriately trained. In alignment with its security policy, AWPC will ensure the EPC contractor develops the security management plan (SMP) to the satisfaction of IFC including the identification of numbers of security guards, fencing, closed-circuit television CCTV cameras, suitable welfare facilities, patrol cars, access control measures, management of security forces, incident response procedure, training plans including induction, formal training, and toolbox talks. This plan will be based on an updated security risk assessment that considers the specific security risks associated with the project area. AWPC will monitor the implementation of this management plan by the EPC & O&M contractors via regular audits. (ESAP #4b)

The project is situated in the Red Sea Coastal Desert ecoregion. The area is characterized by flat or gently sloping compacted gravel desert cut by shallow drainage channels (wadis). Vegetation is sparse and restricted to the wadis. The project overlaps by less than 1km2 with the north edge of the Gebel El Zeit Important Bird and Biodiversity Area (IBA), which is also a Key Biodiversity Area (KBA). The Gebel El Zeit IBA/KBA is situated within the Rift Valley / Red Sea flyway, a globally important migration corridor for migratory soaring birds (MSBs), particularly storks and raptors, and is located where large numbers of birds are funneled along the Gulf of Suez during their spring and autumn migration, often landing in large numbers and flying at low altitudes.

A Critical Habitat Assessment (CHA) determined that the project was within Critical Habitat for five MSB species: Steppe Eagle (IUCN Red List – Endangered), Levant Sparrowhawk (IUCN Red List –  Least Concern), Black Stork (IUCN Red List – Least Concern), Great White Pelican (IUCN Red List – Least Concern),  and White Stork (IUCN Red List – Least Concern). These species will be subject to net gain requirements. Birdlife International representative for Egypt was consulted as part of this Project appraisal regarding the Gebel El Zeit IBA. Although the CHA assessed the Gebel El Zeit IBA/KBA as Critical Habitat, available bird data indicated that the small overlap with the IBA (less than 1 km2) is not used as a stopover/resting site and is distant from the main areas where birds concentrate within the IBA.

A draft Cumulative Effects Assessment (CEA) utilizing bird flight activity data collected across five migration seasons 2020/2022 was used to systematically screen for species at highest risk from project related activities. The CEA identified 10 species populations where the potential for impacts from turbine collision mortality was moderate or high (‘priority biodiversity values’). These included all five species identifying the project within Critical Habitat plus five others: Egyptian Vulture (IUCN Red List – Endangered), Greater Spotted Eagle (IUCN Red List – Vulnerable), Pallid Harrier (IUCN Red List – Near Threatened), Booted Eagle (IUCN Red List – Least Concern) and Common Crane (IUCN Red List – Least Concern). All 10 species belong to the group of MSBs for which the Gebel El Zeit IBA is designated. The five additional priority biodiversity values will be subject to IFC Natural Habitat no net loss (NNL) requirements. The ESIA concluded a low likelihood of bat activity at the project. Priority value for bats will be determined in the finalized version of the CEA. Additionally, the Egyptian Spiny-tailed Lizard is regarded as a priority biodiversity value and will be subject to IFC Natural Habitat no net loss (NNL) requirements.

The project will implement a comprehensive program to avoid and minimize risks. Concerning the integrity of the Gebel El Zeit KBA/IBA, no WTGs or project activities will be located or take place in the area that overlaps with IBA/KBA (ESAP #5a).

As per (ESAP #5b) AWPC will develop and implement a Construction Phase BMP that will include an approach for installing appropriate bird diverters to the 2 km length of the Overhead Transmission Line (OHTL) associated with the project. The design and configuration of diverters used will be based on advice from a qualified consultant (ecologist/ornithologist) with experience in mitigating OHTL bird collision risk for the priority biodiversity values likely to be impacted. The construction phase BMP will also include measures to ensure that all reinstatement of areas around turbines and under OHTL are completed, prior to the operational phase (or outside bird migration seasons) to avoid interfering with bird fatality monitoring activities. The BMP will include a preconstruction survey to identify activity associated with Egyptian Spiny-tailed Lizard and will recommend any associated avoidance and minimization measures relevant to these species.

With respect to the operations phase, as per (ESAP#5c) the project will contract a nationally recognized wind-wildlife consultancy to finalize a Cumulative Effects Assessment (CEA);  finalize, implement, and manage a Post Construction Fatality Monitoring (PCFM) program for turbines and the OHTL, and a radar-assisted turbine shutdown on-demand program (SOD), and develop and finalize an operations phase BMP. The PCFM and SOD programs will be conducted by staff trained at the Migratory Soaring Birds Center of Excellence in Ras Ghareb, or otherwise qualified/experienced to conduct these types of monitoring and mitigation activities for MSBs in the Gulf of Suez. The programs will be carried out for the operational life of the project with semi-annual reporting following a standardized template. The BMP will include: i) confirmation of priority biodiversity values ii) biologically derived fatality thresholds for priority birds iii) an adaptive management framework iv) protocols for PCFM and SOD programs and all other onsite operational phase monitoring and mitigation activities. It will also include a semi-annual reporting template for centralized reporting of all bird and bat monitoring, mitigation, and documenting of adaptive management. The operations phase BMP and accompanying protocols (including the PCFM and SOD programs) will be subject to a strategic review after a 2.5-year period and a 4.5-year period as other types of mitigation, might be required informed by the results of fatality monitoring and the adaptive management framework.

With respect to the five Critical Habitat bird species, as indicated in (ESAP #5c), the project will develop and finalize a fit-for-purpose Biodiversity Action Plan (BAP) and Biodiversity Monitoring and Evaluation Plan.  The BAP will include a loss/gain assessment informed by the pre-construction surveys. It will also include details of viable offsets to achieve net gains for Critical Habitat bird species and additional conservation actions to achieve no net loss for the other priority biodiversity values identified in the CEA. AWPC will contract a qualified expert with international experience on offsets to develop and finalize the offset plan. As per (ESAP #5d), AWPC will select from the list of viable offsets that it agrees to finance, which together will achieve net gain and no net loss goals for the operational life of the wind farm. IFC will approve the offsets and their associated budgets.

The project will be required to contract an ecological consultancy to implement SOD and PCFM through RCREEE as part of RCREEs Gulf of Suez bird safeguarding program for wind energy. To fulfil the interrelated biodiversity requirements for the project and RCREEE, as well as to coordinate and manage multiple biodiversity risks and interrelated monitoring and mitigation measures, AWPC will contract/assign a dedicated biodiversity manager as set forth in (ESAP #1h) who will be responsible for the overall management and reporting of all mitigation and monitoring activities detailed in the construction and operations phase BMPs. The manager will ensure that these activities comply with project-specific protocols as well as requirements detailed in the Cumulative Effects and Critical Habitat assessments.

AWPC has a Communication, Participation and Consultation Procedure as part of their Integrated Management System (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.

The communities near the project site are Ras Ghareb City (9km away) and Zaafarana Village (65 Km away). AWPC recognizes that stakeholder engagement is key to the implementation of the environmental and social management plans. AWPC has developed and implemented a Stakeholder Engagement Plan (SEP) during the early stages of project development. The plan includes an initial analysis of key stakeholder groups and outlines early stakeholder engagement activities and provides a summary of the engagements and commitments made.

AWPC and EPC will update the SEP to address key risks and impacts of the construction and operations phases and will update regularly as the project advances. The Stakeholder Engagement Plan implementation will be the responsibility of AWPC with a dedicated and qualified Community Liaison Officer to manage the day-to-day interaction with stakeholders including the local community, manage the grievance mechanism, follow up on local community grievances and monitor and report on the implementation of community support initiatives. The project SEP was developed initially by the AWPC project team and will be updated prior to the start of project construction. The project company and EPC contractor will collaborate to implement the SEP, which will be updated regularly to reflect any changes in the project context (ESAP #6a).

Community Grievance Mechanism

AWPC SEP includes a community grievance mechanism to be accessed by community members and stakeholders in case of comments, questions, and complaints in alignment with IFC PS1. The EPC contractor will appoint a social specialist to serve as the interface between the EPC Contractor and AWPC on the one hand; and a CLO to coordinate with AWPC CLO on all EPC activities that could impact local communities, manage community complaints and ensure they are addressed as per the IFC PS1 guidelines (i.e., in a timely manner, allowing for confidentiality, non-retaliation, and impartiality). The community grievance procedure including its principles and timeline will continue to be clearly communicated online and through the stakeholder engagement activities and will allow for all types of complaints including those related to gender-based violence and harassment (GBVH), gender-based discrimination and those grievances related to local recruitment. Similarly, the community grievance mechanism will be available for members of the community or employees in the event of a violation by security personnel or any other grievance related to security personnel. These measures will be communicated as per the Stakeholder Engagement Plan (SEP).

Contact Person: Vito Saluto

Company name: AMEA Power LLC 

Company Address: Marina Plaza Offices, Level 33, Dubai Marina, PO Box 37669

Dubai, United Arab Emirates

Mobile: +971 52 104 22 93 

Website: www.ameapower.com