IFC’s appraisal considered the environmental and social management planning process and documentation for the Project and gaps, if any, between these and IFC’s requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable period of time, are summarized in the paragraphs that follow and (if applicable) in an agreed Environmental and Social Action Plan (ESAP). Through implementation of these measures, the Project is expected to be designed and operated in accordance with Performance Standards objectives.
PS1: Assessment and Management of Environmental and Social Risks and Impacts
Damietta Alliance Container Terminal SAE is a newly formed company. As per ESAP #1, the company will develop E&S policies and an ESMS in line with IFC PS and local requirements. The E&S policies will include (i) an environmental policy; (ii) a health and safety policy; (iii) a social policy; and (iv) a code of conduct. The company will communicate the content of the above policies and code of conduct to its employees, contractors, service providers, and display them throughout CT-II. The ESMS will include (i) procedures for the identification and management of Environmental, Health, Safety, and Social (“EHSS”) 3 risks and impacts; (ii) an organizational EHSS structure including training and competency; (iii) emergency preparedness and response (iv) monitoring, auditing, and review mechanisms; (v) regulatory, permits and action tracking register; (vi) stakeholder engagement; and (vii) a community grievance mechanism. As per ESAP #2, the company will develop subject-specific E&S Management Plans (ESMPs) in line with IFC PS and relevant WBG EHS Guidelines. For the operations phase, the company will update their ESMS and develop the required standard operating procedures and work instructions as per IFC PS (ESAP#3).
An Environmental Impact Assessment (“EIA”) was completed for the project in 2006 and approved by the Egyptian Environmental Affairs Agency (“EEAA”). In March 2019, the EEAA confirmed that the environmental approval No. 1457, granted on 22 April 2007 remains valid and requested for the 2006 EIA to be supplemented with an EIA for the dredging and maintenance works for CT-II. This updated EIA was undertaken in 2021 and approved by EEAA in April 2022.
In the event that CT-II builds a rail track connection, it will need to undertake an E&S assessment and implement mitigation measures as per the ESMS and IFC PS (ESAP #4).
No commercial fishing is undertaken within the port area but the disposal of excavated and dredging material has the potential to impact fishing communities. The company will assign a qualified third-party consultant to assess the potential risks and impacts to the fishing stocks and recommend the required control measures, in line with the IFC PSs, and commensurate with the project risk and impacts (ESAP #5).
As part of its ESMS, the company will develop and implement a Contractor Environmental and Social Management and Monitoring Plan (“CESMMP”) that will build upon the contractor clauses included into the contractor tendering documentation and outline contractor EHSS responsibilities. The CESMMP will include explicit requirements to comply with legal requirements, the 2021 EIA, the 2022 EIA approval permit conditions, IFC PSs, WBG General EHS Guidelines, EHS Guidelines for Ports, Harbors, and Terminals, all relevant company policies, code of conduct, and management and monitoring programs (e.g., ESMPs). The CESMMP will also outline contractors' EHSS organizational capacity and required trainings.
The CESMMP will similarly include all OHS requirements to be followed by contractors (ESAP #6). The company will appoint a suitably qualified EHSS manager, supported by health and safety, environmental, community liaison, and labor officers. A similar EHSS structure will be put in place by the engineering design and construction supervision consultant, as well as by the main contractors (and subcontractors as relevant), to adequately support the ESMS implementation (ESAP #7).
The company will develop EHSS monitoring, auditing, and reporting requirements including Key Performance Indicators (“KPIs”) to assess overall EHSS compliance and performance. This will include (i) daily/weekly inspection activities; (ii) monthly EHSS performance reports with OHS leading and lagging indicators (e.g., inspections, training, lost time injuries, incidents, etc.), social and labor performance (e.g., external and internal grievances, terminations, overtime, strikes, etc.), environmental performance (e.g., water, energy, waste, etc.), non-compliances and corrective actions; and (iii) stand-alone internal and third party audits (ESAP #8).
PS2: Labor and Working Conditions
The workforce required for the construction phase is estimated to be up to a maximum of 2500 workers. For the operations phase, the number of workers are estimated to be between 800-1100 employees. The company will provide a manpower plan as part of the HR Management Plan for the construction and operation phase.
The company will develop project-specific Human Resource (“HR”) plans and procedures for the construction and operation phases aligned with national and IFC PS2 requirements, and include (i) nondiscrimination and equal opportunity; (ii) prevention of child and forced labor; (iii) worker representation; (iv) contractor monitoring; (v) a formal worker grievance mechanism; (vi) worker code of conduct; (vii) gender aspects and Gender Based Violence (“GBV”); and (viii) provision of contracts clarifying working conditions (such as working hours, overtime payments, assigned leave, and life and medical insurance). The HR plans and procedures will be communicated transparently and effectively to all the company and contractor workers, including direct and indirect workers and third-party employees. The company will contractually require contractors and subcontractors to align their HR plans and procedures, with the company HR plans and procedures (ESAP #9).
The company will hire a qualified HR manager to effectively implement the company HR policies, plans, and procedures, in line with national and IFC PS2 requirements (ESAP #10). Should the company, contractors, or subcontractors require worker accommodation during the construction or operations phases, whether within or outside the port, the accommodation will be in line with the IFC/EBRD Guidance Note on Workers Accommodation (ESAP #11). As part of the ESMPs, an accommodation and a worker influx management plan will be developed and implemented. These plans will require the company to assess and mitigate any risks and impacts in relation to worker influx and worker accommodation, which will be regularly monitored and audited by the company as per ESAP #2 and #8.
The company will develop a formal Worker Grievance Redress Mechanism (“WGRM”) and associated procedures, including for gender-based violence and harassment (GBVH), for the construction and operations phases of the project, in line with PS2 requirements. The WGRM will outline the company and contractor’s roles and responsibilities towards the implementation of the WGRM including raising grievances, resolutions process, a clear non-retaliation policy, training, sensitization, and a clear resolution timeline. The WGRM will be made available to all project workers irrespective of their employment status, and will be communicated effectively to the entire workforce through induction, toolbox talks, and other sensitization mechanisms. The WGRM will allow for the submission of anonymous complaints to guarantee confidentiality (ESAP #12).
The company will prepare an OHS Management System that will include the necessary control procedures to mitigate relevant OHS risks in line with local regulations, WBG General EHS Guidelines, and WBG EHS Guidelines for Ports, Harbors and Terminals (ESAP #13). Similarly, the company will communicate the requirements of their OHS plan to all project workers (inclusive of contractors, sub-contractors, and suppliers). Construction contractors will be required to develop their own OHS implementation plans, as part of their CESMMP, including training, monitoring and reporting requirements as per ESAP #6 and #8. An OHS committee comprised of managers, supervisors, and workers will meet regularly and oversee the implementation of the OHS management plan.
PS3: Resource Efficiency and Pollution Prevention
Electricity will be supplied from the national grid and water from the municipality network. Water will be for general and sanitary uses, fire water, and irrigation of landscaped areas. All STS cranes will be electrical and the RTGs will have both electrical and diesel engines. To align with efficient and effective resource use, the company will monitor fuel and water consumption, and define measures to improve efficiency during the operation phase (e.g., maximize use of electrical RTG’s). Similarly, the company will consider the use of energy efficient certified buildings (ESAP #14).
Land excavation and dredging are ongoing by DPA for the new container terminal. The materials are being disposed of along the shoreline, adjacent to the east and west breakwaters, built by DPA to protect the port entrance. The excavation, dredging, and its disposal constitute associated facilities as per IFC PS1 and are expected to result in circa 5 million m3 of materials requiring disposal. To address potential risks and impacts at the disposal sites, a land and groundwater contamination survey was undertaken, which found only a few marginal exceedances that are not considered to pose risk to human health or the marine environment. As per, ESAP #15 the results will be documented in a Contamination Impact Assessment Report.
The project will be designed so that no stormwater drains and/or wastewater, discharge directly into surface waters during CT-II operations. Oil/water separators and sewage treatment plants will be used and maintained in good working condition, to avoid oily water and/or untreated sewage from being discharged into the environment. As part of the project’s environmental permit requirements and GIIP, the company will undertake regular monitoring of the maritime life and coastline water quality, and implement measures as required in line with the PSs and WBG EHS Guidelines (ESAP #16). The project itself is not expected to result in any negative coastal impacts.
The construction of CT-II will result in temporary air and noise emissions including particulate matter,
emissions from construction equipment, stormwater and sewage discharges, and elevated noise levels. As part of the CESMMP (refer to ESAP #6 above), the company will contractually require their contractors to place environmental controls and mitigation measures for air quality, noise, and effluent emissions in line with IFC PSs, and applicable WBG EHS Guidelines. Such mitigation measures include the use of water to control dust, the use of covers by trucks, and noise dampening, among others. To confirm the effectiveness of these control measures, the company will implement an air, noise and effluent discharge monitoring program, at a minimum monthly during construction (ESAP #17).
While no significant impact on ambient conditions is expected on account of the project operations, the company will continue to implement procedures so that (i) all equipment operated by CT-II are properly maintained and their emissions are within national standards and WBG General EHS Guideline values; (ii) trucks entering the terminal premises have appropriate pollution control certificates; and (iii) truck dwell time (particularly engine idling time) is minimized. As part of their operations ESMMP (refer to ESAP #3) the company will put in place procedures to address that refrigeration gases used in the reefers to verify they meet national ozone-depleting substances rules requirements under the Montreal Protocol.
The project will not handle or manage any wastes or fuel recharges for the vessels docking at the terminal. The waste generated by CT-II will mainly be non-hazardous with limited quantities of hazardous waste from the operation and maintenance activities. It is anticipated that the wastewater generated will be collected and supplied to an existing wastewater treatment plant at the port. As part of the ESMS development (refer to ESAP #1 and #2) the company will develop and implement a Solid and Liquid Waste Management Plan, which will include using authorized waste contractors, and undertaking a due diligence assessment of all final waste disposal sites, to verify they are licensed and operated in line with WBG EHS Guidelines.
Climate change-related risks include sea level rise (sea level is expected to rise between 0.2 and 0.25 meters by 2050 and between 0.42 and 0.62 meters by 2100.) Agitation represents a minor threat with less than a 5% change from current levels. The terminal design incorporates 1 meter of additional height in the quay wall, which would build resilience against the rise of sea level and agitation due to climate change. The project’s annual greenhouse gas (GHG) emissions for scope 1 and scope 2 are estimated to be 46,200 tons of CO2eq. The project’s emissions are about 3,400 tons of CO2eq less than the baseline (49,600 tons of CO2eq) owing to the use of e-RTGs and solar PV. As the project is expected to produce more than 25,000 tons of CO2eq per annum, the company will report annually GHG emissions based on internationally recognized methods to the IFC.
PS4: Community Health, Safety and Security
Sensitive receptors were identified within a radius of 500m to 1km of the Damietta port consisting of villages and residential households starting from Izbet Nasralla (20m from the southern port perimeter), Izbet Khamesa (115m from the western perimeter) and some small independent residential and farm-houses scattered around the port. Other larger villages are located beyond a 1km distance from the port. CT-II activities that are likely to affect the surrounding community and transport routes in the area, include the movement of vehicles in and out of the terminal leading to increased safety risks for pedestrians and road users. A Traffic Impact Assessment and Management Plan will be undertaken by the company, including route risk assessments, to minimize impacts to the local surrounding communities (ESAP #18).
The existing terminal has a robust security system in place. For the project operations, the company will implement its own security system through a service provider. Prior to the operations phase, the company will develop a Security Management Plan, based on a security risk assessment, in alignment with IFC PS4 and IFC Good Practice Handbook on Use of Security Forces: Assessing and Managing Risks and Impacts (ESAP #19).
