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
The Company has in place an ESMS appropriate to the nature and scope of this project and is mostly consistent with IFC Performance Standards (PS). Limited gaps and proposed mitigants are discussed in the sections below. The Company has developed and will operate each existing and future mini-grid sites, in line with this ESMS.
Policy: The Company has a documented set of E&S policies with commitments to comply with Nigerian legal requirements, IFC Performance Standards and WBG Group EHS Guidelines, as well as the relevant international conventions and treaties to which Nigeria is party.
Identification of Risks & Impacts and Management Programs: The ESMS has a defined risk management workflow that includes an E&S site screening process using an Exclusion List and a comprehensive E&S screening checklist. Based on the findings each site is given an E&S risk categorization. The ESMS states that the Company will only develop sites defined as Category II, i.e., medium to low-risk sites such as those that are not in located ecologically sensitive habitats, with no physical and limited economic displacement, or do not have substantive number of migrant workers stationed in communities. To manage E&S risks and impacts associated with the construction and operations phases of the mini-grids, the Company applies a common Environment and Social Management Plan (ESMP), developed from an Environment and Social Assessment of a typical mini-grid. The ESMP is supported by several associated “sub” plans including emergency preparedness and response; health and safety; and waste management. Environmental and construction permits are obtained in batches for several sites prior to the start of the construction activities. Going forward, the Company shall review the E&S risks and impacts associated with the Project construction and operations and update E&S risk register and ESMP in line with PS 1 requirements and WBG General and Electric Power Transmission and Distribution EHS Guidelines. The ESMP will be adapted to any site-specific issues identified following the E&S site screening. (ESAP # 1).
Organizational Capacity: The HPS has a corporate level Sustainability lead based in India. At Husk Nigeria, E&S responsibility is vested across all employees within the Company, led by Country Manager and supported by an E&S Officer. Each site (or site cluster) also has site technicians and up to two site watchmen. The Company will recruit an additional E&S Officer for every 50 new mini-grid sites being developed. Going forward, upon the development of 50 mini-grid sites, the Company will review its E&S performance to date against E&S organizational capacity and recruit additional E&S resources as needed to support the safe roll out of its investment plan. (ESAP # 2).
Emergency Preparedness and Response: The Company has adopted the HPS Emergency Preparedness and Response Plan (EPRP) for hybrid mini-grid plants. In addition, site specific EPRPs are prepared for each of the project sites in Nigeria. The EPRPs cover all relevant emergency situations (e.g., fire, electrocution, collapse of structures, storms, lightening, etc.) and include emergency response contact numbers. Site observations confirmed that EPRPs are implemented at the project sites visited, through the identification and marking of emergency assembly/ muster points, and installation and regular servicing of fire extinguishers per the relevant recommendations, and placement of a first aid box at each site.
Monitoring & Review: The Company has a self-monitoring checklist to monitor the implementation of the ESMP, however it lacks key monitoring parameters that allows for consistent and adequate monitoring of each mini-grid. Going forward, the Company will update the ESMS with an E&S monitoring and reporting plan and associated Key E&S Performance Indicators (KPIs) to assess the effectiveness of the mitigation measures employed. (ESAP # 3).
Supply Chain: HPS has a dedicated procurement team based in India responsible for all global procurement and procures solar panels, batteries, and associated equipment from ‘Tier 1’ suppliers. To support this. HPS has a supply chain Code of Conduct prohibiting forced labor together with EHS requirements, as well as a supplier registration / evaluation sheet that includes labor and HSE provisions. The Code of Conduct is annexed to all supplier contracts. In addition, the contracts require the supplier to contractually commit to E&S policies that are consistent with core international standards and confirm compliance with national and international laws and regulations.
PS2: Labor and Working Conditions
Husk Nigeria currently employs around 80 staff at the Company headquarters in Abuja and at each operational mini-grid site. This figure is expected to grow as the Company rolls out its investment plan. Furthermore, up to 8 locally sourced workers are employed for the duration of each mini-grid construction. The Company has a HR officer based in Abuja supported by the HPS HR Director based in India.
The Company is in the process of updating its HR manual to include policy statements on freedom of association and collective bargaining, forced labor, child labour, non-discrimination and equal opportunity and Sexual Harassment, and procedures on recruitment, performance management, discipline, and key working terms and conditions. Whilst each worker irrespective of the duration of employment receives a written contract, not all the minimum employment rights prescribed by Nigerian law are referenced (e.g., minimum wage, frequency of payment of wages, any terms and conditions related to working hours, etc.). Whilst Husk Nigeria has a documented Labor Grievance Mechanism (LGM) place it currently lacks provision for anonymous reporting of grievances and a documented option for access to other judicial or administrative remedies for cases where raised complaints cannot be internally resolved. Going forward, the Company will 1) complete the update of the HR manual to align with Nigerian labor law, IFC PS 2 and DARES requirements; 2) develop a Minimum Wage Policy applicable to all workers regardless of employment status; 3) update the Employment Contracts to align with Nigerian labor law; and 4) update the LGM to align with PS2 requirements. (ESAP # 4)
Occupational Health and Safety: Husk Nigeria has a Health, Safety, Security and Environment (HSSE) Handbook that defined its commitments to providing a safe and healthy work environment for its employees and the public. The handbook outlines the key risks and hazards associated with the Company’s activities, defines a basic risk assessment that should be carried out by employees prior to undertaking an activity, and provides safety rules/ instructions covering a range of activities including loading and unloading, manual lifting, welding, and cutting, electrical safety, hot work, working at height, housekeeping, Personal Protective Equipment (PPE), and incident reporting. At the construction sites, OHS training forms part of the employee formal induction that is conducted prior to the start of the construction activities and supplemented by regular toolbox talks. It is mandatory for all construction workers at construction sites to attend employee induction trainings as well as subsequent toolbox talks. Going forward, the Company will update the HSSE Handbook to strengthen the risk management including training and oversight related to electrical safety and installation of the low voltage T&D network in line with WBG General and Electric Power Transmission and Distribution EHS Guidelines. (ESAP # 5).
Workers Engaged by Third Parties: To support the timely roll out of its investment plan, Husk Nigeria plans to engage contractors for several activities, such as transmission line installation, and transportation services. Going forward, the Company will develop a Contractor Management Procedure which includes E&S procurement criteria, contract provisions to comply with Nigerian laws and regulations, Husk Nigeria and IFC PS 2 on EHS and labor, transportation safety and training, and contractor E&S performance oversight, monitoring and reporting requirements. (ESAP # 6).
PS3: Resource Efficiency and Pollution Prevention
Greenhouse Gases: Greenhouse gas emissions (“GHG”) from the project during construction are predominantly associated with the transport of project components and on-site equipment and machinery and are expected to be less than 25,000 tones CO2 equivalent (tCO2eq/year).
Water Resource Needs: Water resource needs during construction and operations will be limited to domestic needs and for cleaning of panels and will be sourced from onsite water wells. Due to the small size of the solar plants, the volume of water requirement for cleaning is expected to be small and will not affect community water supplies.
Pollution Prevention – Wastewater: Wastewater from the washing of solar panels using biodegradable soaps drains into the soils on-site. Each project site has a ventilated improved pit (VIP) latrine which can be emptied by a sewerage contractor when required, for offsite disposal. As per the accepted standard, the latrines are sited at least 30 meters from a water source and 2 meters between the bottom of the pit and the groundwater table to avoid microbial contamination, as per the standard recommendation for such latrines. Given that these are standard and generally approved latrines that are generally only used by the two security watchmen per site, soil and ground water pollution related to their usage is not expected.
Pollution Prevention – Waste: Non-hazardous and hazardous waste generated at Husk Nigeria includes construction and demolition waste (i.e., wood, concrete, packaging material, metal scrap), domestic waste (particularly plastic water sachets used by the project workers), used lead acid batteries and potentially damaged PV modules and electronics. The overall volumes of both types of waste generated by each mini-grid during both construction and operations phases are expected to be low. HPS has in place a Waste Management Policy and Procedure for its operations in India that includes high level waste management measures aligned with local legal requirements. Husk has stated that the agreement with the battery supplier places a requirement on the supplier to take back the batteries at end-of-life. Going forward, the Company will update the Waste Management Procedure to align with Nigerian laws and regulations and IFC PS 3 requirements. (ESAP # 7).
PS4: Community Health, Safety and Security
Road Safety & Traffic Management: The transportation of mini-grid components and equipment to the site and staff movements to and from site represents the key safety risk in relation to the other road users and communities adjacent to the roads being used. Going forward, the Company will develop a Transport Management Procedure for the safe delivery of components and equipment and staff to and from the site. (ESAP # 8).
Security Management: Each mini-grid site will be fenced off with a single controlled access point. Access control and security will be provided on a need/ on call basis by two unarmed, locally employed watchmen. Considering, Nigeria has security challenges with cases of kidnap, terrorism, violent crime, and inter-communal violence occurring throughout all regions of the country, the Company will undertake a Security Risk Assessment of all its locations of operations and develop a Security Management Procedure to support the safe and secure development and operations of the Project, in line with IFC PS4 requirements. (ESAP # 9).
PS5: Land Acquisition and Involuntary Resettlement
The part of the ESMP, the Company establishes a Village Power Committee (VPC) to facilitate the mini-grid site selection in each village. All potential sites are screened from an E&S perspective and any sites that involve physical or significant economic displacement are not selected. The sites could either be owned communally or privately with the preferred option being communal land. If communally owned, the Company (in liaison with the VPCs) engages the village to agree on the most appropriate mode of compensation – this is typically guided by the Voluntary Land Donation Guidelines set up by under the NEP. The preferred compensation option is in the form of community investment. If there are any instances where some households are using the land, the VPC identifies and allocates alternative land to the household to use. Where the identified site has crops, the owners are generally allowed time to harvest them prior to the commencement of the construction activities, reducing economic displacement impact. In the case of privately owned land, the VPC helps the Husk team to identify the landowners to discuss, negotiate and agree the leasing of the land with. In both cases, the parties enter into a lease agreement based on a willing-lessor willing-lessee basis. Going forward, the Company will develop a Land Access Procedure that outlines the principles applied and steps followed to access land in line with IFC PS5 and DARES requirements. (ESAP # 10).
