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.
Environmental and Social Policy and Management System
The Sponsors are yet to develop an ESMS for construction and operations. As part of ESAP #1, the Sponsors, will develop and implement an ESMS in accordance with the general requirements of PS1, including the following elements: i) E&S policy; ii) identification of hazards and assessment of risks and impacts; iii) management plans; iv) organizational capacity and competency; v) training plan; vi) emergency preparedness and response; viii) stakeholder engagement plan and community grievance mechanism; and ix) monitoring and review. The E&S Policy will outline RSB commitment to operate in compliance with applicable laws and regulations, IFC’s Performance Standards and define the Project’s E&S objectives. The ESMS will detail processes developed by the Sponsors to identify and manage E&S risks and impacts of all project components, including the agricultural facility and transmission line. As part of the ESMS, RSB will develop and implement specific mitigation measures, including management plans and procedures and ensure adequate capacity to implement those plans detailing roles, responsibilities, and level of accountability.
Identification of Risks & Impacts
E&S risks and impacts associated with the Project are outlined in the ESIA, which was prepared as part of RSB’s application process to obtain planning permission from Barbados’ Planning and Development Department (PDD). The ESIA was conducted in accordance with local requirements and RSB was granted planning permission for 25 years in June 2023. Gaps identified in the ESIA will be addressed through the ESAP items contained thereof and include OHS, effluent and solid waste management, road safety, security, and cultural heritage.
A Cumulative Impact Assessment was conducted as part of the ESIA. Overall, cumulative impacts on the atmospheric and acoustic environment, surface water and groundwater resources, flora and fauna, visual environment, health and safety, human capital, cultural values, infrastructure, and services, are not predicted to be significant. RSB performed an alternative analysis to determine the best Project site location considering E&S criteria.
Quantitative Risk Assessment
The ESIA includes baseline surveys, supplemental modelling studies and a coarse Quantitative Risk Assessment (QRA) to assess the impact and likelihood of potential hazardous events linked to the Project. The QRA study covers various major accident scenarios such as fires and explosions linked to hydrogen production, storage, fuel cells and lithium-ion battery energy storage system. Overall, the QRA, conducted in line with internationally recognized standards, concluded that the consequences of major accident hazards associated to RSB’s operation are limited to within the Project site boundary.
As per ESAP #2, at the detailed design and engineering phase, RSB will complete a detailed QRA to also cover analysis of risk exposure from escalation domino events, and impact to on-site workers and offsite populations. Based on the results of the detailed QRA, RSB will develop and implement any needed prevention and mitigation measures, including needed engineered safeguards, to avoid and minimize harm and risk of injuries to workers and communities. In addition, RSB will ensure public safety measures are implemented through a) the implementation of design solutions and adequate measures to ensure containment of an exclusion zone within the Project perimeter; b) prohibition of unsupervised public intrusion to avoid the risk of injury to people outside the project limits; and c) development and implementation of a Compensation Framework for minor damage to surrounding infrastructure such as broken windows or small wall cracks, a social baseline, and an inventory of assets in areas where occasional minor damage may happen. In addition, RSB will develop and implement a Process Safety Management System (PSMS) compliant with Good International Industry Practice (GIIP) to prevent process-related incidents. The PSMS will include but not be limited to process hazard analysis, operating procedures, training, management of change, incident investigation and emergency planning. Process safety studies relevant to the safe design, construction, and operation of the plant, will include, as a minimum, Hazard and Operability (HAZOP) study; Safety Integrity Level (SIL)/Layers of Protection Analysis (LOPA); Identification of Safety Critical Elements (SCE) and development of their Performance Standards; Hazardous Area Classification study; Occupied Buildings Risk Assessment (OBRA); and, Escape and Evacuation Risk Assessment (EERA), among others.
Potential Impacts associated with Land Acquisition
For the Project components, the Sponsors have entered into an Option to Lease arrangement for 73.2 Ha of land through a willing buyer/willing seller negotiation with the private company Harrow Limited for 28-year leasing, and no physical displacement has been identified nor is anticipated. RSB will connect to the national grid via a new approximately 3km underground transmission line; and, to the water municipal network that is owned and operated by BWA. It is expected that in both cases the Right-of-Way (ROW) and pipelines will run over existing public roads/trails. RSB has not yet performed an analysis of potential impacts related to the installation of the T-Line or infrastructure needed to connect to BWA’s network. Therefore, as per ESAP #3, to prevent and mitigate all potential risks and impacts associated with land use/acquisition, RSB will develop a Land Acquisition and Compensation Framework (LACF), including a socioeconomic assessment to identify and prevent any potential physical or economic displacement in any Project component. If determined necessary and in alignment with the LACF, RSB will develop and implement a Resettlement Action Plan and Livelihood Restoration Program based on the results of the assessment and following PS5 requirements. The Stakeholder Engagement Plan and Community Grievance Mechanisms will be available to address complaints associated with land acquisition (ref. ESAP #18).
Management Programs
An Environmental and Social Management Plan (ESMP) was developed as part of the ESIA. The ESMP outlines general mitigation measures to be followed by RSB and its contractors during Project construction, commissioning, operation and maintenance, and decommissioning. It also outlines response procedures to be followed in the event of an emergency. However, the ESMP needs further enhancement to be aligned with IFC PSs and WBG EHS General Guidelines, including labor, OHS, and community safety. As part of ESAP #4 and ESAP #5, the Sponsors and the EPC contractors will use the ESMP as a broader framework to develop a Construction Environmental and Social Management Plan (CESMP), and an Operations Environmental and Social Management Plan (OESMP) that address the gaps mentioned above and provide a more detailed approach to the E&S requirements identified.
The CESMP and OESMP will consist of a set of management plans that outline the strategies and measures to address environmental, health, safety and social impacts associated with the Project construction and operational activities. These management plans will be developed in alignment with IFC PSs and WBG EHS General Guidelines and will include but not be limited to labor management, occupational health and safety, process safety, hazardous materials management, solid and hazardous waste management, water management, emergency preparedness and response, community health, safety & security, road and traffic safety management, security management, environmental monitoring plan, stakeholder engagement (including community grievance management and communications strategy) and contractor management.
Contractor Management
HDF has developed an Environmental and Social Requirements document for the Project that includes the minimum E&S criteria that should be followed by the selected EPC, including specific compliance with IFC Performance Standards. As per ESAP #6 the Sponsors will revise and update the document to include among others i) development and implementation of an ESMS; ii) adherence to the Project’s policies, iii) detailed ESHS plans to be developed and implemented, iii) provisions of E&S personnel and resources allocated to the contract, iii) monitoring and reporting of E&S performance, and iv) explicit commitment to compliance with the Project conditions, ESAP and national law. The document will make an integral part of the contract and will also require the EPC contract with relevant subcontractors to integrate needed E&S requirements into their bidding and contracting process, including monitoring processes that are appropriate for the works being subcontracted. The updated document will be developed following provisions outlined in IFC Good Practice Note: Managing Contractors' Environmental and Social Performance. In addition, the Sponsors will develop a Contractor Management and Assurance Plan (CMAP) describing the controls to ensure all ESHS risks and impacts are adequately managed from mobilization and early works, through construction, commissioning, and operations.
Organizational Capacity & Competency
E&S management and monitoring responsibilities for construction and operations will be shared between the Sponsors and the EPC. The Project Director will act as the Sponsors’ representative during the construction phase and will be responsible for validation of the updated ESMP and alignment with the Sponsors’ guidelines. The EPC will be responsible for the implementation of the ESMP with the support of the EHS Coordinator that will also report to Project management on EHS matters and monitor compliance with relevant EHS standards. During O&M, the Plant Manager will have overall accountability for the implementation of the ESMP.
As part of ESAP #7, RSB will appoint qualified and experienced staff, including EHS and social managers, to ensure adequate capacity to manage environmental, labor, process safety, OHS and social aspects and oversee the EPC contractor. RSB will require the EPC contractors and subcontractors to appoint qualified and experienced teams to manage their respective scopes of work. The social manager and team will be appointed before the construction stage starts.
Emergency Preparedness & Response
The ESMP outlines key aspects of an Emergency and Disaster Management Plan, including spills, fires, vehicles accidents, explosions, and hurricanes. Based on the document and as part of the CESMP and OESMP, RSB and its contractors will develop Project-specific Emergency Preparedness and Response Plans (EPRP) for onsite and off-site emergencies in accordance with IFC PS1 & PS4 and relevant GIIP such as CCPS Guidelines for Technical Planning for On-site Emergencies. These plans will be linked to the updated QRA to be developed during detailed engineering and design and will also cover credible potential emergency scenarios, including but not limited to, medical emergencies, major accident hazards, natural disasters, and extreme weather conditions and identify communities and individuals that may be impacted. The EPRP will cover all project components and include response procedures, equipment and resource provisions, designation of responsibilities, periodic training and drills, and communication flows, including potentially Affected Communities and relevant authorities (ref. ESAP #4 & ESAP #5). The EPRP will be supplemented by a Communications Strategy to raise awareness, preparedness, and training for Affected Communities and relevant stakeholders (ref. ESAP #18).
Monitoring & Review
Periodic audits during construction, commissioning, operation, and maintenance are foreseen as part of the ESMS and ESMP to assess compliance with existing regulatory and ESMP requirements. As part of the CESMP (ref. ESAP #4) and OESMP (ref. ESAP #5), RSB will develop E&S Monitoring and Assurance Plans for both the construction and operation phases covering aspects such ESHS training, water use and consumption, liquid effluents, solid and hazardous waste management, noise, transportation, workplace conditions, process safety, OHS, social aspects including labor, security, and stakeholder engagement, etc. The CMAP will outline specific controls to oversee and monitor the EHSHs performance of the EPC and its subcontractors (ref. ESAP #7). In addition, as described under PS6, RSB will develop an independent verification system to monitor long-term implementation of Global GAP for Livestock requirements in the Project’s agricultural component (ref. ESAP #15).
Monitoring will also include regular internal/external ESHS and process safety inspections and audits. RSB will review and evaluate the effectiveness of the ESMS and ESMPs on a regular basis. As part of the PSMS (ref. ESAP #2), an independent review of operational readiness of project prior to commissioning and process safety audit one year after start of commercial operations will be undertaken. Moreover, as per ESAP #8, RSB will appoint a third-party Environmental and Social Consultant to review the effectiveness of the ESMS, CESMP and OESMP, every six months during the construction phase and every year during the first two years of the operation and maintenance phase, and every 2 years thereafter. RSB will review and evaluate the effectiveness of the ESMPs on a regular basis.
Supply Chain
HDF has a Responsible Purchasing Charter (RPC) with specific provisions against child and forced labor and requirements to ensure a safe and healthy workplace. As per ESAP #9, the Responsible Purchasing Charter will be adopted by both Sponsors who will also incorporate contractual clauses in agreements with the EPC contractors and its suppliers requiring that suppliers and sub-suppliers comply with the RPC. The Sponsors or EPC will be entitled to change its suppliers if non-compliances are found and cannot be resolved, such provisions will be embedded in the supplier contract. Moreover, RSB will require the development and implementation of Subcontractor and Supplier Management Plan which will be prepared as part of the CESMP (ref. ESAP #5). The plan will require the screening of suppliers, recordkeeping on relevant documentation and compliance with the RPC. RSB’s internal audit team will review documentation related to EPC’s due diligence regarding their suppliers. The Sponsors have two pre-qualified solar panel providers, both of which have Supplier Code of Conducts addressing compliance with laws, zero tolerance for child or forced labor and measures to protect environment, health, and safety.
PS2 – Labor & Working Conditions
Project construction will be managed by an international EPC contractor that will subcontract local workforce. It is estimated that the construction phase of the Project will provide temporary employment for 150 – 200 people. Following construction, it is estimated that approximately 20 full-time workers will be hired for operation, maintenance, and security requirements. In addition, approximately 10 employees will be hired by the farm entity for the operation of the sheep farm. The number and gender of local and national workforce that will be hired has not yet been determined but it is expected that around 30% of the employees will be hired locally during construction and 10% during O&M, with the intention of maximizing knowledge transfer to a majority locally trained workforce.
Human Resources Policies and Procedures
RSB is yet to develop its HR policies and procedures which will be developed as part of a Workforce Management Plan as required by ESAP #10 and will be aligned to local regulations, international standards, and IFC PS2 requirements, including prohibition of child and forced labor, prevention of discrimination and sexual harassment, freedom of association and collective bargaining agreement and health and safety in the workplace. In addition, the Plan will include (i) a Code of Conduct for managers and all workers (direct and contractors) with disciplinary actions for non-compliance and induction training that includes internal rules and the expected behavior on the workplace and as well as rules for interactions with local communities, including prevention of sexual harassment in the workplace, sexual exploitation and abuse in local communities; (ii) procedures for local recruitment, reporting of working conditions and demobilization to mitigate negative impacts on workers and communities, such as providing notice period, ensuring payment of severance packages, and addressing workers’ liabilities in hosting communities such as unpaid bills and compensation for damages; (iv) workers’ accommodation plan compliant with IFC/EBRD Guidance Note on Workers’ Accommodation; (v) a gender strategy including gender equality approach, GBVSH prevention and addressing safety risks for women in the workplace, such as transportation and work in isolated areas, and provision of adequate personal protective equipment to ensure safety does not hinder employment opportunities for women.
Workers Grievance Mechanism
As per the ESIA and the ESMP, RSB has committed to implement an internal grievance mechanism to address complaints from workers, including a confidential/anonymous channel to file complaints associated with harassment and GBVSH. As per ESAP #11, RSB will establish an internal grievance procedure that covers the channels available to report grievances (including those confidential, anonymous, and associated with GBVSH to be managed by trained personnel) as well as dissemination, recording, logging, and tracking methods for all complaints to ensure the follow-up and analysis. The procedure will include interface with contractors, subcontractors, and service providers as well as internal protocols to effectively manage and report grievances.
Workers Accommodation
No workforce accommodation camps are envisioned as part of the Project, for the construction or operations phases. However, the contractor may consider the use of construction camps to accommodate their workers as a means of limiting competition for housing on the island between workers and local community members, in which case, RSB will follow i) provisions detailed on IFC and EBRD’s Worker’s accommodation: Process and Standards Guidance Note and include monitoring and inspections on worker’s accommodations as part of the Workforce Management Plan (ref. ESAP #10); and ii) the Land Acquisition and Compensation Framework and implement Resettlement Action Plan and Livelihood Restauration Program if required (ref. ESAP#3).
Workers Organizations
Barbados Constitution provides for the right of workers to form and join unions. As mentioned above, RSB HR policies will include provisions on freedom of association and collective bargaining (ref. ESAP #10).
Child and Forced Labor
No child or forced labor will be used by the Project at any time. RSB will request proof of identification and age at the time of employment. Moreover, as mentioned above, RSB HR policies will include provisions to prohibit child and forced labor (ref. ESAP #10).
Occupational Health and Safety
Main occupational health and safety risks related to the Project include fire and explosions hazards associated with hydrogen storage, battery energy storage system and fuel cells, exposure to chemicals and electric shocks. Construction phase related hazards include worker´s exposure to extreme weather events, such as heatwaves or heavy storms, heavy equipment operations, confined space entry, trenching and excavation, and man-machine interface hazards.
RSB performed a Hazard Identification (HAZID) Study for the Project site and a HAZOP study for the hydrogen storage area. As part of ESAP #12, RSB and its EPC will prepare site-specific OHS risk assessments relevant for the construction and operational phases of the Project and implement risk control measures for all identified risks and hazards, including a permit to work system and specific safe work procedures to manage and control high risk activities. RSB will also develop and provide health and safety training to workers and contractors relevant to construction and operations phase hazards and risks, provide personal protective equipment to workers, and report on leading and lagging indicators including reporting and investigating work-related incidents. OHS aspects will be embedded within the Environmental and Social Requirements document to be developed as part of ESAP #6 and the following provisions outlined in IFC Good Practice Note: Managing Contractors' Environmental and Social Performance.
PS3 – Resource Efficiency & Pollution Prevention
Air emissions and Greenhouse Gases
Greenhouse gases from the Project are expected to be less than 6,000 tones CO2 equivalent (tCO2eq/year) and will be associated mainly with transport, on-site equipment, machinery, and sheep. The Project is expected to generate approximately 56 gigawatt hours (GWh) of electricity per year, resulting in an estimated GHG reduction of 37 226 tCO2eq/year.
Non-polluting gaseous emissions are expected to be released from the HESS, including pure oxygen from the water electrolysis process, small quantities of hydrogen gas from the electrolyzers and fuel cells and water vapor from the operation of the fuel cells. As part of the PSMS (ref. ESAP #2), RSB will develop an oxygen dispersion model to assess the potential risks and impacts associated with the release of oxygen from the electrolysis process at the Project site and surrounding areas. Based on the results of the model, the Sponsors will establish appropriate mitigation measures and safety protocols to reduce the risk of fire and explosion.
Water Consumption and Liquid Effluents
The Project’s water consumption requirements are estimated to be around 75m3/day and will be used for human consumption, producing hydrogen from water electrolysis, supporting agricultural operations and cleaning of solar panels. Solar panels will be hand-cleaned with clean water once a year with an average estimated consumption of 100m3/year. No detergents or cleaning chemicals will be used to prevent groundwater pollution.
Based on an Alternate Water Source Assessment, it was determined that the Project’s water supply will be primarily sourced from the municipal grid. The water volume requirements are not considered to be significant and are not expected to impact water availability in the country. Nevertheless, as per ESAP #13, RSB will reduce the water footprint by maximizing the use of rainwater for non-potable water use. Surface runoff from rainwater will be managed through on-site drainage works and directed towards suck wells. As part of the ESIA, a drainage assessment was conducted to identify potential changes to drainage patterns following the construction of the Project. The drainage system configuration was determined based on the assessment to capture, attenuate, and promote the infiltration of runoff to groundwater zones.
An average of 60 m3/day will be treated via reverse osmosis to remove minerals and produce approximately 30 m3/day of demineralized water for hydrogen electrolysis. The remaining 30 m3/day of water will be a mineralized water by-product of the treatment process that is not expected to contain contaminants other than the minerals that were removed during the reverse osmosis process. As per ESAP #14, RSB will assess environmentally sound, technically, and financially feasible options for the use or final disposal of the reverse osmosis reject water, supported by relevant studies as needed, and implement a monitoring program. Furthermore, the quality of discharged effluents will comply with parameters established under the Barbados Marine Pollution Control Act, CHAP. 392A.
There is no sewerage in the part of the island where the Project is located as sewerage systems are limited to Bridgetown and the south coast. Therefore, wastewater from sanitary uses within Project buildings will be preliminarily treated at an onsite septic tank. The cumulated solids will be periodically emptied by truck and disposed of at adequate licensed facilities.
Hazardous Materials
In addition to hydrogen and batteries, for which an additional QRA will be developed as stated under PS1 (ref. ESAP #2), the main hazardous materials that will be present on-site include fuels, hydraulic fluids, lubricants, oil from electrical transformers and potassium hydroxide (KOH) that will be used as an electrolyte. Hazardous substances will be stored in secure areas with secondary containment. There will be no hazardous emissions, discharges, or wastes associated with hydrogen storage or use.
As part of the CESMP and OESMP described within PS1, RSB and its contractors will establish and implement a Hazardous Material Management Plan aligned with local legal requirements, IFC PS3 and WBG EHS General Guidelines that covers classification, labeling, handling, storage, transportation, and final disposal. The plan will be linked to the Emergency Preparedness and Response Plan that will include procedures for spill prevention, control, and response in relation to these substances.
Solid and Hazardous Waste Management
Solid and hazardous waste will be segregated and temporarily stored on-site for off-site disposal, recycling, and/or treatment at approved waste management facilities in accordance with applicable regulatory requirements. Solid waste will include mainly sheep manure, municipal solid waste, metal scrap and non-hazardous electronic components. Hazardous waste will include mainly used Lithium-ion batteries, used KOH solution, and used transformer oil.
As part of the CESMP and OESMP described within PS1, RSB and its contractors will develop a Waste Management Plan aligned with local legal requirements, IFC PS3 and WBG EHS General Guidelines. The plan will outline the process for appropriate waste storage, segregation, and transportation, as well as an assessment of available waste treatment and final disposal facilities. Project waste will only be disposed of and treated at appropriately licensed and adequately designed facilities and in accordance with applicable regulatory requirements.
Environmental noise
A baseline noise assessment was completed to measure noise levels originating from current site conditions in the vicinity of the Project. Overall, existing ambient noise levels were found to be below the WHO Guideline threshold for outdoor residential areas except for two monitoring points. Noise will result mainly from the operation equipment and the presence of sheep. Machines will be equipped with appropriate sound attenuation devices and will be regularly inspected and maintained so that they remain operating in accordance with manufacturer’s recommendations. Noise levels will be periodically measured as part of the monitoring plan.
PS4 – Community Health, Safety & Security
Main risks to the Project’s surrounding communities are related to the presence of hazardous substances such as hydrogen, transportation activities, influx of workers, presence of security forces, and emergency scenarios that could extend beyond the Project site. Construction activities will be scheduled during daytime only to avoid undue nuisance to off-site receptors. As described under PS1, RSB and its contractors will develop EHSS management plans and procedures to protect public health, safety, and security.
Community health and safety
As per ESAP # 15, RSB will implement a Gender Strategy to address GBVSH related to the behavior of Project workers in surrounding communities that includes i) the implementation of awareness campaigns for both workers (including contractors, truck drivers, and security forces personnel) and communities regarding the gender risks associated with the Project; ii) the development, dissemination, and promotion of the grievance mechanism including the available specific channels for reporting GBVSH cases/grievances in the community that involves workers and contractors; iii) development of an Influx Management Plan (linked to the Workforce Management Plan) to assess, prevent, mitigate, and monitor impacts from Project-induced immigration on public services (e.g., medical, schools, water, and sanitation), public security and GBVSH, and will include the designation of a participatory monitoring committee with the local authority (Parish) to prevent, monitor and address the potential impacts.
Hazardous Materials Management and Safety
As described under PS1 section, RSB will develop a detailed QRA to assess the impact and likelihood of potential hazardous events linked to the presence of hydrogen and lithium-ion batteries at the Project site and develop and implement adequate mitigation measures to avoid and minimize impacts to Affected Communities (ref. ESAP #2).
Road and Traffic Safety Management
The Project components required for construction and equipment installation will be transported to the Project site by truck. The roads around the Project site do not have sidewalks and it is estimated that approximately 450 trucks will be required for transportation. As part of the CESMP (ref. ESAP #4) and OESMP (ref. ESAP #5), RSB will develop a Road and Traffic Management Plan to address risks associated with increased traffic during construction and operations. The plan will i) include child-elderly approach, community awareness and driver training; ii) identify critical locations such as hospitals and schools to prevent accidents and protect vulnerable pedestrians, and potential GBVHS risk zones identification (e.g. critical rest locations for drivers on the roads); and iii) inventory infrastructure that could be affected due to the traffic; iv) inspect existing roads prior to the start of construction to determine if additional maintenance works are required; v) address trip planning, driver fitness, training and competence, speed limits, vehicle maintenance and emergency response for road accidents; and vi) consultation and coordination with local traffic authority/police. The final routes will be determined based on a risk assessment to minimize impacts on local communities. The plan will also consider a compensation procedure to address any property damage resulting from vibrations and traffic.
Community Emergency Preparedness & Response
As described under PS1 section, RSB and its contractors will develop an EPRP for the construction and operational phase of the project. The plan will identify communities and individuals that may be impacted in an emergency and describe communication flows, including appropriate information disclosure to Affected Communities and relevant government agencies. (ref. ESAP #4, ESAP #5 and ESAP #18).
Security Personnel
The Project property will have a dedicated guard building with 24-hour security presence to prevent unauthorized entry to the Project site. As part of the CESMP (ref. ESAP #4) and OESMP (ref. ESAP #5), RSB will develop and implement a Security Management Plan that outlines principles of proportionality and good international practices, including security forces vetting, equipping, monitoring, and training on appropriate use of force, Human Rights and GBVSH. Security workers will also adhere to the Code of Conduct developed as part of the Workforce Management Plan (ref. ESAP #10).
PS6 - Biodiversity Conservation and Sustainable Management of Living Natural Resources
The Project is located in the Caribbean shrublands ecoregion (WWF) and the landscape has been degraded for many years. No significant biodiversity values are associated with the Project site.
Regarding the livestock component of the Project (sheep), even though no significant biodiversity values are associated with the Project site, the operation will be managed sustainably, as such RSB will manage the livestock operation following Global GAP for Livestock requirements and will develop an independent verification system to monitor long-term implementation as required by ESAP #16.
PS8 - Cultural Heritage
A section of the historic Barbados Trailway Line is included in the Barbados National Registry of Historic Places and parallels the northern section of the Project site. The trailway, which is currently under rehabilitation works, will be converted into an accessible pathway for pedestrians, runners, and cyclists to the UNESCO World Heritage properties along the route connecting the East and West coasts of the island. RSB has excluded the Trailway area from the Project area to protect and preserve the historic path. As per ESAP #17, RSB will formally consult with relevant regulatory agencies entrusted with the protection of cultural heritage and Affected Communities and determine appropriate measures to protect the railway section that crosses the Project site. In addition, RSB and its contractors will develop a Chance Find Procedure to ensure all provisions for managing chance finds (defined as cultural heritage encountered unexpectedly during project implementation), are appropriately implemented, including the notification to competent authorities and the designation of a qualified specialist.
