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
Access has developed a platform-level ESMS, as documented in its ‘ESMS Manual’, to oversee E&S risk management throughout its project investment cycle. In line with IFC PS, the ESMS includes an overarching Environment, Social and Governance (ESG) policy, a framework for the identification of risks and impacts, E&S management programs, organizational capacity and competency criteria, and requirements for emergency preparedness and response, stakeholder engagement, community grievance mechanism, and E&S performance monitoring and review. The ESG policy commits Access and its partners to managing climate, governance and E&S risk in compliance with host country legislations and applicable standards, including IFC PS among others, by minimizing operational environmental impacts and ensuring workers, stakeholders and host community safety.
Similarly, Access requires developers to meet its E&S selection criteria and maintain an IFC-compliant ESMS. The MG Developer has developed ESMS manuals that include E&S policies, risk assessment frameworks, organizational structures and E&S management programs commensurate with their current scope and scale of operations. The MG Developer has in addition introduced contractor E&S audits and monitors corrective actions. The Power Hub’s ESMS is still at an earlier stage of development. Going forward, Access will ensure that the Power Hub documents and implements an ESMS in line with IFC PS and applicable World Bank Group (WBG) Environment, Health and Safety (EHS) Guidelines. (ESAP#1)
Access’ risk assessment framework starts by prescreening proposed projects against an 'Exclusion List' to sieve out those that involve illegal activities, forced or child labor, and projects that harm critical habitats or indigenous lands. After initial screening, the ESDD stage verifies compliance with host country legislation, including ESIA and environmental licenses, and alignment with IFC PS1 to PS8 principles and requirements. It also includes a review of developer's initial data, including E&S policies, management programs, and performance history. E&S risks associated with distribution lines for MG sites were determined to be minimal due to their alignment with existing easements and relatively short lengths. Access also requires developers to assess land acquisition and involuntary resettlement for applicable projects, and to prepare resettlement action plans (RAP) and livelihood restoration plans (LRP) in alignment with IFC PS5 among other standards. However, the E&S screening and ESDD procedures do not adequately cover PS5 and PS6 requirements. Discussions on PS5 and PS6 compliance for the 15 sites already built by the MG Developer are covered under the specific PS sections. Although the Power Hub’s operations do not require ESIA per Nigerian laws, Access similarly conducted ESDD to identify additional E&S requirements. The ESDD process results in a timebound ESAP which is included in the Development Agreement.
Going forward, Access will update its E&S exclusion list, site E&S screening checklist, and ESDD and monitoring procedures to incorporate (i) PS5 compliance review criteria for validating willing-lesser/willing lessee land transactions for leases signed at community level; and (ii) ESDD requirements for voluntary community land donations. In addition, Access will apply the findings of the ESDD on land acquisition to avoid donated/leased land and easements with (i) physical displacement, (ii) significant economic displacement, (iii) inadequate records or evidence of compensation/replacement land for the resettlement completed prior to IFC involvement in the projects, and (iv) historical land injustices including forced evictions. If these instances cannot be avoided, Access will require its Developers to create and implement a RAP and an LRP in alignment with PS5 and monitor and report on the implementation and outcomes of the involuntary resettlement for applicable projects. (ESAP#2)
To meet PS6 requirements, Access will develop a biodiversity screening and management procedure which will detail the process required to identify (i) Natural and Mixed World Heritage Sites (WHS) and Alliance for Zero Extinction (AZE) sites, and (ii) legally protected areas and internationally recognized, so that the acquisition or construction of new assets in these sites can be avoided - where avoidance is not possible, the procedure will (iii) set out the steps required when new assets are proposed in such areas - these will include consultation with the relevant stakeholders (e.g. KBA/AZE Secretariat, World Heritage Committee) to understand if the proposed activities are compatible with the values of these areas and the PS6 requirements (ESAP#3). Additional measures are outlined in the PS6 section.
Going forward, Access will also (i) ensure that the MG Developer submits PS-compliant ESIAs for the remaining five (5) sites comprised in the current pipeline, and (ii) enhance its E&S screening and ESDD procedures and ESIA requirements in its ESMS to address E&S risks related to BESS in accordance with IFC PS and WBG EHS Guidelines (General and sectoral). (ESAP#4)
Access has established several E&S management guidelines that apply both to its own structure and to developers and their contractors, to ensure adherence to its E&S commitments. The guidelines cover human rights, labour and working conditions, OHS, employee grievance management, biodiversity, community health and safety, supply chain, involuntary displacement and resettlement, resource use efficiency, pollution prevention (waste management, air quality, noise monitoring etc.), cultural heritage and stakeholder engagement among others. These guidelines are generally consistent with the principles of the PSs.
Developers are required to adopt the guidelines and establish project specific E&S management procedures in line with Access’ standards. For developers with existing ESMPs, additional management measures identified during ESDD are used to inform the specific ESAP. The two current developers have documented procedures that generally align with Access’s guidelines. The MG Developer’s ESMP is broadly aligned with the principles of IFC PSs and includes adequate provisions for extending E&S risk management measures to contractors. The Power Hubs’ ESMP is generally commensurate with the scale of its operations and embedded in the risk register; however, it does not place sufficient emphasis on the site construction phase. Access will require the Power Hub to review its ESMP to adequately address E&S risks associated with the construction phase in line with the principles of IFC PSs and the ‘IFC Good Practice Note for Managing Contractors’ E&S Performance’. (ESAP#5)
At the platform level, Access ESG Manager is responsible for ensuring integration of ESG policies across the organization’s operations, and adherence thereof by developers and their contractors, including progress on the developer’s ESAP. Related responsibilities are assigned to various internal stakeholders, including technical, legal, operations, and customer teams. Access' Board includes an ESG Committee with executives responsible for the sustainability strategy. At the developer level, Access mandates the appointment of a Board Director responsible for E&S issues. For every batch of 5 to 20 projects, Developers must also appoint one qualified EHS officer reporting to the country operations manager, to oversee environmental and OHS compliance during site construction and operation, and act as Community Liaison Officer (CLO). Per Access’ ESMS requirements, Developers with more than 20 projects in a single country, will be required to appoint an E&S Manager to supervise the EHS officers.
Access has established an extensive E&S training plan which is being implemented for developers at various project sites, depending on agreement status. Training modules have been designed to cover the requirements of IFC PS and WBG EHS Guidelines, and Access requires that Developers extend the training to their contractors.
According to Access’s ESMS, developers must prepare 'Emergency Preparedness and Response Procedures' aligned with IFC PS1 among other standards, to address potential emergencies such as fires, terrorism, security threats, earthquakes, flooding, hazardous materials spills, and other incidents that may impact workers, the environment or the host community. During its ESDD on the two current developers, Access identified various gaps in their existing procedures, including on the designation of responsibilities and periodic exercise. Consequently, it designed corrective measures, which were incorporated into their respective ESAP.
Access has established monitoring criteria and performance Key Performance Indicators (KPIs) that align with the commitments and goals specified in the ESG policy, as approved by the board. These include training, environmental and OHS performance, developer’s progress on the ESAP, stakeholder engagement, contractor selection and performance, human rights, gender, governance, employment among others. Periodic compliance audits of developers are scheduled to ensure continuous improvement.
PS2: Labour and Working Conditions
Access expects a construction workforce peak of 1300 (20% women) across all MG sites, averaging 85 workers per site. During operations, these numbers will drop to 28. For Power Hub sites, an average battery swapping hub provides four full-time jobs for local women and men. Developers do not require accommodation for their workers.
Access's HR policies are found in the 'Group policies and procedures manual' and the Employee Code of Ethics and apply to all employees and developers, broadly consistent with IFC PS 2 requirements. The policies explicitly cover issues like fair working conditions, freedom of association, non-discrimination and equal opportunity; gender, sexual harassment, workers’ grievance mechanism, prohibition of child labor and forced labor, and OHS at the platform-level, at developer level and in the supply chain labor. Developers are required to ensure compliance with local employment laws and applicable international standards. MG Developers and Power Hubs have established HR policies applicable to their workforce and supply chain, which are largely aligned with Access’ standards.
Access provides open-ended and term contracts for its staff in line with host country’s laws and requires developers to establish contracts with their workers on the same basis. Contracts define working hours, wages, overtime, rest days and annual leave among others. Access follows CrossBoundary’s (CB) Group HR policies and procedures manual which outlines employments terms such as payscale, overtime pay and deductions as per local labor law requirements (social security and taxes); medical cost-reimbursement, salary review, performance and bonus criteria for applicable job categories; attendance allowance, per diem, transport, and cellphone communication. Staff are informed of these terms and conditions at workers’ induction sessions. Developers HR policies and procedures are designed in line with local law and the International Labor Organization (ILO) core conventions and are broadly aligned with IFC PS2 requirements.
The Group’s HR manual outlines a worker complaint filing procedure with commitment to non-retaliation and not impeding access to other available judicial or administrative remedies, and extends to every level and location of its operations within the confines of applicable legislation. There is an anonymous hotline to allow for internal (and external) grievances and a Whistleblower’s Policy. Developers are required to prepare their own grievance mechanism in line with Access procedures. The MG Developer has a formal whistleblower process embedded in its ethics incident reporting process, which allows submission of employee grievance by email only. The ‘Power Hubs’ has also implemented a whistleblower policy, which emphasizes that complaints relating to the conduct of staff or contractors should also be reported to one or more of the Directors. To align with IFC PS2, Access will revise its employee grievance mechanism to include dedicated channels for reporting and procedures for handling issues related to gender and gender-based violence and harassment (GBVH). Access will also update the E&S Management Guidelines in its ESMS to require the same for Developers’ own employee grievance mechanisms. Once amended, Access will communicate i) its updated employee grievance mechanism to all Developers, and ii) the updated requirements in the E&S Management Guidelines for reporting and procedures for handling issues related to gender and GBVH to be incorporated into Developers’ own employee grievance mechanisms to adopt and communicate to their workforce. (ESAP#6)
Access follows CB Group’s HR manual, which recognizes the principles of freedom of association in line with host country requirements and IFC PS2. Both current Developers’ HR policies commit to respecting employees’ rights to collective bargaining and acknowledging freedom of association in accordance with the ILO core conventions. Power Hubs incorporates its commitment to freedom of association and effectively communicates it to workers across all the projects sites.
The HR policies include guidelines and mechanisms to uphold principles relating to the prohibition of forced labor and child labor, non-discrimination and equal opportunity across the company’s operations. These principles are cascaded to Developers through the E&S guidelines provided in Access’s ESMS manual and ESAPs incorporated in the respective development agreements; compliance is monitored in line with IFC PS2. Developers’ workers’ age is checked at the time of recruitment.
To implement its OHS policy, Access has developed an OHS manual, serving as a comprehensive guide for addressing and managing OHS risks across all operations, at the platform-level and at developer/project-level. The manual details Access’ oversight strategy, including regular KPI reporting, site visits, and defined roles and responsibilities. Developers are required to appoint dedicated OHS staff to promote a safe work environment with zero tolerance for unsafe practices, conduct regular OHS trainings and ensure contractors receive OHS induction prior to undertaking any activity, carry out OHS inspections/audits throughout the life of a project, monitor and report OHS performance and work incidents, and perform emergency response drills for all its sites.
During its ESDD, Access noted that the MG Developer has developed adequate employee OHS induction training programs, ‘Permit to Work’ systems, and safe working procedures (Electrical, work at height, use of personal protective equipment (PPE)), trained technicians and provided community awareness campaigns. The MG Developer’s OHS management system includes provisions for the management and oversight of contractors (mainly EPC) but does not adequately consider potential risks associated with BESS. This gap will be addressed as part of ESAP #3. The ‘Power Hubs’ operator has documented an OHS policy and developed an OHS risk register commensurate with the scope and scale of its operations. Lost time injury frequencies are not yet systematically reported across the projects; however no work-related fatalities were reported at any of the sites during the past year. Gaps have been documented in the respective developer’s ESAP for appropriate action. Selected developers appoint contractors for various jobs including site construction, module and office cleaning, waste collection or security at site.
E&S screening of Access solar modules supply chain management system confirmed that the ESMS and the Supply Chain policy adequately cover the identification and management of potential issues as per PS2. Developers perform a comprehensive ESDD process, which includes screening, policy implementation, and collecting relevant information. For instance, following its ESDD on Power Hubs, Access required the development of a human rights policy in accordance with the UN Guiding Principles on Business and Human Rights, or at a minimum, to incorporate these principles into the ESG policy and establish a procedure to ensure compliance with the policy by its suppliers and contractors. The two developers were also required to incorporate measures to screen their suppliers including for solar PV and stationary batteries to ensure they abide by a code of conduct that explicitly prohibits the use of forced labor or child labor in the supply chain.
At project level, Access has adopted with each developer different approaches for demobilization. Per ESAP#7, Access will develop a demobilization framework plan and ensure that it is cascaded to Developers and implemented at project-level in line with host country legislation and IFC PS2.
PS3: Resource Efficiency and Pollution Prevention
The current pipeline will generate 1,072 GWh of electricity annually, including 92% from solar PV and 8% from backup diesel generators (used for a maximum of 2-3 hours daily), emitting 119,455 tCO2e. This will result in a net emissions reduction of 1,305,619 tCO2e per year.
ESIA findings indicate that the impact of water extraction on neighboring communities will be limited. Water will mainly be required for sanitation, dust suppression (during construction), and solar modules cleaning (during operations). The MG Developer anticipates approximately 640L of water per cleaning cycle per site, which equates to 10,240L per year per site. The Power Hubs do not track water usage given the much smaller scale of operations. Access requires developers to evaluate water use impacts. When required, developers/contractors are responsible for developing water management procedures and promoting efficient use of water during construction and operation, in accordance with applicable WBG EHS Guidelines and GIIP.
The implementation of the various pipeline projects is expected to generate minor air, dust, water, soil pollution. Access anticipates that these issues will be mitigated by standard ‘pollution prevention and control measures’ as defined within project-specific ESAPs and ESMPs. In addition, Access enforces pollution control measures from projects construction and operation in line with performance criteria defined in its ESMS and with project-specific ESIAs and ESMPs. These measures are adequate to address pollution risks associated with power evacuation lines.
Both MGs and battery swapping technologies use Lithium Iron Phosphate (LFP) BESS to meet evening and nighttime demand. Existing BESS capacities average 0.05 to 10 kwh for the Power Hubs, 120-90 kwh for the MG Developer. Access requires developers to perform sound level measurements for sites already acquired in line with GIIP and to take appropriate mitigation measures in case of any exceedance to ensure alignment with the WBG EHS General Guidelines.
Access has developed waste management guidelines, cascaded to its developers, which describe its strategy for managing waste generated during site construction and operation, broadly in line with the principles of the WBG EHS Guidelines and GIIP. The guidelines recommend segregating construction waste into paper and plastic waste and storing solar modules, used batteries and electronic waste until viable arrangements are in place with licensed partners. The MG Developer has documented a waste management procedure which requires alignment with applicable legislation in host countries; Power Hubs has similarly developed a procedure that is mostly centered on the management of lead acid batteries. Access will ensure that the two current Developers enhance their current waste management procedures to align with its ESMS requirements and WBG EHS Guidelines and GIIP. (ESAP#8)
Wastewater from panel cleaning contains no chemicals and is disposed of in stormwater drains. Risks related to hazardous material are minimal given their limited use in operations.
PS4: Community Health Safety and Security
Project specific risks and impacts to host communities are assessed through respective ESIAs. Access also carries out community E&S risk screening during the due diligence phase. Developer’s agreement clauses require that assets be designed according to internationally recognized fire protection standards, including the National Fire Protection Association (NFPA) and the International Electrotechnical Commission (IEC), and clearances for solar sites and MGs. Distribution lines are designed according to the minimum clearances specified in the electricity grid regulations of the host country and run along public right-of-way.
On average, the MG Developer appoints 2 to 4 security guards per site, selected within the host community. Access’ ESMS has defined a set of requirements for the management of security forces by developers in line with the Voluntary Principles on Security and Human Rights and the IFC’s Good Practice Handbook: Use of Security Forces’. During ESDD, Access reviews security guards' working conditions and offers recommendations for improvements. Going forward, Access will require Developers to maintain community engagement logs as well as vetting requirements of security contractors and trainings of security personnel on respectful engagement with workers and communities. If EPC contractors hire additional security, these personnel will receive similar training and will follow the same security management plan. (ESAP#9)
As part of stakeholder engagement, developers organize community meetings to raise awareness about E&S risks associated with their operations. As part of its ESMP, Access requires developers to document project-specific EPRP covering risks associated with the health and safety of the potentially affected communities and other stakeholders. Under ESAP#4, Access will ensure that community risks associated with BESS are addressed and adequately managed.
The ESIAs assessed the risk of exposure of host communities to traffic accidents as minimal. Developers recruit construction workers locally and during operations, technicians use motorbikes for technical support. Under ESAP #5, Access will require developers to document project-specific 'traffic management procedures' for construction and operations in line with national requirements and IFC PS4.
PS5: Land Acquisition and Involuntary Resettlement
Access partners with developers to set up MGs on communal land in rural communities. Sites are selected on village outskirts or open areas to avoid taking inhabited or productive land. The MG Developer has secured eight deeds of gifts and seven deeds of lease from the host communities, beneficiaries of the first batch of projects considered under its agreement with Access. Past land use screening on the project sites indicates low risks of economic displacement and no physical displacement. MG Developers also have multiple options and prioritize vacant land to avoid physical displacement and minimize the risk of economic displacement.
Going forward, as outlined under ESAP#2, Access will enhance its land access screening procedure to include due diligence questions covering land access process including community land donations as well as the requirements and monitoring of implementation of RAP and LRP in line with IFC PS5. This procedure will be communicated to all developers and monitored by Access with specific monitoring and reporting requirements.
PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources
Access acquires bankable, ‘shovel-ready’ solar-hybrid MGs in Sub-Saharan Africa, with the focus of the current investment being on 15 sites situated throughout Nigeria, in the Guinean forest-savanna ecoregion. An analysis of the MG sites indicates that whilst all sites are characterized by Modified habitat, two are situated within a protected area (Dagida Game reserve; IUCN Management category IV). A further 13 are situated within the Lower Kaduna-Middle Niger Floodplain which is designated as a Ramsar Site (Wetland of International Importance) and is a legacy Key Biodiversity Area (KBA), which is not expected to meet Critical habitat thresholds.
The biodiversity baseline assessments were basic and relied on visual observations rather than systematic surveys. Furthermore, the national ESIAs do not fully address IFC PS6 requirements such as confirming the presence/absence of natural habitat, identifying legally protected areas (LPAs) or internationally recognized areas (IRAs), assessing the presence and risk of invasive species and the application of the mitigation hierarchy. Access will require Developers, through an update to its ESMS, to screen and assess projects against IFC PS6 criteria (as per ESAP#3), and any biodiversity-related mitigation measures to be captured in the ESMPs prior to commencement of project activities. Should there be likely impacts on biodiversity, the Developers will be required to seek suitably qualified biodiversity experts with IFC PS6 experience to undertake the impact assessment and develop appropriate mitigation measures as part of the ESIAs. The mitigation and management measures pertaining to biodiversity conservation included in the ESIAs and ESMPs shall be IFC PS6-compliant, including avoidance, minimization (including management of invasive species, sediment and erosion controls and managing human access), restoration, offsetting (as required), and ongoing maintenance. For sites in the existing portfolio which are situated in legally protected areas and/or IRAs, Access’ Developers will secure the relevant legal permissions, consult protected area sponsors and managers, and engage suitably qualified biodiversity experts to develop a BAP to define mitigation actions and additional programs (which are consistent with any government recognized management plans for the area) to contribute to the conservation objectives of these areas, in consultation with relevant stakeholders. (ESAP#10)
