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 Assessment and Management System
Policy
Agro Care, the parent company of Hicha II, has developed and implements policies that relate to the typical environmental and social aspects of growing tomatoes in greenhouses. The Corporate and Social Responsibility (CSR) department, based in the Netherlands, develops these policies and the practices/procedures described therein, including environmental policies (EHS management, effluent and solid waste management including hazardous wastes, emergency preparedness, etc.), those pertaining to human resources management including contractors/sub-contractors, occupational health and safety (OHS) management (including both construction and operational phases), recruitment, retrenchment and a stakeholder engagement policy. Specifics are referenced below in the relevant sections of this document.
In addition to these policies, company operations are certified to a number of international standards, including ISO 22000 (food safety), ISO 9001 (quality), ISO 14001 (environmental management), ISO 45001 (OHS), SEDEX SMETA (SEDEX Members Ethical Trade Audit, a worldwide social audit practice that reviews working conditions in a company’s business and, as applicable, its supply chain), GlobalGAP, Fairtrade and customer bespoke E&S standards (such as from leading UK and European supermarkets), all of which require policies aimed at driving high levels of environmental and social performance. Evidence of good practices, as required by these policies and standards, was seen with regards to environmental and human resources management during site visits to Agro Care operations in Tunisia and the Netherlands.
Whereas some of the above policies refer to aspects of IFC’s Performance Standards, as part of the ESAP item #1, the company will review and update all the relevant policies to ensure they are consistent with the IFC Performance Standards and indicate who within the organization will ensure compliance with the same and communicate the updates to all levels within the organization.
Identification of Risks and Impacts
Requirements of the sustainability standards, which all contain the requirement to conduct risk assessments, combined with host nation laws and regulations, and those of their marketing co-operative (HH) and their customers, guide Agro Care in identifying and assessing typical E&S risks and impacts found within its tomato growing business.
The company has undertaken an Environmental and Social Impact Assessment (ESIA) for the proposed Hicha II project as required by Tunisian legislation. The ESIA (which is disclosed alongside this ESRS) was developed in response to host nation law; additional requirements to fully meet PSs were not the basis of the initial assessment.
A review of the ESIA, led IFC to determine that some risks and impacts assessments regarding associated project elements were insufficient in scope and depth and did not fully address the requirements of the IFC Performance Standards. For example, the potential impacts upon fisher’s economic livelihood had not been subject to assessment, nor a socio-economic baseline of this cohort established (per the requirements of PS5). Full engagement with those likely to be impacted had not been undertaken, nor project impacts fully explained. Additional biodiversity assessment and mitigation plans were also required for potential impacts to natural and critical habitat in order to meet PS6 requirements for No Net Loss and Net Gain. Following a discussion with the company regarding these shortcomings, the company has closed these assessment gaps to align with PS5 and PS6 as described below.
Management Programs
The ESIA includes an environmental management plan (EMP). The EMP includes elements related to management and staff capacity, monitoring, and it defines specific actions to be undertaken with respect to construction and operational activities. These include generation and management of wastes, effluent discharges, atmospheric pollution, noise, etc. Please see the section on PS3 for the need to enhance this EMP to ensure it is compliant with the applicable requirements of the relevant WBG EHS Guidelines. The management programs will also be complemented with relevant plans to mitigate risks and impacts identified by the additional assessments undertaken to meet PS requirements.
In addition to the above, the company conducts management programs to align with its customer expectations with respect to E&S management, those of Harvest House, and as part of the continual improvement requirements of its certification schemes.
Organizational Capacity and Competency
The company employs competent individuals to oversee operations, supported by their teams. The manager responsible for quality matters and compliance with sustainability certifications is supported by an environmental officer and ten qualified individuals (through having completed company provided training) to manage matters related to waste separation, compaction, two hygienists (managing food safety, hygiene, first aid, use of personnel protective equipment, or PPE), a health and safety (H&S) officer (checklist enforcement, monitoring/measuring achievement of monthly Key Performance Indicators, or KPIs, plus topical issues as they arise through the year such as working in heat, flu season) and ten personnel responsible for overall cleanliness. See below in the section on PS2 for those engaged in human resources management. The company has provided suitable resources for E&S management of its operations.
A competent engineer, experienced in the design, construction and operation of desalinization plants, has been mobilized to manage project elements of Hicha II. The company has also engaged with Tunisian professionals for the preparation of the ESIA.
Emergency Preparedness
Agro Care has developed an emergency preparedness and response plan (EPRP) procedure for its Tunisian operations. It outlines actions to be taken regarding possible fire, accidents, incidents, road accidents, spills of hazardous materials, epidemics, acute health impacts (such as food poisoning), and occupation of the premises/robbery. A requirement to conduct drills and to report on the performance of such and, where necessary, to detail the need to improve is referenced.
Monitoring and Review
The company has developed its own KPIs, also to meet Harvest House requirements and other management system certifications. Each 3rd party certification scheme requires setting objectives and targets on a recurring basis, and a performance review that is integral to the periodically required senior management review.
Agro Care is preparing to comply with the European Union Corporate Sustainability Directive (CSRD) when that enters force.
PS2: Labor and Working Conditions
Human Resources Policies and Procedures:
Agro care has developed an HR Manual for Hicha I, in line with the Tunisian Labor code and will be expanded for future operations in Hicha II. The HR manual outlines several policies and procedures including: i) terms and condition of employment (working hours and rest time, overtime, gazetted holidays); ii) staff responsibility; iii) equality of treatment and non-discrimination; iv) prohibition of forced and child labor; v) freedom of association and vi) mechanism for managing grievances accessible to all employees. The following HR gaps with PS 2 requirements were identified i) provisions on employee benefits (sick leaves, injury leaves, maternity and paternity leaves requirements); ii) measures to prevent gender-based violence and harassment (GBVH) at workplace and iii) a retrenchment policy. For Hicha II, Agro Care will update its HR manual and disseminate it in a language accessible to all its workforce in a manner consistent with the Tunisian Labor Code and PS2 requirements (ESAP #3)
Working Conditions and Terms of Employment: The project is expected to hire around 100 workers during the 18 months construction period of the desalination plant. Once in operation, the plant will expect to have eight full time open end (Contract à Durée Indeterminée – CDI) workers involved.
Currently, Hicha Joy employs 95 workers, CDI, and term staff (CDD, Contrat á Durée Determinée), depending on the required skills and project phases. The company complies with the Tunisian labor legislation where term contracts cannot exceed four years of employment after which a worker is automatically converted into an open-end staff.
Around 1500 seasonal workers will be employed during the full operation of the greenhouses, mainly covering two seasons including planting and harvest seasons (from September to Mid-July) and preparation for the new season. Seasonal contracts cannot exceed 10 months per two consecutive seasons and are renewable from year to year for specific tasks. At contract renewal, each seasonal worker automatically is awarded with an additional step in the job grade system and an increase of 3% minimum of the previous salary.
All staff have been given contracts in accordance with the Tunisian Labor Code which specifies employment duration (including possibility of renewal), probation period, description of the job tasks, possibility of contract extension, breakdown of the amount to be deducted to contribute to the social security system. Open-ended staff are also entitled to medical coverage and provision for five days of sick leave per year, as required by the Tunisian legislation. As per ESAP item 3 the company will prepare and implement a comprehensive benefit package that will also target all CDD and seasonal workers.
Gross salaries for both permanent and seasonal staff are at least 15% higher than the national minimum wage. All workers are also eligible for an annual prime allowance and other performance-based bonuses. Salary increases are on average 3% per year with possibility to negotiate higher rates through working committee for exceptional reasons, such as in response to high inflation levels. Additional in-kind allowances are given in the occurrence of religious holidays and celebrations.
In line with Tunisian law, workers are employed for 48 hours a week (with one hour break for lunch per day). Each greenhouse has its own canteen where lunch is provided to staff. As part of the Fairtrade requirements, a kitchen to prepare warm lunches is on site. Each greenhouse is also equipped with a nursing room with a full-time nurse and can be accessed by all employees at no cost. There is also a clinic in each greenhouse and a medical doctor comes to the facilities once a week. There are no lactation rooms on site, but women are granted one hour for their children. As part of the Hicha II project, the company is planning to build a kindergarten to be accessible by all employees; one was built and is in operation at the project Desert Joy. Based on the design of project facilities, Hicha II will include separate changing rooms and showers for male and female workers with controlled access in each greenhouse.
Child Labor / Forced Labor
The HR policy explicitly prohibits forced labor and child labor in the facilities. As part of the Fairtrade certification, the company only employs workers who are older than 18 years of age with ID controlled at the moment of hire. Hicha Joy requires contractors and sub-contractors to adopt a Code of Conduct which includes clauses to refrain from using child labor. The HR policy does not prevent workers from establishing or joining a union at the site. Currently for Hicha I, there is a Workers Committee (WC) which is composed by six elected members for a three-year tenure basis and has a full representation of the different parts of the workforce. The WC meets monthly and every two months with the company’s CEO. Minutes of the WC meetings (with outcomes and actions to be taken) are posted and accessible to all employees in a specific location in the greenhouse facility. As part of the Fairtrade certification, there is a Premium Committee is composed by five members (three members are female) elected for a period of one year. The main purpose of the committee is to manage the Fairtrade Premium received for the benefit of workers. The committee also receive trainings on communication and bargaining skills from Fairtrade. The same committees will be established for the Hicha II project.
Grievance Mechanism
The HR policy allows all workers (both permanent and seasonal) to lodge a complaint to an advisory committee. Specific provisions for GBVH grievances are also included in the policy. As per ESAP #4 of the project, the company will enhance its internal grievance process to meet PS2 requirements. This will include, but not be limited to, i) a procedure that ensures accessibility to all workers, including the possibility to lodge a complaints via different channels (i.e. suggestion boxes on site, setting up a hotline/social media account or unions); ii) a process to document, track and manage resolution; iii) allowing for anonymous complaints to be raised without any fear of retaliation; iv) set up a series of documented training/informative sessions to explain the purpose of the grievance mechanism; v) enhance data protection and confidentiality for female workers aiming to lodge complaints. The HR department will also set up and roll out regular training sessions on the new grievance mechanism and its procedures, including the provisions relevant to addressing GBVH targeting all direct and contracted employees.
Workers Accommodation
Given on-site worker accommodation facilities are not permitted within the project concession, all workers and staff will be accommodated within the nearby urban settlements. It is anticipated that most of the workers during the construction will come from and be accommodated in the nearby villages of Hicha (about a mile away), Metouia (6 miles), Akarit (2 miles) and Ouedherf (4 miles). The EPC contractor for the desalination plan will be also lodged in Hicha or in some cabins outside the project site. Expected impacts of non-local worker influx into the communities include i) increased pressure on local resources and social services; ii) GBVH-related risks and iii) increased incidence of communicable diseases. The company will require the EPC contractor to develop a construction worker accommodation plan in line with the IFC/EBRD Guidance Note on Workers Accommodation. The company will undertake a risk assessment of the construction workers’ accommodation options in line with the same Guidance Note and will undertake audits prior to occupancy and on a quarterly basis thereafter during construction activities (ESAP #5).
Occupational Health and Safety
Construction of all project’s facilities will be undertaken under an EPC Contractor with contracted and third party workers. The company will employ a main contractor for the construction of the eight greenhouses; for the construction of the desalination plant, two contractors (one for the offshore and one for the onshore component) will be employed throughout the entire construction phase (14-18 months). Hicha Joy currently has an Occupational Health and Safety plan for construction and operation phase which provides details on the main risks and mitigation measures to be implemented. As per ESAP #6, the company will assign a dedicated EHS officer to be responsible for the oversight of the overall OHS performance of the contractors and undertake regular inspections during construction and operations. The company will also require all contractors on site to have at least one EHS officer whose responsibilities will include i) identification of risks and hazards; ii) providing regular EHS training and sensitization sessions; iii) set up rules for personal protective equipment (PPE) requirements and housekeeping. The EHS officer will be also responsible to collect, develop and analyse OHS statistics to report on performance to company management on a regular basis.
In operations, the main EHS risks in greenhouses for workers are related to handling of pesticides and exposure to chemicals, improper handling of equipment and machinery parts and potential exposure to heat. Transport of product - to port for shipment will utilize the existing road network in place in Tunisia. Traffic during operations will be limited to a maximum of 3-4 trucks per day, given some seasonality in production. The company will develop project OHS procedures and practices aligned to ISO 45001 that will be inclusive, but not limited to i) an OHS policy; ii) an OHS management plan; iii) permit to work systems; iv), operational transportation route risk assessments; v) journey management; and (vi) procedures for incident management, reporting and investigation. The OHS procedures will include a risk assessment matrix to identify types of hazards, likelihood of risk, and how to mitigate the risk through a combination of design measures, hazard signs, employee training on hazards, and use of PPE (such as gloves, face mask, and rubber boots). Procedures will reflect steps to follow in case of an accident or injury, including documenting the occurrence of the injury and corrective measures to prevent reoccurrence, and tracking them on a regular basis. The procedures will be part of a training plan, refreshers and ongoing training that will be implemented to all workers in the project (ESAP #7)
PS 3 Resource Efficiency and Pollution Prevention
Resource Efficiency
IFC’s visits to Agro Care’s existing operations in Tunisia allowed IFC to see examples of how the company has implemented technically and financially feasible and cost-effective measures to improve efficiency in its consumption of energy, water, as well as other resources and material inputs (such as fertilizer use) within its core business activities. Tomatoes are grown using drip irrigation to minimize water use. Fertilizers are mixed into this irrigation water, resulting in fertigation, which is applied directly into the growing medium where it is most efficiently used by the plants. The growth medium is coconut coir which favors water retention, thereby helping to reduce water consumption. Any drainage from the growing medium is recycled into the irrigation system for re-use. Likewise, any wastewater generated through washing the tomatoes prior to their being packed is returned to the process. Plants are grown using natural light, with no need for artificial illumination.
Greenhouse Gases
As noted above in the Scope of Review section of this document, Harvest House commissioned a Lifecycle Assessment of the existing Desert Joy operation, to compare overall impacts associated with cherry tomato production in Tunisia as opposed to those grown in the Netherlands. Results showed Tunisia has a considerably lower impact as growing the same amount of product in the Netherlands (the main drivers of the Product Environmental Footprint were energy, fertilizers, transportation, and water use.) due to warmer weather and less energy needed to be consumed. For the Netherlands, the results were 7.75 kg CO2-eq per KG of product; for Tunisia, after the project is in operation, the lifecycle emission intensity is estimated to be ~1.9 kg CO2eq. Using these figures, the total CO2 eq for Hicha II production (12,500,000 kg/year, using production rates of 250 ton/ha) can be estimated at 23,750 tons CO2-eq/pa. Adding the estimated emissions from the desalination plant (~1,691 tCO2e/year), the project’s total emissions are estimated to be ~25,441 tCO2e/year.
The proposed natural gas fired CHP plant has yet to be finalized in terms of size; as noted above, the current plan is for the installation of a 10MW-capacity plant. The proposed CHP plant has been assessed by the company as the most efficient means to provide the required inputs for tomato production: heat (for the months when the local weather is too cool to support an ideal growth temperature in the greenhouses), electricity (to power all necessary equipment in support of production and associated activities) and CO2. The latter is captured using a flue gas cleaner and is used to enrich the air inside the greenhouses to stimulate CO2 uptake and hence the growth rate of the plants. The use of CHP plants in Dutch horticulture has become commonplace in the last few decades, replacing natural gas boilers to heat the greenhouses, as they are more efficient and generates less GHG emissions.
The proposed gas-fired CHP plant will be designed to meet the emission levels of the WBG General EHS Guidelines for NOx and to comply with Tunisian law/regulation as it pertains to such equipment, whichever is more stringent. Results from monitoring of emissions will be submitted as part of the annual monitoring report required for this investment.
Water Consumption
The project will not impact the scarce local water resources as the supply of irrigation water will come from sea water that is to be desalinized. Indeed, whereas Hicha I (not being financed by IFC) currently uses boreholes to supply its irrigation water needs, once complete, the desalinization plant will have sufficient capacity to supply both Hicha I and Hicha II (the latter being the project financed by IFC) so the boreholes will no longer be required. The project will draw sea water through a 3.5 km long pipeline into the desalinization plant. Water needs are estimated to be the order of 1,500 liter/m2/year. This is in line with general industry standards for this type of crop and the mode of production to be employed. Daily, this equates to 0.004 m3/m2/day or 4,932 m3/day for the entire 122 ha associated with both Hicha I and II, which will be served by the desalinization plant. Therefore, for Hicha II, the amount would be ~ 2,021 m3/day.
Pollution Prevention/
Wastes will be generated both during construction and operation of the Hicha II project. Typical construction activities of land preparation, trenching, driving piles for foundations, metalwork for the greenhouses and the construction of warehouses and other ancillary structures, installation of equipment and equipment packaging wastes, etc. can all result in solid and/or liquid wastes, and airborne dust and other particulates. Measures to avoid or reduce impacts are included into the waste management and environmental management plans developed for existing operations.
The discharge of brine from the desalinization plant was modelled as part of the ESIA. Those results contributed to the design of the diffuser to maximize the dispersion of the brine, with respect to the size, placement and direction of the orifices through which the brine will be released. Salinity rapidly falls from 77 psu to approximately 2 psu above baseline (39-40 psu) within approximately 5 meters of the diffuser, and from there gradually falls to less than 1 psu above baseline over 360 m and 0.5 psu over 700 meters. Seagrass beds, the benthic community, and fishes will all be monitored during operations and if mortality of seagrass or changes in the benthic or fish community is detected then brine will be further diluted with sea water before discharge, following the Brine Discharge Monitoring Plan.
Organic wastes from production activities include pruning wastes, waste green tomatoes, waste from substrate used to grow the tomatoes, food wastes from the canteens; such are either provided to local farmers for animal feed or composted and provided to local farmers to improve the quality of their soils. Industrial wastes from maintenance and cleaning activities including batteries, scrap metal, cans, lubricants, oils and oil filters, are separated, suitably stored and disposed of by licensed waste disposal companies. Plastics, paper and cardboard, etc. are recycled.
The management of hazardous material and wastes was seen in practice at the Desert Joy and Hicha I operation and it is described in the waste management plan, the environmental management plan and a hazardous materials management plan. Procedures therein include refuelling vehicles (from fuel storage in a bunded tank), storage of waste oils (until collected by a local company that recycles the wastes) and management and disposal of e-wastes.
Pesticides Use and Management
Production norms in the existing operations utilize integrated pest management. Biological crop protection and use of insects or agents of natural origin are the first line of defense. Application of pesticides is limited to instances whereupon a failure to address pests would lead to financial impacts to operations. Such an approach, evident in Agro Care operations visited by IFC, and confirmed by the certification to the Fairtrade standard, will be replicated in Hicha II as standard practice, as will the training of operatives in the safe storage, handling, mixing and application of pesticides only when absolutely required and the appropriate disposal of spent containers as guided by those procedures already in existence at ongoing operations. Hicha II will not use WHO class Ia or Ib pesticides.
PS 4 Community Health, Safety and Security
The Project is in an isolated and deserted area located close to the Gulf of Gabes. The nearest villages are located more than 2 miles from the project location.
Around 40 fishermen and 80 fisherwomen are located at less than 10 km for the project site and involved in some local scale fishing activities in an area close to the site selected for the landfall of the pipes of the desalination plant. Main risks during construction will be the disruption of fishing activities due to the works, disruption of livelihoods and possibility of incidents among the contractor with local fishers. Dredging and trenching activities for the pipes required by the desalinization plant can have negative impacts on the marine environment and the species that depend upon it, and upon those local community members who exploit those or other marine resources as part of their livelihoods. Currently, it has been observed that some people from other areas do fish near the project site, namely beach seiners from Ghannouch. As part of ESAP #8 , the project will prepare and implement a community health and safety plan, which will include measures for preventing incidents involving fishers in the project area during offshore construction. The plan will set up a monitoring framework to assess the potential influx of other fishermen in the project area.
Transportation Plan
Hicha Joy has implemented a detailed traffic management plan that controls and minimizes traffic impacts related to produce truck delivery and work transportations. The company provides various transportation options for their workers depending on their grades (bus services for seasonal workers and short-term employees; car services for open end employees). A traffic manager reporting to the HR manager oversees the hiring of drivers and fleet planning. Workers employed in night shifts are allowed to use their own transportation and are compensated with a lump sum payment according to the distance from their residence to the site.
During construction at Hicha II, each contractor and subcontractor will be required to ensure that all drivers follow traffic rules and provide awareness training as currently provided for in Hicha Joy’s traffic management plan. The project will enhance the existing Desert Joy traffic and transportation management plan to ensure construction activities at Hicha II are in line with GIIPs. The plan will include i) a driver safety procedure, consistent with GIIP; ii) journey management monitoring, supervision, and audits; iii) defensive driving; iv) incident investigation v) reporting indicators. The plan will require contractors to provide transportation for the workforce on site to reduce risks of accidents with third party vehicles. Hicha II will extend its traffic management plan to contractors in order to screen subcontracted drivers prior to hiring, including verification of valid driver license and past driving record; provide driver safety training to respect speed limits, not use a cell phone while driving, use of a fire extinguisher, and vehicle maneuvering skills; procedures for limiting trip duration, duty roster to avoid overtiredness, avoiding dangerous routes and times of day to reduce the risks of accidents, use of speed control devices on vehicles; inspection of vehicles after each delivery for any evidence of having been in an accident; and overall truck maintenance to ensure good working conditions (ESAP# 9).
Food Safety
The design and lay-out of the greenhouses at Hicha II will integrate the principles and practices of Hazard Analysis Critical Control Points (HACCP) to reduce the risks related to hygiene and food safety. Current practice (at Desert Joy) is that tomatoes are cleaned and sorted in boxes and shipped via truck and then sea, ultimately arriving in company packing premises. Customers require that the tomatoes supplied by Agro Care are certified to relevant global standards regarding quality and food safety, as noted above.
Security Personnel
Hicha II’s facilities will be provided with unarmed security personnel, as is the current practice at Desert Joy. The company will prepare and implement a detailed induction program on Voluntary Principles on Security and Human Rights for all the security personnel. The program will also include how to manage relations with community members and with fishers that perform their activities at night. (ESAP #10).
PS 5 Land Acquisition and Involuntary Resettlement
No land acquisition risks are envisaged for the construction of the project facilities. In 2021, the company entered into a 25-year lease agreement for an area of 200 ha with the Government of Tunisia obtained through a public tender process. The land was on the eminent domain in the name of the Government of Land Affairs, General Directorate of Agricultural Land and no economic activities were present on site at the time of the agreement. All project related activities will take place in the area leased by the company. Since 2022 the company has engaged with the fishing communities on the various stages of the project and potential impacts on the fishing activities in the area.
The project may generate economic impacts on fishing activities conducted in areas offshore of the project. Until its ban by the Tunisian Government in 2018, the shoreline adjacent to the project area was used by women involved in mollusk (clam) fishing. Since the fishing ban, around 80 fisherwomen have changed to handpicking polychaetas to be used as fishing bait. The activity has been observed in adjacent areas to the project area, which is however not used for this mainly informal activity and is not regulated.
As indicated under PS4, another group of fishers involves 40 fishermen, using 27 vessels, that are involved in some local scale fishing activities in an area close to the site selected for the landfall of the pipes of the desalination plant. Fishing activities will be potentially impacted during the construction phase, especially during the net fishing phase in the winter season.
As per ESAP #11, Hicha II will conduct an assessment on the potential interactions with current fishing activities, including informal mollusk gathering. The assessment will include i) a description of the physical environment; ii) description of the socio-economic issues related to the informal fishing activities; iii) target fish and fishing routes per seasons; iv) fish trading, revenues and expenditures; v) economic analysis of the fishing activities; vi) potential impacts during construction and operations; vii) planned mitigation measures and viii) monitoring requirements.
Based on the findings of the assessment, and as per ESAP #12, the company will develop and implement a fishing community action plan in line with PS requirements to mitigate and enhance potential impacts. The plan will also include a targeted action for the women involved women handpicking activities.
PS6 Biodiversity Conservation and Sustainable Management of Living Natural Resources
Protection and Conservation of Biodiversity
The project is located on the coast of the Mediterranean in the Mediterranean dry woodlands and steppe ecoregion. The upland terrestrial landscape is halophytic steppe, a sparsely vegetated dry ecosystem. The coastal zone is partially unvegetated saline coastal plain (sebkha), salt marsh, and intertidal mudflat. The adjacent marine area includes some areas of seagrass beds and their associated benthic community. Threats to the terrestrial area include unregulated grazing and uncontrolled solid waste disposal. The marine area is impacted by fishing activity.
The project area partially overlaps with the Sebkhet Dreiaâ Key Biodiversity Area (KBA), a terrestrial and marine area, established under the criteria for Important Bird Areas for migratory bird species. The project also includes the installation of seawater intake and brine discharge pipes that traverse a marine (intertidal mashes) Ramsar site that is also a national protected area named Complexe des zones humides des Chott El Guetayate et Sebkhet Dhreia et oued Akarit Rekhama et Melah. The project has completed an environmental review and has received permission from the authority that manages this area, Agence de Protection et D'Amenagement du Littoral (APAL)
A Critical Habitat Assessment was completed for the terrestrial and marine areas of the project and it is disclosed together with this ESRS. The project is sited entirely in terrestrial and marine Natural Habitats, some of which qualify as Critical Habitat. Twenty-five hectares of the two-hundred-hectare terrestrial footprint qualifies as Critical Habitat for Kentish Plover (Charadrius alexandrinus) and Grey Plover (Pluvialis squatarola). The marine area is Critical Habitat for at least eight species of cartilaginous fishes, a coral (Cladocora caespitosa), fan mussel (Pinna nobilis), the European Eel (Anguilla Anguilla), and seagrass beds of Posidonia oceanica, which are endemic to the Mediterranean and a regional and national priority for conservation.
The terrestrial footprint will largely occur (198 hectares) in halophytic steppe, a common habitat in the region. It will also include 2.5 hectares in sebkha (partially unvegetated saline coastal plain). The marine habitat footprint caused by trenching includes 12.1 hectares of soft sediment and 2.9 hectares of seagrass beds (1.3 ha of Cymodocea nodosa and 1.6 ha of Posidonia oceanica).
Marine impacts from the project’s construction will be minimized through trenching techniques designed to control the width of the trench and the suspension of sediment that could settle beyond the area of construction. The marine construction sub-contractor will develop a Marine Construction Environmental Management Plan prior to beginning work (ESAP #13). The plan will include environmental controls necessary to avoid and minimize suspension and dispersion of sediment during construction of the seawater intake and brine discharge lines, as well as measures to minimize disturbance to coastal birdlife. The plan will include quantitative performance indicators, such as acceptable limits of suspended sediment. Marine impacts during operation will be minimized through appropriate brine discharge controls from the desalination plant and ongoing monitoring of the health of seagrass beds, benthic communities, and fish communities (including all species for which Critical Habitat is designated), as noted in the PS3 section. If brine discharge has a significant negative impact on these receptors, brine will be diluted prior to discharge to reduce salinity. The company will restore seagrass beds disturbed by trenching, based on a method developed by the University of Sfax for a Posidonia oceanica restoration project at nearby Djerba island following a Seagrass Restoration Management Plan. The company will restore temporary coastal/terrestrial impacts following a Coastal Restoration Management.
The company will achieve a Net Gain for terrestrial and marine Natural and Critical Habitats, and in so doing will support the improved management of the Important Bird Area, Ramsar site and national protected area. The Biodiversity Action Plan (BAP) (including a quantitative loss-gain analysis) and Biodiversity Monitoring and Evaluation Plan (BMEP) are disclosed together with this ESRS. Actions to achieve a Net Gain for the marine environment include: a) installation of artificial reef structures to facilitate seagrass meadow establishment in the broader area (with quantitative additionality metrics); b) support for research on impacts and best practices for bait collection in the intertidal zone; c) support research on Blackchin Guitarfish; d) support research on Fan Mussel; and e) support environmental education on conservation of the inter-tidal zone. Actions to achieve a Net Gain for the terrestrial environment include: a) creation of bird nesting and foraging habitat within neighboring wetlands (with quantitative additionality metrics); b) restoration of degraded halophytic vegetation in the KBA (with quantitative additionality metrics); c) support for coordinated monitoring of Kentish Plover; d) support for reducing non-natural predation risks and enhancing nesting success for priority bird species; e) supporting development of a management plan for the Ramsar site; f) solid waste removal in the coastal zone in coordination with NGO partners; and g) support for environmental education on conservation of the area. ESAP items # 14, 15 & 16 will support implementation in alignment with PS6.
