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
At a corporate level, AMEA Power has developed a set of policies, including quality, Health and Safety (H&S), gender equality, security, and environmental and a social sustainability, which outlines the sponsors commitment to quality, the prevention of injury, ill-health, limiting pollution of the environment, and compliance with applicable statutory and regulatory requirements. These policies apply to all AMEA projects, including this project. AMEA Power has also developed an Integrated Management System (IMS) which is certified to ISO 9001:2015 (Quality), ISO 14001:2015 (Environment) and ISO 45001:2018 (Occupational Health and Safety “OHS”) since April 2021.
As part of its corporate ESMS, AMEA assesses and manages E&S risks and impacts through an E&S risk and impact assessment procedure that sets out the minimum requirements for managing risks and impacts during different phases of any project; and a risk assessment methodology that allows to identify and manage OHS risks, hazards and impacts. Given the numerous other solar plants and OHTLs in the vicinity of AFRE, including the OHTL to be built for the project by EETC, AFRE will develop and undertake best efforts to implement an Interface Management Plan to coordinate with other developers and EETC, so as to maximize positive impacts and minimize E&S negative impacts (ESAP#1).
At the project level, AFRE has a number of approved E&S policies (including an environmental policy, a quality policy, a H&S policy, a social sustainability policy, a security policy and a gender equality policy statement). All these policies include the identification of responsible parties for compliance and are in line with IFC PS1. The project also commits to undertaking business activities in line with international standards (such as ISO 9001, ISO 45001 and 14001) and in compliance with National Laws and Regulations.
As per AMEA policies, the EPC contractor is required to produce a project specific ESMS manual together with an ESMP with subject specific plans and procedures including all the required elements in line with IFC performance standards (e.g., contractor and supply chain management plan, site mobilization plan, occupational H&S management plan, Emergency Preparedness and Response Plan (EPRP), community H&S, a worker influx plan, traffic and transport management plan, GBVH management plan, employment and procurement management plan, among others). These project specific management plans will be developed by the EPC Contractor based on AFREs ESMS manual and the project’s ESIA and RCIA prior to the start of main construction (ESAP #2). AFRE will also be required to develop operational phase ESMP plans and related procedures prior to the start of operations (ESAP#3).
An ESIA and RCIA in line with IFC PSs were undertaken in the second half of 2024. Four Valued Environmental and Social Components (VECs) were identified for more detailed assessment, as part of the RCIA i) water resources; ii) waste disposal; iii) traffic and transportation, and iv) worker influx. Overall, the RCIA concludes that the impacts will not be substantial and that with the correct implementation of mitigants, the project will not result in significant impacts on the identified VECs. Both the RCIA and the ESIA will have a final round of community consultation during April/May 2025.
AFRE’s E&S organizational structure for the project will include an HSE Manager, an HSE Specialist, an HSE Engineer and a Social team (composed of a Social Manager supported by a Social Specialist, a Labor Compliance Officer and two Community Liaison Officers). The HSE team will be responsible for overseeing and managing the EPC Contractor’s activities. AFRE’s E&S team will be overseen by AMEA corporate Head of ESG and corporate solar E&S Coordinator. At the EPC Contractor level, the HR Manager and Social Specialist have been retained from Abydos I, however the remaining members of the E&S team have not yet been appointed. AMEA will recruit a suitably qualified Labor Compliance Officer and contractually require the EPC contractor to put in place an E&S organization consisting of qualified personnel with appropriate responsibility allocation to implement/oversee/monitor a) the implementation of the ESMP; b) community engagement and grievance redress system/mechanism; c) performance of contractors on labor and health & safety aspects; d) regular training of employees and contractors; e) emergency preparedness and response; f) periodic monitoring of social and environmental performance; (g) internal and third party audit; (h) management review; and (i) periodic reporting of E&S performance to the management (ESAP#4).
A draft EPC training plan was reviewed as part of the ESDD, which provides the requirement for a project site induction, specialized training (including First Aid, harassment prevention, GBV prevention, and other OHS topics). As per ESAP#2&3, the project will update the training plan to include all required E&S topics to effectively cover anticipated E&S risks and impacts.
AMEA possess several corporate procedures including control of records, inspection management, accident and incident management, lessons learned, Quality and HSE Audit Management and reporting requirements for each of these procedures. The project ESIA sets some monitoring and reporting requirements for the project including air quality, noise, water consumption, traffic, worker welfare, community H&S, E&S contractual controls and subcontractor management. Similarly, the project’s ESMS identifies the HSE and security reporting requirements that will be undertaken for the project throughout the construction and operation phase including a list of Key Performance Indicators (KPIs). The project will update their EHS aspects monitoring tracker prior to the commencement of construction to capture additional KPIs and monitoring parameters, not already included within existent EHS plans. The project will also keep an environmental register, an incident register, a hazardous waste and substances register and include air quality, noise, heat stress, waste management, wastewater management and emergency response planning, among others (ESAP#2&3).
PS2: Labor and Working Conditions
AMEA HR Policies and Procedures include commitments that are in line with IFC PS2 and national legislation including non-discrimination and equal opportunity, gender equality, GBVH, worker organizations, child and forced labor and a worker grievance procedure. The project ESMS manual that is being finalized echoes this commitment whereby AFRE commits to adhere to the principles of IFC PS2 as listed above. For the project, the People policy will clearly state the maximum number of working hours per week and the minimum rest days per week as per National Law to ensure that all parties involved in the project adhere to the working hours allowed. AFRE will undertake quarterly audits to ensure this policy is adhered to (ESAP#5).
AFREs Labor Code of Conduct (LCC) is in line with IFC PS2. The LCC provides the working conditions and workers’ rights based on good practices and ILO standards including demobilization, retrenchment, provision of contracts, working hours, annual leaves, wages and Personal Protective Equipment (PPE) requirements. As per ESAP#6, the LCC will include a monitoring procedure for Child and Forced Labor, Supplier Code of Conduct, Worker Grievance Mechanism, Gender Equality policy and People policy, which will be translated into Arabic language and communicated to all project workers.
At the project level, a Labor and Working Conditions Management Plan and Local Supply Chain Management Plan have been developed building on AMEA’s experience with Abydos I. The plan covers employment terms, non-discrimination, local hiring and termination, working hours and compensation, grievance mechanism, retrenchment and welfare provisions. The project has also developed an Employment and Procurement Management Plan to establish a systematic and transparent approach to hiring qualified candidates as well as acquiring goods and services by the EPC. According to ESAP#7, Employment and Procurement Plan will be updated to include provision for compliance to be above minimum wages, as well as establish a process for recruiting and registering casual labor in compliance with Egypt’s labor law and as per the new legal updates in March 2025.
The project will accommodate non-local workers in the surrounding urban centers. The Project will develop a Labor Accommodation Management Plan (LAMP) in line with IFC/EBRD Worker Accommodation Processes and Standards. The LAMP will define the roles and responsibilities of the project social team in overseeing the implementation of the plan and auditing third party accommodation, as well as the roles and responsibilities of the EPC to undertake regular inspections (ESAP#8). It’s anticipated that the peak manpower will be around 4000 workers that will require to be transported and/or accommodated. The LAMP will be based on a robust accommodation needs assessment taking into consideration AFRE’s commitment to hire local labor (ESAP#9).
All contracts will have a specific duration of employment for the construction phase. Therefore, no retrenchment is foreseen for this project but rather demobilization at the end of the construction. Prior to the completion of the construction phase, AFRE will develop a demobilization plan including appropriate measures for reducing the workers from approximately 4000 to around 90 workers for the operation and maintenance phase. The plan will include the provision of demobilization sensitization measures throughout the project life cycle to reduce social impacts; manage labor compliance; and minimize risks on the community, as a result of large scale demobilization (ESAP#10).
AFRE has developed a Worker Grievance Mechanism Procedure (WGM)aligned with IFC PS2 and will update its WGM procedure to include a dedicated channel for reporting and addressing incidents of GBVH.
As per ESAP#7, The project will be required to recruit numerous local subcontractors in line with the Employment and Procurement and Local Supply Chain Management Plans, the project will update these plans to ensure their employment and procurement strategy adequately considers the local context and is adhered to, including providing transparent feedback (in line with the mentioned strategy) to unsuccessful candidates In addition, AFRE will undertake a) an assessment of preparedness of the project to engage and manage labor (before the start of main construction); and b) a mid term review of labor and working condition through an independent party, to assess progress and compliance with PS2 requirements, ESAP#11.
AMEA undertakes the contracting of the EPC in line with IFC PSs requirements. AMEA does not procure PV panels or BESSs directly but requires the EPC to procure the PV panels and BESSs. AMEAs Responsible Sourcing Policy, Supplier Code of Conduct and more recently its Supply Chain Risk Management Procedure (SCRMP) establishes minimum requirements for identifying and managing supply chain risks and impacts to protect the sponsors reputation and ensure compliance with legal and ethical standards.
The supplier Code of Conduct (CoC) is aligned with IFC PSs as well as AMEAs responsible sourcing policy, which requires full adherence to both host country regulations and internationally recognized standards. The (SCRMP) clarifies how supply chain risks are managed including how i) supply chain mapping is undertaken; ii) Reputational Risk Reviews (RRRs) are undertaken (covering relevant risks such as forced labor, child labor, and working and labor conditions); and iii) how the required follow-up assessments are implemented, including monitoring of the supply chain to track the effectiveness of due diligence and risk management measures undertaken. The results of the RRRs are shared with the EPC contractor and suppliers who are asked to provide their responses to any allegations raised, which must be formally submitted (i.e., in writing and using official business letterheads). In addition, all short-listed suppliers are requested to provide a list of key component sub-suppliers, to verify their geographical location and assess potential supply chain risks.
The PV and BESS suppliers are also required to sign a forced labor declaration form to comply with the sponsors supply CoC and ESG standards. Similarly, key component sub-suppliers are also required to sign the same forced labor declaration form to confirm that all contracting practices are in accordance with the local laws and international labor standards. AMEA reserves the right to terminate its contracts with any suppliers that repeatedly do not comply with the material obligations of the CoC.
As per their SCRMP, AMEA will require for their EPC suppliers (i.e., PV panel and BESS suppliers) to engage an independent, reputable and experienced third-party consultant, to conduct an audit of their respective supply chain. This audit will be undertaken to verify labor and working conditions’ compliance with the local regulations and international best practices. The audit report and any suggested corrective actions will be made available to IFC (ESAP#12).
The project will identify, assess and include PV panel and BESS specific OHS risks into their OHS Management System and related OHS training requirements, as per ESAP#2&3. Risks from fire, explosions, battery rupture hazard, exposure to toxic gas (e.g., from battery fire etc.,) will be considered.
As per ESAP#13 the project will strengthen the existing pre-employment medical screening program by identifying additional medical fitness evaluations, based on Project specific risks and lessons learned from the Abydos I and Abydos 1 BESS. Fit for purpose fitness tests will be undertaken by suitably qualified third-party medical service providers, in addition to government mandatory health screening to all project workers.
PS3: Resource Efficiency and Pollution Prevention
During construction, diesel will be the primary source of energy for the project and will be supplied from available fuel stations in the region.
The Project will rely on municipal water from New Aswan Governorate for its water needs. The ESIA estimates the water needs for the construction phase to be around 400 m3/day while an estimated 60m3/day during the operation phase. AMEA will employ dry cleaning technologies for the PV solar panels. The project will develop a water management plan (refer ESAP#2 and 3) to manage and monitor its water consumption sustainably including training, KPIs, roles and responsibilities and water quality monitoring
The project construction phase is expected to generate point source air emissions and fugitive emissions due to the use of various equipment, machines and trucks as well as the dust generated by these vehicles and equipment. The same activities will have an impact on noise emissions during construction. At appraisal, no stationary sensitive receptors were detected. The project will develop an air quality and dust management plan, soil and drainage water management plan (refer ESAP#2 and 3), in line with WBG EHS General Guidelines and PS3.
The ESIA estimates the project GHG emissions to generate approximately 3,100 GWh of electricity per year displacing 1,258,256 tons of CO2e annually. The project is expected to result in saving 29,450 tons of CO2equivalents and 20,150 tons of CO2eq during operation.
The project is expected to generate construction waste, municipal solid waste and hazardous waste including broken or less efficient PV panels. The amount of solid waste expected to be generated will be around 3000 kg per day at the peak of construction, and 45 kg/day during operations. Municipal non-hazardous waste will be transported to Alaqi municipal landfill which was previously used by Abydos I. The estimated hazardous waste per day will be around 20 kg/day during construction and 12kg/day during operations, which will be transported to a hazardous waste disposal facility that will be licensed and approved by EEAA.
The construction phase of the project is expected to generate sanitary wastewater c. 160m3/day which will be discharged into PVC holding tanks. The project will hire a licensed contractor to collect and discharge wastewater at the New Aswan Municipal wastewater treatment facility.
AFRE will require its EPC to develop a waste management plan defining roles and responsibilities and some management and monitoring measures for waste including prohibition of waste disposal to land, maintaining proper housekeeping and maintaining waste manifest forms. The plan will cover collection, transport, storage, emergency response, community awareness training, monitoring and reporting of non-hazardous and hazardous waste management measures. The plan will also outline storage specifications, leakage prevention and clean-up, maintaining material safety data sheets MSDS) and a non-hazardous and hazardous materials register. Similarly, the plan will include an estimation of waste quantities per waste stream, waste tracking, training; KPIs, roles and responsibilities, monitoring and reporting. AFRE will establish a main waste collection, segregation and storage area on site. This waste area will also include a secure hazardous waste storage area. The design of the hazardous waste storage area has not yet been determined; however the project will ensure it is sheltered, impermeable, well-ventilated and has restricted access. The project will also investigate waste reduction by using industrial compactors. AFRE will contract licensed and certified contractors for waste disposal to a licensed and certified facility. Based on documented engagement with EEAA and if legally required, the project will develop a separate EIA for the waste, collection, segregation, compaction and storage area.
Batteries can generate pollutant emissions such as Polychlorinated Biphenyl (PCBs) or Ozone Depleting Substances (ODSs). AMEA will require the Original Equipment Manufacturer (OEM) to confirm in writing that the BESS does not include PCBs or ODSs. The Original Equipment Manufacturer (OEM) of the PV panels and BESS will provide written confirmation regarding decommissioning, disassembly, packaging and safe transport to the designated recycling sites, including recycling and disposal according to the state of the art of technology. AFRE will hire a decommissioning entity to prepare an E-Waste Management and Disposal Plan evaluating all recycling options and ensuring the adequate management of e-waste during construction, operation and maintenance, decommissioning recycling and/or disposal (refer to ESAP#2&3).
PS4: Community Health, Safety and Security
The ESIA identified community H&S risks and impacts including trespassing of unauthorized personnel during construction and operation; and potential impacts from working influx during construction (e.g., pressure on infrastructure, services and utilities; local health centers; local economy; risk of diseases; inappropriate conduct; and elevated crime rates).
In alignment with WBG EHS General Guidelines, IFC PS4 and National Legislation, the project has drafted a Community Health and Safety and Influx Management Plan (CHSIMP) outlining strategies and responsibilities required to manage community H&S and worker influx during the construction phase. The CHSIP will be updated to include roles and responsibilities in overseeing the implementation of this plan, the mitigation measures that have been stated in the ESIA as well as how the project intends to prevent worker influx impacts. The CHSIP will also include in its introduction, a summary statement on the expected number of local, national and foreign workers to be hired for the project and how it will evolve over time (ESAP#2-3).
The project has drafted a Traffic Management Plan (TMP), a Security Management Plan (SMP) and EPRP which aim at managing community H&S risks and impacts related to the project. The project has also developed a labor code of conduct instructing workers to respect communities and behave respectfully. Going forward, the TMP will be updated to address traffic accidents resulting from the transport of non-hazardous and hazardous materials. The EPRP and the labor code of conduct will be communicated to the surrounding community in their own language (ESAP#2&3).
The ESIA identifies several security risks and impacts including impacts related to trespassing and the presence of security personnel, including inappropriate management of security issues and inadequate use of force. The SMP lists several mitigation measures including fencing, installation of CCTV cameras, the presence of unarmed security guards, screening of security personnel, and training on adequate use of security force. The project will update the SMP in line with IFC PS4 and IFC Good Practice Handbook on the use of Security Forces, Assessing and Managing Risks and Impacts (ESAP#2&3).
The ESIA also assessed the potential impacts of the project on road networks during the construction phase including the principal sources of traffic, the maximum number of daily container delivery, as well as an estimated number of transport and delivery vehicles. The project will use in Sukhna Port to deliver all imported equipment, which is at least 984 kilometers away from the project site. As per ESAP#2&3, the TMP will be updated with a traffic route assessment that will be conducted to select the best transportation route considering Community H&S. Similarly, the project will conduct an awareness campaign targeting the communities of Daraw town, and the village of Raqaba to ensure they are aware of the project mitigation measures such as traffic signage, speed limits and contact information of the project liaison officer to address any issues. The project will also implement transportation protocols including car inspections and the preparation of journey management plans.
The project has developed a project-specific EPRP identifying an emergency response procedure to ensure safety of workers and property within the project site. The EPRP outlines risks such as fire, accidents, spillage, traffic accidents, natural disasters and others, explaining emergency scenarios, procedures to address a range of potential emergencies and guidelines on pre-emergency planning, hazard identification, risk assessment and preparedness measures. The EPRP will be updated to include information on emergency scenarios involving communities, information on the communities that may be impacted by the project emergencies and the communication procedure to be followed regarding emergency situations affecting local communities. (ESAP#2&3)
PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources
The project is located adjacent to an existing highway, in the South Sahara Desert Ecoregion. The habitat consists of rocky, gravel desert hills, alternating with furrow-like sandy depressions, which are vegetated with a few species of thorny subshrubs.
An ESIA, including baseline studies of the solar project area (e.g. vegetation, mammals, avifauna, reptiles and invertebrates) have been completed, and an ESIA Addendum (aligned to IFC PSs) will be developed for the associated OHTL. IFC conducted additional screening using tools including the Integrated Biodiversity Assessment Tool (IBAT) which confirmed that the project is not situated within, nor in proximity to, protected areas or internationally recognized areas, and flagged the regional occurrence of three threatened soaring raptors – potential impacts on these species will be assessed in the OHTL ESIA addendum.
The ESIA baseline states that more than half of the area surveyed was degraded and supported low species diversity. The project area is a mix of natural and modified (in proximity to the highway) desert habitat, typical of the vast South Sahara region. One threatened plant species, which has not yet been evaluated by the IUCN Red List but has been independently assessed by species experts as endangered, was confirmed in the vegetated sandy depressions during baseline surveys, as were some caves with potential to support roosting bat species. Discussion with the plant species expert confirmed that the individuals observed on site do not constitute a nationally/regionally important concentration, thus the area does not meet thresholds for Critical Habitat for this (or other) species. AFRE will consult with relevant species experts and integrate any conservation recommendations together with the currently proposed mitigation measures into the project Biodiversity Management Plan (BMP) as per ESAP#14.
The area is considered low risk for avian collision or electrocution impacts due to the relatively low bird abundance and diversity observed at baseline, and distance from key migratory pathways as confirmed during ESIA scoping via consultation with Nature Conservation Egypt, which is Bird Life International’s country partner. This will also be confirmed during the ESIA Addendum for the OHTL, and any additional necessary mitigation measures (as required) will be incorporated into the project BMP. No invasive alien species were observed in the project area at baseline; measures to prevent alien invasive species introductions specified in the ESIA will be implemented.
