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
Environmental and Social Policy and Management System
At the corporate level, the company has policies on health, safety, environment, social (HSES), sustainability, ethics, and human rights, demonstrating its commitment to quality, injury and illness prevention, reducing environmental pollution, and ensuring compliance with statutory and regulatory requirements. These policies align with IFC PS requirements and apply to all Voltalia projects, including Menzel Habib. They will be shared with all project personnels, including contractors. Therefore, MSP is not expected to develop its own policies but adopt Voltalia’s and, where needed, develop project-specific procedures and plans.
Voltalia has a corporate HSES management plan defining process to identify and manage HSES risks, including mandatory requirements for MSP and contractors (detailed in its ‘HSE Minimum Requirements’). This plan will guide EPC and O&M contractors, who will be contractually required to develop project-specific Environmental and Social Management Plans (ESMPs) aligned with Voltalia’s E&S policies. Together with ESIA provisions, the corporate plan outlines requirements and standards underpinning the project’s ESMPs. As per ESAP#1, MSP will develop and implement a project-level HSES management plan detailing processes and standards for construction, ensuring adequate E&S management and supervision. It will require EPC and O&M contractors to implement a project-specific EHS/OHS management system and ESMPs in line with IFC PSs, WBG EHS Guidelines, Voltalia policies, and ESIA provisions. Voltalia/MSP will review and approve all plans before construction starts.
Aligned with corporate policies, the company has developed procurement and contractor/supply chain management procedures setting minimum requirements to integrate E&S obligations into contracts. These requirements, aligned with IFC PSs and the Contractor Management Guidance Note, have been included in all RFPs and the draft EPC contract.
Identification of Risks & Impacts
The company developed an ESIA in accordance with local legislation, IFC PSs and WBG EHS provisions and guidelines, and good international practice. The ESIA assessed all relevant baseline conditions (e. g. air quality, noise, traffic, biodiversity, etc.), analysis of alternatives, climate change risk assessment, impacts along with relevant mitigating measures and expected residual impacts once mitigants are implemented, and a framework ESMP. As outlined above, the project includes a 200m OHTL that will be built and operated by Voltalia, which will connect to the existing 145km OHTL. The 200m OHTL will be constructed within the project site. The ESIA also included the baseline condition and impact due to the upgrade of the existing OHTL. The project ESIA was disclosed via multiple meetings with all stakeholders and selected focus groups in August 2025 within the nearby communities of El Mehamla and Menzel Habib. Flora, Fauna and Avifauna fatality surveys were carried out over various periods (refer to PS6) to assess baseline and expected impacts on biodiversity.
To address E&S risks in procurement and supply chains (refer to PS2), Voltalia has implemented structured processes, including vendor prequalification and selection procedures, a PV Module Supply Chain Risk Assessment, an Ethics Guide, and a Code of Conduct that defines Voltalia’s E&S commitments (including those related to labor practices and human rights). These commitments are integrated into all contracts signed with suppliers.
Management Programs
As part of the ESIA study, a framework ESMP has been developed, which provides a summary of the E&S management plans, monitoring requirements and mitigation measures applicable to the construction and operation phases of the project. As per ESAP#2, the EPC and O&M contractors will develop a Construction Environmental and Social Management Plan (“CESMP”) and Operation Environmental and Social Management Plan (“OESMP”). The CESMP and the OESMP will be based upon the ESIA framework ESMP, the project-level HSES management plan, Voltalia’s E&S policies, IFC PSs requirements. The latter plans will be reviewed and approved by the Lenders prior to use. Construction and operations phase E&S management and monitoring will be shared between the company and EPC/O&M contractors, who will be contractually bound to fulfill their ESMP responsibilities.
The CESMP will comprise a series of sub-plans, including but not limited to: waste management; pollution prevention (covering emissions, spill response, etc.); water management (covering supply, treatment, disposal, etc.); stormwater management, hazardous materials; emergency preparedness and response; community health, safety, and security; road safety and traffic control; accommodation management; local recruitment and labor management; influx management; environmental monitoring plan; stakeholder engagement (including grievance handling); contractor management plans; gender-based violence and sexual harassment, and biodiversity management plans. As for the OESMP, it will consist of a suite of sub-plans, which will include but not be limited to: waste management; pollution prevention (including emissions, spill response, etc.); water management; hazardous materials; emergency preparedness and response; community health, safety and security; road safety and traffic management; biodiversity management including reptiles and pest management; environmental monitoring plan and stakeholder engagement (including grievance management).
With respect to the 145km OHTL, upgrade works will be carried out over a period of 2-3 months during the winter season. The OHTL will have to be de-energized by STEG for works to proceed, hence requiring close coordination between STEG and MSP. As per ESAP#3, the project will establish an EHS/OHS coordination procedure with STEG aimed at achieving compliance with the IFC PSs during construction and operations of the OHTL. The procedure will detail the type and frequency of the engagement and the proposed steps the project will take to ensure STEG and its selected EPC and subcontractors comply with relevant PSs standards and WBG General and sector specific EHS guidelines. This procedure will further detail the need for developing intervention plans considering HSES of workers as needed for the upgrade works.
Organizational Capacity & Competency
The company has at a corporate level an E&S Head, that has overall responsibility for the project’s ESHS and OHS management. The E&S head is supported by an Europe+ regional E&S Advisor. The company has good capabilities to manage a range of ESHS and OHS issues as well as understanding of IFC and international best practice provisions and standards. At the project level, MSP intends to hire a local E&S Coordinator and EHS resources, and a dedicated local Community Liaison Officer. The EPC and O&M contractors will be required to have qualified personnel to oversee all E&S issues including an EHS manager, and EHS/OHS officers based on the size of the workforce.
As per ESAP#1, the company will finalize the project related EHS organogram for both MSP and the selected EPC and O&M contractors before start of construction.
Emergency Preparedness & Response
The company has developed a corporate Emergency Preparedness and Response (“EPR”) procedure that sets out minimum requirements and guidelines for the identification and response to possible emergency situations. The corporate HSES management plan further outlines the requirement for this plan to be fully developed by the selected EPC contractor. As per ESAP#2, Voltalia/MSP and the EPC and O&M contractors will develop a project specific EPR plans in accordance with IFC PS1 and PS4 provisions.
This plan will cover preparedness and responses to a range of potential emergency scenarios including but not limited to: medical emergencies (including on-site injuries, pandemic type outbreaks, snakes and scorpion bites); fire, extreme weather conditions such heatwaves and floods; transport incidents and major hydrocarbon spills. Security related incidents, acts of sabotage/vandalism, terrorism etc. will be addressed with a separate Security Management Plan (ESAP 9 see below). The response plan will include a communication protocol to alert local authorities, communities as appropriate, as well as the management team in addition to specific responses and evacuation procedures. Regular drills and emergency training and exercises will be developed.
Monitoring & Review
The company will be responsible for reviewing and formally auditing their contractors with regards to their HSES performance and compliance against project standards, national requirements and IFC PS. As part of its project level HSES management plan (ESAP#1), MSP will establish specific procedures, based on corporate guidelines and framework, and allocate resources to monitor and measure the effectiveness of theirs and their contractor’s management plans / programs as well as compliance with relevant Tunisian legal requirements. E&S / OHS monitoring requirements of the EPC contractor for their own activities and that of their subcontractors will be defined within their management plans (ESAP#2) and approved by Voltalia/MSP. The implementation will be closely followed by the company during construction activities.
The project-level HSES management plan will also outline the minimum monthly reporting requirements of the EPC contractor. These reports will include coverage of the contractor’s E&S / OHS performance in accordance with reporting requirements outlined within the project ESIA, ESMPs and IFC PS requirements. Clear Key Performance Indicators (“KPIs”) will be developed as part of the reporting.
Voltalia has a Contractor and Supply Chain Procedure in place specifying selection, contractual agreements, auditing, monitoring and supervision requirements for contractors and suppliers. The company will implement the requirements outlined in these procedures at the project level; in particular, covering child, forced labor, and significant safety issues requirements.
PS2 – Labor & Working Conditions
The project is expected to employ up to 450 workers during the 18-month construction peak, including 100 skilled and 350 unskilled laborers, most will be engaged by the EPC contractor and sub-contractors. The workers are expected to come from the surrounding communities. A few expatriates may be retained for oversight and specialized construction. Given strong expectations for local jobs, Voltalia/MSP will coordinate with the EPC contractor and local authorities to maximize and fairly manage community recruitment. Around 20 workers will be employed during the project’s O&M phase.
Human Resources Policies and Procedures
Voltalia maintains group-level Human Resources (HR) policies broadly aligned with IFC PS2, covering recruitment, rights, obligations (including non-discrimination and equal opportunity), freedom of association, collective bargaining, and grievance mechanisms. Key documents include the Ethics Guide & Code of Conduct and the Group Diversity, Equity & Inclusion Policy. Voltalia also enforces a Human Rights Policy that commits to rejecting child and forced labor, discrimination, harassment, abuse, or violence, while promoting equal opportunities. These policies apply to all Voltalia subsidiaries, contractors, and workers, and will be implemented for this project.
As per ESAP#4, MSP will prepare for both construction and operations phases project-specific “Worker’s Handbook”. The Worker Handbook will include (i) Labor Policy statements addressing non-discrimination, equal opportunity, prevention of child and forced labor, freedom of association, and prevention of Gender-Based Violence and Sexual Harassment (“GBVSH”); (ii) HR procedures, including local recruitment, with measures to promote gender equality; worker induction; terms and conditions of employment; disciplinary actions (including GBVSH-related); and workforce demobilization post-construction; (iii) Workers’ Code of Conduct emphasizing respectful behavior in host communities and zero-tolerance for GBVSH; and (iv) Labor Grievance Mechanism (including contractors and third-party workers) enabling receipt and resolution of optionally anonymous grievances, including a separate gender-related issues like GBVSH and discrimination, handled sensitively and confidentially. These HR policies, procedures, Code of Conduct, and Grievance Mechanism will apply to all project workers, including those employed by contractors and sub-contractors (e.g., security providers), and will be translated into French and Arabic (or as relevant), easily accessible, and clearly communicated during induction and through sensitization and training. MSP will also ensure the EPC and O&M contractors’ processes fully align with these policies and that the HR function is adequately staffed with experienced personnel.
No workers’ accommodation camp will be set up during the construction phase as the project intends to hire from the surrounding communities. If needed, workers will be accommodated in the surrounding villages. As part of its project-level HSES management plan (ESAP#1), MSP will develop an overarching Accommodation Management Procedure that will articulate the minimum requirements for workers accommodation including provision of basic services and welfare facilities, consistent with PS2 requirements and the IFC/EBRD guidance note on Workers Accommodation: Process and Standards. These provisions will guide, if necessary, the development of a project specific accommodation management plan by the company or its contractors or subcontractors (ESAP#2) should workers be accommodated in the surrounding villages. MSP will require its EPC and O&M to develop a transportation management plan assessing and addressing the risks associated with transporting workers to and from the worksite (ESAP#2).
Working Conditions and Term of Employment
The project will ensure that all employment contracts comply with Tunisian labor codes and IFC PS2 requirements. Every employee (including those hired by contractors and subcontractors) will receive a contract in French/Arabic specifying terms of employment, working conditions (including health and safety standards), wages and benefits, working hours, overtime arrangements and compensation, annual and sick leave, vacation, holidays, and other statutory leaves. Contracts for construction-phase workers will clearly state the short-term nature of the project and indicate the expected employment duration.
In line with ESAP#4, Voltalia/MSP will establish a project-specific policy affirming that workers will not be restricted from joining unions or other workers’ organizations. This applies to both direct and third-party workers during construction and operations phases. The project will ensure that child or forced labor is never employed at any stage. The company will enforce contractual provisions with contractors and suppliers, including verification of identification and age.
Occupational Health and Safety(OHS)
Key OHS risks for the Menzel Habib project include slips and falls, hazards from moving machinery on-site, heavy lifting, traffic accidents, exposure to electric shocks and burns, bites from venomous snakes and scorpions and safety concerns during panel module assembly. Voltalia corporate HSES management plan covers various mentioned aspects, such as: a robust training program for staff and contractors; Job Safety Analysis and Risk and Hazard Assessment with related management procedures; PPE requirements; Permit to Work System; Lock Out-Tag Out System; OHS signage standards; medical support provisions; rest and welfare facilities; access protocols; induction and refresher Toolbox Talks; incident reporting and investigation; and performance monitoring. As part of ESAP#1, MSP will put in place similar requirements within the project-specific HSES management plan and will further include provisions to manage project-specific risks such as presence of venomous reptiles and high outdoor temperatures and further ensure these are included in the CESMPs and OESMPS(ESAP#2).
EPC and O&M contractors will also be contractually obligated to deploy an adequate number of qualified Health and Safety (“H&S”) supervisors to ensure compliance with contractual OHS provisions. A H&S Committee comprising worker representatives will be established to provide feedback and recommendations on safety matters, in line with Tunisian regulations. An OHS plan and related procedures will also be prepared for the operation and construction phases (ESAP#2). As per ESAP#5, Voltalia/MSP will implement strict monitoring requirements, including third-party audits during both construction and operations, to ensure contractors and subcontractors maintain compliance with national laws, employer labor standards, and PS2 provisions. The monitoring frequency will be quarterly throughout the construction phase and semi-annually in the first two years of operations.
Labor risk within the supply chain
To manage E&S risks in procurement and supply chain, Voltalia has formalized processes, including vendor prequalification and selection, a PV Module Supply Chain Risk Assessment, an Ethics Guide, and a Code of Conduct defining Voltalia's E&S commitments (including labor practices and human rights). These commitments are incorporated into supplier contracts. The Code of Conduct (CoC), aligned with IFC PSs, requires adherence to host country regulations and internationally recognized standards. These processes describe how i) supply chain mapping is undertaken; ii) Third Party Risk assessment and background checks are conducted (covering risks such as forced labor, child labor, and labor conditions); and iii) follow-up assessments are implemented, including monitoring to track due diligence and risk management effectiveness.
Additionally, short-listed suppliers must provide a list of key component sub-suppliers to assess potential risks. Voltalia also maintains a list of approved suppliers and sub-suppliers which EPC and O&M contractors will be allowed to work with. The PV module suppliers are also required to sign a forced labor declaration form to comply with Voltalia’s CoC and E&S 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. Voltalia/MSP reserves the right to terminate its contracts with any suppliers that repeatedly do not comply with the material obligations of the CoC. Voltalia/MSP will require their EPC supplier/s 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#6).
PS3 – Resource Efficiency & Pollution Prevention
Resource Efficiency – Greenhouse Gases
Greenhouse gas emissions during construction are expected to be minimal, mainly from fuel use in generators, transport, on-site equipment, and machinery. Although quantities have not been calculated, they are expected to be low and well below 25,000 tCO2eq/year. The Project is expected to provide around 200 Gigawatt Hour (GWh) of electricity per year and, it is estimated to result in about 126,000 tCO2eq/year GHG emission avoidance.
Resource Efficiency – Water Consumption & Availability
Estimated water requirements are 5,500m³ during construction and 10m³/month during operations. Water during construction will mainly be for dust suppression, concrete production, minor batching for substation, control and admin buildings, and domestic use. Consumption will be accurately quantified once key elements (e.g., batching, worker accommodations) are defined. During O&M, water use will focus on panel cleaning, prioritizing dry brush-cleaning. Wet cleaning may be needed when dust adheres due to rain or humidity, estimated at no more than four times per year.
At appraisal, the construction water source was not identified. The ESIA includes a sustainability review of groundwater use, concluding minimal aquifer depletion risk due to low demand. As per ESAP#2, MSP will develop a Water Management Plan for construction and operations, based on ESIA findings and sustainability assessment. The plan will ensure efficient water use, especially for panel cleaning, and outline monitoring procedures. It will detail potable/non-potable water quality, sustainable sourcing, resource efficiency measures (e.g., water-saving taps), training, KPIs, roles, and protocols for monitoring water quality in storage tanks.
Pollution Prevention
During construction, minor and insignificant pollution to air, water, and soil, and increased noise levels are anticipated; these can be mitigated through standard pollution prevention measures outlined in the different environmental management plans. Wastewater will be collected in impermeable tanks and transported by a licensed contractor to the nearest municipal treatment plant. During operations, no significant pollution impacts are expected except wastewater from panel cleaning and regular household waste. The company will implement pollution prevention measures per national law, IFC PSs, and ESIA provisions.
The project will generate non-hazardous waste (paper, wood, plastic, scrap metals, glass) and limited hazardous waste (transformer oils, paints, batteries, electronic waste). Overall volumes during both phases are expected to be low. As per ESAP#2 and 1, MSP and EPC/O&M contractors will develop a waste management plan aligned with local laws, Voltalia HSES guidelines, IFC PS3, and WBG EHS provisions. The plan will commit to waste reduction, maximize reuse/recycling, and outline processes for storage, segregation, tracking, transport, and disposal/treatment. It will include full waste traceability, third-party selection criteria, management of broken/expired PV panels, hazardous storage requirements, disposal solutions per good international practices, and ensure hazardous waste contractors are licensed.. As part of the project-level HSES management plan (ESAP#1), each licensed facility will be assessed for suitability to ensure safe disposal/treatment for human health and the environment.
Pollution Prevention – Hazardous Materials
Hazardous materials during construction and operation include hydrocarbons, oils, lubricants, and paints.. An impermeable storage area with restricted access will be established onsite as required by local legislation. A project-specific hazardous material and spill prevention management plan is developed for both phases by the EPC and O&M, based on the existing corporate hazardous material management policy (ESAP#2). The plan will cover transport, storage, refueling, emergency response, community awareness, training, inspections, maintenance, monitoring, reporting and compliance with national legislation and align with IFC PS3 and WBG EHS Guidelines.
Stormwater management
The southwestern boundary of the project site is bordered by a seasonal water stream, which typically flows for three to four weeks per year during particularly wet seasons. A hydrology study was conducted as part of the project design, identifying flood risks along both the southeastern and southwestern boundaries of the site. To mitigate these risks, a safety buffer will be maintained between the project infrastructure and areas prone to flooding, as determined by the hydrology assessment. Furthermore, as part of ESAP#2, MSP, along EPC contractor and O&M team will develop a Stormwater Management Plan for both the construction and operational phases. The construction-phase plan will include the design of appropriate stormwater drainage systems tailored to the site’s conditions.
PS4 – Community Health, Safety & Security
Community Exposure to Disease
The project is located in a sparely populated rural area, with the nearest residential area, located approximately 2.3km from the site. Although, the project intends to maximize recruitment from local communities to the extent possible, the large construction related workforce needs may lead to an influx of workers into the region. As stated earlier, no workers accommodation camp will be set up for the construction phase. Any accommodation of workers by the company or its contractors will need to meet the requirements of IFC/EBRD’s guidance note Worker Accommodation: Process and Standards.
As per ESAP#7, the project will develop and implement a Community Health and Safety and Worker Influx Plan. The plan will include an assessment of worker influx at a cumulative level given other development projects within the area and will include: (i) a communicable disease (including HIV/AIDS and sexually transmitted infections) awareness and prevention program for site workers as well as local communities; (ii) requirements for adequate on-site medical facilities; (iii) a community grievance mechanism (“CGM”); and (iv) provisions for periodical monitoring of social related effects of the influx of migrants. The implementation of this plan, together with the project Code of Conduct, measures to maximize local recruitment in the local procurement and employment procedure and plan, and the Worker Accommodation Plan (if needed, as per ESAP#2), will help manage the risks and impacts of population influx.
Road Safety & Traffic Management
During construction, the dominant vehicle movement patterns will be in relation to the transportation of construction material and equipment over the 18-months construction period. Increases in traffic related to the transportation of project components may represent a safety risk for the other road users and communities adjacent to the roads being used. The project ESIA has identified the road network and estimated road traffic; this information will be used by the project to develop a traffic management plan to bring in equipment and workers along with the associated impacts and mitigation.
As per ESAP 8, MSP shall undertake a Transportation Risk Assessment and guided by the findings, develop a Project Traffic and Transport Management Plan. The plan will define transport routes to be used for equipment deliveries based on the risk assessments undertaken to evaluate road traffic and conditions with the aim of minimizing impacts. It will also define a safety inspection program for the project (especially for local subcontractors) and implement ongoing monitoring of vehicles and proper use of safety measures.
The south part of the site is crossed by the existing commercial railway, which is used particularly for transport of phosphate. The new 200m OHTL will cross above the existing railway, and minimum legal height of 12m will be maintained. Access to the other side of the railway will be via existing designated crossing. In order to ensure workers’ safety during construction and operation, the site will be fenced, and a minimum safety distance of 20m will be maintained between the site and railway. Furthermore, safety risk related to the railway will be covered under the OHS management plan (ESAP#2)
Security Personnel
A permanent fence will be erected around the perimeter of the site. Security and access control to the site will be provided on a 24-hour basis by a third-party security company retained by the EPC and O&M contractors during construction operations. Security guards will not be armed. Per ESAP#9, the project will develop a Security Risk Assessment and Security Management Plan for construction and operations phases based on HSES procedures, assessment findings, and PS4 requirements, including IFC’s “Good Practice Handbook” and Voluntary Principles on Security and Human Rights. The plan will ensure security procedures are communicated to communities to foster understanding and minimize conflicts. During construction and operations. MSP will conduct regular audits of security provisions as part of monitoring and reporting under PS1 (per ESAP#1 and 4).
Community Safety of the existing OHTL
Key health and safety risks associated with high voltage power lines are: (i) electrical shock due to contact; (ii) overhead electric lines falling on the ground; and (iii) electromagnetic radiation from the power lines for which a safe distance must be kept. The RoW for the existing 145 km OHTL was established 40 years ago extending 14 meters on each side of the T-Line. For the planned upgrade works, MSP and its EPC contractor will request STEG to facilitate temporary access to the RoW. This access will be limited to a maximum duration of two months, with activities occurring no more than two days per week. STEG remains in control of the operation of the existing OHTL that MPS project and other entities are connected to. In alignment with ESAP#10, MSP, in collaboration with STEG, will undertake (i) conduct a comprehensive risk assessment on potential health and safety hazards for construction and operation of the transmission line due to its upgrade from 150kV to 225 KV voltage to meet the project capacity focusing on the areas of encroachment of the established RoW to repair, construct, or maintain transmission lines and towers, and (ii) communicate the outcomes of this assessment to STEG for appropriate follow-up actions, and provide best effort support on the implementation of necessary measures as required in accordance to IFC PSs.
Access to the transmission pylons is already established, as STEG performs bi-annual maintenance on the OHTL. The project will utilize these existing access routes, and therefore, no socio-economic or safety impacts whether temporary or permanent are anticipated during the upgrade works.
PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources
The project site is in the “Saharan Halophytic Ecoregion” (WWF) and is characterized by a generally flat relief and an altitude between 95 and 111 meters. Hydrologically, the site is bordered to the east by the Wadi El Herriga and to the west by a tributary of the Wadi El Oussif. The landscape is characterized by sparse vegetation, composed of species adapted to conditions of water stress and sometimes high salinity. Other existing infrastructure in the vicinity includes a track from Route Nationale 15 (RN15), a railway line connecting Gabes to Gafsa, an existing 150 kV high-voltage overhead power line, and agricultural activities including olive trees.
The PV site is not located within an internationally recognized or Protected Area. The nearest Key Biodiversity Area is the Sebkhet Sidi Mansour (Ramsar site, KBA, IBA – 3km to the north). During rainy years, this site irregularly hosts large numbers of migratory waterbirds including threatened species such as Marbled Teal (Marmaronetta angustirostris, IUCN - NT), and White-headed Duck (Oxyura leucocephala, IUCN - EN). The overhead grid connection and existing overhead lines do not pass through any internationally recognized or Protected Areas, but are within 5km of 3 such areas: (i) Chott el-Jerid (Ramsar, IBA, KBA, UNESCO proposed) is a large endorheic salt lake, however the area closest to the project is not typically the most inundated area (this is much further from the project, at-least ~20km); (ii) the second area is Sebkhet Sidi Mansour, described above; and (iii) the third is Chott Elguetar (Ramsar, KBA, IBA), a seasonal intermittent saline lake. When water is present in the site it is important for breeding and wintering water birds.
Tunisia has 42 Ramsar sites, many of which have dried out significantly in recent years as a result of climate change (the Mediterranean region has been designated a climate change hotspot), and do not typically perform the ecological function for which they were originally declared. No long-term data on the hydrology or avifauna of these sites exists. This is the case with the Ramsar sites close to this project. Local ornithological experts believe that these sites now hold water extremely seldom and they are no longer significant avifaunal receptors.
Flora surveys in May 2023 and March 2025, and satellite imagery identify the vegetation on site as typically steppe, with very sparse plant cover and an unremarkable floristic diversity. The site plants on site are dominated by sparse stands of Astragalus armatus, Haloxylon salicornicum, Anabasis articulata and Gymnocarpos decandrus. In the wadi beds adjacent to the site there are large tufts of Zizyphus lotus. No threatened or protected plant species were recorded.
Fauna was surveyed in May 2023 and February 2025 and recorded no threatened or protected species, whilst literature review also recorded no threatened species likely to occur on site. One endemic Mantid (Eremiaphila denticollis) was recorded on site. Although not threatened species, several poisonous snakes and scorpions exist in the area, including the highly venomous Yellow Fat-tailed Scorpion Androctonus australis. This poses a risk to construction and operational phase workers and to the animals themselves through persecution as a result of fear. A protocol as part of the biodiversity management plan, will be prepared for the safe management (capture and local relocation) of these animals when encountered, and training and awareness will be conducted for all staff.
Avifaunal surveys conducted on the PV site in February and August 2025 recorded 12 and 11 bird species respectively, including Southern Grey Shrike (Lanius meridionalis, IUCN -VU, National – VU), and Long-legged Buzzard (Buteo rufinus, IUCN - LC, National - NT). Avifauna surveys on the existing overhead line route in August 2025 recorded 41 species. Seven of these are of national conservation concern, and one is of global conservation concern, the European Turtle Dove (Streptopelia turtur)(IUCN - VU). No evidence of migration routes was identified from baseline data on site or literature sources. The national Red List for birds does not fully comply with IUCN standards and criteria. Bird fatality searches were conducted along ~62% of the existing power line route (~140km) in August 2025 and recorded only one bird fatality, a Rock Dove (Columba livia – IUCN - LC). Three species (all IUCN - LC) were recorded nesting on the existing pylons: Lanner Falcon (Falco biarmicus); Common Raven (Corvus corax); and Long-legged Buzzard (Buteo rufinus).
The vegetation on site is classified as natural habitat, with land use to date being primarily grazing by livestock. A rapid Critical Habitat Assessment (CHA) was included in the ESIA and identified no CH triggers. Three species are considered Priority Biodiversity Features (PBFs): the Southern Grey Shrike (Lanius meridionalis), the Long-legged Buzzard (Buteo rufinus), and the endemic Mantid Eremiaphila denticollis tunetana
The ESIA has adequately assessed the impacts of the proposed project on the identified receptors. Mitigation for construction phase impacts has been recommended and included in the framework ESMP. As per ESAP#11, MSP will develop a Biodiversity Management Plan (BMP) for both construction and operation phases including a no net loss strategy for the project site. The upgrade works for the existing overhead power line will be implemented out of breeding season (April – September) to avoid disturbance of birds nesting on pylons. For operation phase, the BMP will include a biodiversity chance find procedures will be used to capture data on any incidental mortality of birds and other wildlife at the facility.
PS8: Cultural Heritage
As part of the ESIA, an archaeological study was conducted to identify potential cultural heritage presence within the project site and its area of influence, including the access road. Within the perimeter of the solar PV plant, no archaeological sites were identified, aside from a few isolated ceramic shards with no significant archaeological context. The nearest archaeological site is located approximately 600 meters north of the project site. It consists of a small mound currently occupied by a visitor center. The project’s interface with this site will be minimal, as it is not located along any access road and the project site will be fenced off.
Another site, El Mehamla, was identified approximately 2.25 km north of the project site, near the entrance to the north-south untarred track and about 200 meters from the R15 access road. This site contains ruins of a Roman-era oil press, dating back to around 300 to 400 BC. Given the proximity of El Mehamla site to project activities, particularly truck movement along the access road, there is a potential risk of damage. To mitigate this, MSP will develop a Cultural Heritage Site Management Plan that will include avoidance protocols, in-situ preservation of known sites, monitoring procedures, contractor management measures (ESAP#12). Additionally, MSP will implement a Chance Find Procedure, ensuring that contractors and employees are trained and sensitized to follow proper protocols in the event of discovering archaeological resources during land clearance or mechanical excavation.