MIGA’s due diligence review considered the environmental and social management planning process and documentation for the Project, and identified gaps (if any) between these and MIGA’s requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable time period, are summarized in the paragraphs that follow and in the Environmental and Social Action Plan (ESAP) attached to this ESRS. Through the implementation of these measures, the Project is expected to be designed and operated in accordance with the Performance Standards.
Key environmental and social (E&S) issues associated with the Project business activities are summarized in the paragraphs that follow.
PS1: Assessment and Management of Environmental and Social Risks and Impacts
Quadran has a set of corporate policy statements and standards in place setting out the guiding principles for Environment, Social, Health and Safety (ESHS) requirements, applicable to the solar plant sites and related infrastructure. The policy statements affirm Quadran’s’ commitments to develop the Projects in a socially responsible manner and in line with sound environmental management practices.
Identification of Risks and Impacts:
Separate Environmental and Social Impact Assessment Studies (ESIAs) have been prepared for the Projects, in accordance with local regulation and the requirements of the PS. The studies were conducted by ERM, an international consulting firm, in cooperation with Insuco, an international social consulting firm with presence in Burkina Faso. The ESIAs are currently being reviewed by the local environmental authorities as part of the environmental approval process. Associated infrastructure such as transmission lines and access roads are included in the scope for both ESIAs. ERM also conducted an analysis of risks related to human rights, including a assessment of the security context. The assessment concluded that security risks are fluid but manageable, and regular re-assessment is required.
An Environmental and Social Due Diligence of the Projects and the ESIAs against the requirements of the PSs was commissioned by the lenders in February 2020 and conducted by IBIS, an international consulting firm. The main gaps identified were related to stakeholder engagement and consultation, and land acquisition. These gaps are being addressed by the Project Companies, as further described below.
Potential cumulative impacts were considered in the ESIAs, which concluded that no material cumulative impacts are expected.
The ESIAs include frameworks for Environmental and Social Management Plans (ESMP), which provide principles for preventing and mitigating environmental and social impacts, in both construction and operation phases. For each impact and corresponding mitigating action, the ESMPs define a technical description, schedule of implementation, responsibilities, monitoring indicators, and budget.
The EPC Contractors will establish and implement Occupational Health, Safety and Environmental Plans (OHSEP) based on the information in the ESIAs, prior to commencement of construction (as per the ESAPs). The implementation of the OHSEPs and adherence with the E&S requirements of the Project Companies, including the PS, are conditions of the EPC Contracts. The OHSEPs will include sub-management plans for issues such as construction camp management; erosion and sediment control; occupational health and safety; community health and safety; water resources; air emissions and pollution prevention; waste; hazardous materials; traffic, biodiversity and chance find procedure. The Project Company will complement the EPC Contractor ESMPs by developing and implementing specific plans regarding stakeholder engagement and grievance mechanism (as per the ESAP), and inspection and auditing of the Contractor.
An ESMP for the operations phase will be developed prior to commencement of operations, as per the ESAP.
Organizational Capacity and Competency:
The Project Directors have the overall responsibility for compliance with E&S requirements and related coordination with authorities, contractors and other stakeholders. The Project Companies will also employ on-site E&S Managers (one per site), reporting to the Project Directors. Quadran will also provide support to the Projects through its corporate level E&S Manager based in France.
At each site, the EPC Contractor will be required to appoint an Occupational Health, Safety and Environment (OHSE) Manager responsible for overseeing the implementation of the ESMP, monitoring and inspections, training, and reporting to the Project Company and relevant authorities. The OHSE Manager shall be suitably qualified and have prior experience overseeing OHSE management in construction projects. In addition, each sub-contractor will be required to appoint an OHSE Officer.
At each site, the Project Company will also recruit a community liaison officer (CLO). As per the ESAP, the Project Company will notify MIGA of the appointment and qualifications of the ESHS Manager and CLO prior to the start of construction.
Emergency Preparedness and Response:
An Emergency Response Plan for each project will be developed a part of the ESAP, which will include (inter alia) procedures for responding to fire and explosion, spills, loss of containments of dangerous substances, traffic incidents, safety and security incidents, and malicious acts. The procedures and responsibilities for emergency response actions and communication will be clearly defined and available on-site.
The plan will also include provisions for communication, resources, and training and updating of the Emergency Response Plan.
Monitoring and Review:
As part of the ESMP, the EPC Contractor will develop and implement a monitoring and reporting system on OHSE impacts related to construction. Monitoring frequencies, methodology and indicators will be reflective of the risks and impacts identified in the ESIA. The EPC Contractors will report to the Project Companies, which will report to authorities as required. The Project Companies will also disclose monitoring results and provide feedback to affected communities on at least an annual basis in relation to any impacts affecting them and associated mitigation measures. Annual monitoring reports will also be developed and submitted to MIGA.
In 2019, during the ESIA processes, several community consultation activities were completed for both Projects and with various groups of participants, including landowners, women, youth and local authorities. Stakeholder meetings were held to discuss the Projects and to provide an opportunity for the affected communities to raise any concerns. Issues raised during the meetings primarily included employment opportunities; communication during Project implementation, and community support activities. Prior to the consultations in 2019, SONABEL also carried out community consultations related to the land acquisition.
Stakeholder engagement activities were carried out as part of the development of the ESIAs, and Stakeholder Engagement Plans (SEP) have been established for each site, building on the engagement undertaken as part of the ESIA. The SEPs include an identification and analysis of stakeholders, principles for communication and engagement with each stakeholder or groups of stakeholders, roles and responsibilities, grievance mechanism (see below) and reporting measures. The SEPs cover both construction and operations phases.
As described under PS1 above, a stakeholder engagement plan which includes a grievance redress mechanism has been prepared for the Project. The LRP, described under PS5, also includes stakeholder engagement activities and grievance redress mechanism related to livelihood restoration measures.
External Communication and Grievance Mechanisms:
Grievance mechanisms have been established as part of the SEPs described above, and implemented by the Project Companies, with the purpose to ensure that all complaints or other communications received from communities or other stakeholders are responded to and managed appropriately. This includes recording any stakeholder comments or complaints and ensuring that they are passed on to the relevant party for response and resolution as soon as practicable. If the grievance is related to the EPC Contractor’s activity, the EPC Contractor will work with the Project Company to address the complaint.
PS2: Labor and Working Conditions
Construction works for each plant will generate about 200 jobs for up to one year, and operations will involve about 20 full-time workers. Construction staff will be housed in nearby towns, with transportation provided by the EPC Contractor. Worker accommodation provided by the contractor will be in line with the IFC/EBRD Guidance Note on Worker’s Accommodation (as per the ESAP).
The EPC Contractors will develop and implement local recruitment plans as part of the OHSEP, in order to maximize employment opportunities for local villagers. The plans will include public presentations of employment and business opportunities, creation of recruitment offices and training programs to support the plan. Recruitment at the entrance of, or close to the project site, will not be permitted.
Working Conditions and Management of Worker Relationship:
The EPC contracts require the Contractor to observe applicable labor laws and comply with the requirement of PS 2 regarding its employees, and it will also require the Contractor to ensure that this requirement is passed on to sub-contractors. Relevant HR policies and procedures for the construction and operations phases will be established (as per the ESAP) to cover all workers, including direct workers and contracted workers. At a minimum, the HR Policies will include the following provisions: working relationship; working conditions; terms of employment; workers’ organizations; non-discrimination and equal opportunity; grievance mechanism; prohibition of child and forced labor; and occupational health and safety. The conditions of employment and worker’s rights will be communicated to all new employees during the induction process.
The HR policies and employment contracts for direct employees and contractor staff will allow for employees to join or form worker’s organizations. A staff representative will also be appointed, responsible for bringing employee’s concerns or requests to the management.
Protecting the Work Force:
In line with the Quadran’s policy statement, child and forced labor is prohibited in relation to the Project. The EPC Contractor will be contractually bound not to use any forms of forced labor, and to observe applicable laws and PS2 requirements related to child labor.
Occupational Health and Safety:
The ESIAs includes descriptions of health and safety risks and impacts during construction and operations, with a series of preventive measures. The main risks and impacts will include heat exposure, traffic safety, exposure to welding light and fumes and potential for fires and/or explosions resulting from ignition of flammable materials or gases. As referenced earlier under PS 1, the EPC Contractors will develop and implement the ESMP, including an OHS Management Plan. This will include organization, identification of risks and prevention measures, scheduling of meetings and trainings, permit-to-work procedure, and medical check-ups.
Workers Engaged by Third Parties:
As stated above, the Project Companies will include OHSE provisions in the EPC and O&M contracts and contracts with other sub-contractors providing services to that Project Company’s operations. These provisions will include as a minimum: compliance with labor legislation, terms of OHS management, worker accommodation and access to a workers’ grievance mechanism including review and response to anonymous complaints. The EPC Contract and the Project Companies will monitor third-party compliance with approved OHSE requirements.
PS3: Resource Efficiency and Pollution Prevention
The Project Company will undertake a water resources studies prior to construction (ESAP item), to assess options for meetings water requirements during operations, including rainwater storage and whether water can be extracted from the ground aquifers to meet the water requirements, whilst ensuring that extraction will not affect the local communities’ resources. If sufficient water is not available, water will be supplied by trucks.
During construction, water will be trucked in to meet the Contractor’s requirements. Water will be primarily required for building foundations of the solar plant and transmission line towers, as well as for sanitary purposes and dust control. During operations water will be used for sanitary purposes and to clean the panels during operations. The frequency of cleaning depends on weather and climatic conditions, and according to the ESIAs, estimated water usage during operations will be around 1,000 m3 per year for each Project.
The Projects are estimated to lead to greenhouse gas emissions reductions equivalent to approximately 19,000 tCO²/year for Zano and 14,8000 tCO²/year for Dedougou.
During construction, a minor amount of temporary air, noise and water emissions are anticipated, which will be mitigated through standard pollution prevention and control measures. The EPC Contractor will be required to implement pollution prevention measures in the ESMP to mitigate the risk of any pollution, with specific provisions for erosion and sediment control, effluent management, chemical management, and waste management. During the operational phase, environmental pollution will be limited to wastewater and waste generation, and similar pollution prevention requirements will be included in the O&M Contract.
During construction, to minimize air and noise emissions from vehicles, the measures indicated in the ESMP of the ESIA include the use of proper equipment, vehicle and roads maintenance, timely dust suppression measures, speed restriction, etc.
According to the ESIA, during construction waste will primarily consist of wood residues, pallets and packaging material, metal scraps, and domestic waste. During operations, waste will be mostly generated at the offices, along with mineral oil from transformers, and sanitary effluents. A waste management procedure has been developed as part of the ESMP, including characterization of waste by type, quantities, and potential use; opportunities for source reduction, as well as reuse and recycling; procedures and operational controls for onsite storage; and final disposal. During decommissioning, waste will consist of used panels, metals, used oil, and concrete.
Vegetation control will be carried out manually without any pesticide use. The waste management system described above will include used hazardous materials and will address issues linked to waste minimization, generation, transport, disposal, and monitoring. Provision of secondary containment, drip trays or other overflow and spill containment measures will be implemented in designated areas.
Apart from runoff water from cleaning the solar panels, only sanitary wastewater will be generated during operations. As there is no sewage collection network at the sites, a septic system will be used, designed and installed in accordance with local regulations and the EHS Guidelines to prevent any hazard to public health or contamination of land, surface or groundwater.
PS4: Community Health, Safety and Security
Community Health and Safety
Both plants are located in rural and sparsely populated areas. The Zano site is surrounded by rural communities grouped in villages and hamlets, the closest of which is the village of Zano with a population of around 500 people, at around 1.5 km from the Project perimeter. The closest structure is the village school, 300 m from the site. The closest village to Dedougou is Souri, at around 1 km from the site and a population of around 300 people
Construction traffic is the primary potential adverse community health & safety impact associated with construction. A Traffic Management Plan will be implemented, including training & certification, vehicle safety procedures, signage, and awareness campaigns in affected communities.
Community impacts related to in-migration are expected to be moderate and short-term due to the relatively short duration of the construction works. In-migration will be minimized and managed through a local recruitment plan, prohibiting the use of day-laborers workers and recruitment at the site, and the communication of qualified job opportunities on a national level.
Hazards most directly related to power facilities occur as a result of electrocution from direct contact with high-voltage electricity or from contact with tools, vehicles, ladders, or other devices that are in contact with high-voltage electricity. Signs, barriers (e.g. locks on doors, use of gates, use of anti-climbing devices), and education / public outreach will be used to prevent public contact with potentially dangerous equipment.
As discussed under PS 3, the quantities of hazardous materials are limited, and the materials are managed in a suitable manner to avoid community exposure to these materials.
The community exposure to disease around the plant is limited as the sites are located in sparsely populated areas. The Project will be implementing worker’s health programs to screen the health of workers, and a Communicable Diseases Awareness Campaign will be implemented in the communities surrounding the projects as part of the capacity building activities in the LRP. A Code of Conduct for employees will be established, covering rules of interaction with local communities, addressing respect for local beliefs and customs and with special attention to prevent risks related to sexual harassment, gender-based violence, and prostitution.
As indicated under Performance Standard 1, the Projects will develop and implement Emergency Preparedness and Response Plans which will include procedures for informing stakeholders and responding to emergencies.
Quadran has developed a Security Management Plan for its operations in Burkina Faso, applicable to both Projects. It relies on the use of public forces (gendarmerie and police) for site protection and escort, and private security companies for management of site security, and tracking of motor vehicles transporting goods or personnel to the sites. The Security Management Plan will be revised to include provisions ensuring that security contractors and public forces operate in a manner which meet the requirements of local regulation and Performance Standard 4 (as per the ESAP). This includes setting up an agreement with the security forces, including commitment to the Voluntary Principles on Security and Human Rights, rules for use of force, and code of conduct.
The site will be fenced to prevent public access to the solar plant.
PS5: Land Acquisition and Involuntary Resettlement
Both sites were selected and Project layouts refined to minimize displacement. No physical displacement is required, but the Projects will result in economic displacement associated with land acquisition for the solar plants and the transmission lines.
Land acquisition for the sites was carried out by SONABEL in 2016 and 2018 based on local regulation. As part of the ESIA studies, the Project Company commissioned ERM to conduct a gap analysis between the compensation provided by SONABEL and the requirements of the PSs. To bridge these gaps, the Project will implement Livelihood Restoration Plans (LRP) for each site in line with the PSs.
The gap analysis concluded that the compensation paid out to the landowners by SONABEL 2016 exceeded full replacement cost of the land, but gaps were identified primarily related to compensation for assets (i.e. trees, crops), consultation and stakeholder engagement, livelihood restoration, and consideration of vulnerable groups. Additional project affected persons were also identified, belonging to households that make use of the project area for seasonal agriculture or collecting wood.
The Zano site has been used for subsistence farming by a total of 108 project-affected persons (PAP) (corresponding to 65 households), growing primarily beans, peanuts, millet and corn. The area is also to a lesser extent used for grazing of animals. Out of the 108 PAPs, 35 were compensated for loss of land by SONABEL in 2016. Based on the new census carried out by ERM and INSUCO in 2019, the compensation plan being implemented under the project will cover PAPs not compensated in 2016, as well as bridging gaps against PS5 related to compensation for loss of trees and crops. All PAPs also cultivate land in different areas not affected by the Project. There is also a dirt track used by the local community which runs across the site. An alternative road will be constructed around the project perimeter.
The Zano LRP does not include additional payments to landowners since the amounts provided by SONABEL were confirmed to exceed full replacement cost. The LRP; however, does include compensation for loss of trees and crops for Project Affected Peoples (PAPs) both with and without formal ownership of the land. According to the LRP, PAPs will be presented with various options including both in-kind and cash compensation. Based on surveys conducted to date, all PAPs are likely to opt for monetary compensation.
The Dedougou site has been used for subsistence farming by 28 PAPs in total which correspond to23 households, growing primarily beans, peanut, millet, corn and okra. The area is also to a lesser extent used for grazing of animals. The entire area was previously owned by one single owner, who was compensated by SONABEL in 2018. All households also cultivate land in different areas not affected by the Project.
The compensation program in the Dedougou LRP will not include additional payments to the previous landowner for loss of land since the amount provided by SONABEL was confirmed to exceed full replacement cost. The LRP includes compensation for loss of trees and crops for PAPs both with and without formal ownership of the land, and PAPs will be presented with various options including both in-kind and cash compensation. Based on surveys conducted to date, all PAPs are likely to opt for monetary compensation.
The transmission lines have been routed to avoid physical resettlement. The 1 km transmission line for the Zano project runs along the easement of existing roads and will not require additional land acquisition. The 54 km transmission line to be built for the Dedougou project is being funded under the World Bank’s Electricity Support Program, and it is anticipated that the World Bank ESSF will be applied during the construction of the line.
In addition to compensation, the LRPs include livelihood support measures to be provided to the PAPs and members of the affected communities, identified based on the consultations and surveys conducted as part of the ESIA studies. These measures include agriculture productivity programs, livelihood diversification for women, tree planting and management, training on management and use of monetary compensations, improved access to energy through subsidies for grid connection, support for strengthening artisanal skills, support for development of livestock and poultry farming, and a welfare program for vulnerable households in cooperation with local NGO. The final design and implementation of the support programs will be conducted in consultation with the PAPs and local authorities. Eligible for participation in the support programs will be affected households of the Zano community for the Zano plant, and all affected households in the Souri community for the Dedougou plant. In both cases, this includes all PAPs.
LRP close out audits will be conducted for each project by a third party within one year following the completion of the LRPs (as per the ESAP).
The community grievance mechanisms include multiple communication channels, including directly to the Project Companies via the CLOs and hotlines, and via the village chief