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Annex 4. Environmental and Social Management Framework and System (ESMFS) of the Egypt
Renewable Energy Financing Framework
Executive Summary of the ESMFS
Egypt has the world's fourteenth highest Greenhouse Gas (GHG) emissions growth rate in the 19902012 period and is among the top 6 greenhouse gas emitting countries in the EBRD region. It faces
significant challenges in diversifying its electricity sources away from its more than 90% reliance on
hydrocarbons (gas and oil). Scaling up renewable energy will help Egypt meet its climate change
mitigation commitments as well as reducing the country’s fuel import bill and saving foreign exchange
reserves. Egypt has launched an ambitious programme to change the energy mix and to foster the
development of renewable energy.
The GCF-EBRD Egypt Renewable Energy Financing Framework (the Framework) is designed to
support Egypt to achieve its goals via two components: Component 1 – Enhancing renewable energy
integration, policies and planning through a comprehensive technical assistance programme;
Component 2 – Scaling up renewable energy investments, by blending EBRD and GCF financing and
leveraging additional debt financing from international financial institutions and in the future from
commercial banks, as well as private sector investments.
The Framework will support Egypt to unlock its vast renewable energy potential by investing in a
series of sub-projects in the wind and solar sectors as identified under current Feed-in-Tarrif (FiT)
programme.
All sub-projects considered under the Framework will be subject to detailed
environmental and social appraisal and disclosure as set out in this document.
EBRD has adopted a comprehensive Environmental and Social Sustainability Framework (ESSF)
consisting of an Environmental and Social Policy (ESP) and a set of Environmental and Social
Performance Requirements. The ESSF is aligned with other IFIs, such as the IFC and Equator Banks
and the Green Climate Fund. EBRD also maintains Environmental and Social Procedures, which
outline the process by which Bank staff process and monitor projects in accordance with the overall
ESP framework.
In accordance with EBRD’s ESSF, all sub-projects in this Framework will undergo environmental and
social appraisal both to help EBRD decide if the project should be financed and, if so, the way in
which environmental and social risks and impacts should be addressed in its planning,
implementation and operation. The appraisal process also identifies opportunities for additional
environmental or social benefits. EBRD seeks with its ESSF and environmental and social appraisal
and monitoring processes that projects are designed, implemented, and operated in compliance with
applicable regulatory requirements and good international practice.
Each subproject to be considered under the EBRD-GCF Framework will be subject to full project and
sponsor-specific environmental and social due diligence utilising the EBRD’s ESSF. EBRD
anticipates that all solar projects under the FiT scheme will be Category B and the wind projects will
be a combination of Category A and B. On the basis of this each Subproject will be individually
reviewed and categorised and due diligence will be undertaken accordingly.
Under GCF’s “Comprehensive Information Disclosure Policy of the Fund” this Framework would be
categorised according to the anticipated risk profile of the individual Subprojects would require site
specific assessments consistent with the approach of EBRD. With this in mind Category A projects
will be excluded from receiving GCF financing so that this framework will overall be considered
Category B.
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This ESMFS sets out:
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The rationale for the proposed GCF-EBRD framework, including a description of the
prorgamme and the proposed approach.
A summary of relevant, available environmental and social baseline information and
referencing of source data. The E&S context of the project is also provided.
Typical environmental and social issues associated with the Framework are provided and
details of best practice for mitigation of any such risks and impacts.
The ESMS summarizes EBRD’s E&S Policies and procedures, including the Performance
Requirements and the key steps for project appraisals.
EBRD’s stakeholder engagement requirements and project redress mechanism.
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Programme Background and Description
Background
Egypt has the world's fourteenth highest Greenhouse Gas (GHG) emissions growth rate in the 19902012 period and is among the top 6 greenhouse gas emitting countries in the EBRD region. It faces
significant challenges in diversifying its electricity sources away from its more than 90% reliance on
hydrocarbons (gas and oil). Renewable energy production to date has primarily been hydro power
(2,300 MW – c. 7%). Scaling up renewable energy will help Egypt meet its climate change mitigation
commitments as well as reducing the country’s fuel import bill and saving foreign exchange reserves.
Egypt has launched an ambitious programme to change its energy mix and to foster the development
of renewable energy. The government has worked for many years to prepare the framework for
renewables, which is currently based on the Renewable Energy Law dated 21 December 2014. The
Sustainable Energy Strategy to 2035, builds on previous strategies emphasising the importance of
renewable power and confirms the target (established in 2008) for renewable sources to provide 20%
of electricity consumption by 2022, with the private sector expected to deliver most of this capacity.
Despite the progress made by the government to develop the framework for renewables there has
been limited development so far towards the renewable energy target, primarily because there are
barriers to the implementation and financing of the projects, namely:
(i)
(ii)
(iii)
(iv)
the uncertainty and high transaction costs associated with the first private renewable
energy projects,
the limited availability of debt from commercial sources, particularly given the required
long tenors of the projects,
the need to establish an adequate infrastructure to integrate renewables into the grid, and
the need to design and implement competitive tenders for renewable energy.
The Programme Description
The GCF-EBRD Egypt Renewable Energy Financing Framework (the Framework) will support Egypt
to achieve its goals via two components: Component 1 – Enhancing renewable energy integration,
policies and planning through a comprehensive technical assistance programme; Component 2 –
Scaling up renewable energy investments, by blending EBRD and GCF financing and leveraging
additional debt financing from international financial institutions and in the future from commercial
banks, as well as private sector investments.
Overall, the Framework will catalyse the development of a competitive, efficient renewable energy
market that will allow Egypt to achieve its renewable energy targets, while increasing the share of
privately owned generation capacity. The projects to be implemented with co-financing from the
Framework are expected to result in avoided GHG emissions of about 800,000 tCO2e annually once
all projects are operational.
GCF funds will only be used for subprojects with an Environmental and Social Categorisation of B.
The GCF-EBRD Egypt Renewable Energy Financing Framework (the Framework) will support Egypt
to unlock its vast renewable energy potential by addressing key barriers hindering its development
through two key components:
1) Component 1 – Enhancing renewable energy integration, policies and planning
The Framework will include a wide technical assistance program that will help creating the
enabling environment for private sector renewable investments in Egypt. The technical assistance
program will include 3 key components:
a) Enhancing planning and RE integration – this component aims at ensuring that the
new renewable energy capacity developed as part of this framework is successfully
integrated into the electricity grid. Specifically, the aim is to ensure that the network
injection capacity will be sufficient to preserve the Very High (VH), High Voltage (HV) and
Medium Voltage (MV) networks’ security and balance and that the electrical system
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performance will not be technically degraded once new renewable energy generation
plants are commissioned.
b) Enhancing capacity for administering RE tenders – this component will seek to
provide the relevant institutions (including but not limited to the regulator and the off taker)
with advice on the practical implementation measures needed for the successful launch
and completion of competitive tenders for renewable energy. This element could be
extended to provide support to investors and financiers in the preparation of the
subprojects.
c) Promoting gender equality – this component will include technical training to relevant
projects to strengthen equality of opportunity for women and men to access and benefit
from employment and other economic benefits connected to the development of
renewable energy sources.
2) Component 2 – Scaling up renewable energy investments
The Framework will support the development and construction of renewable energy projects
totalling USD 1 billion. The scale of this investment reflects the scale of the need, and opportunity,
for renewable energy in Egypt. This investment in the first wave of private renewable projects in
Egypt will directly deliver significant renewable capacity and catalyse the development of a new
industry in the country.
The project will leverage EBRD and GCF finance to attract additional investments from
international financial institutions and commercial banks, as well as equity investments from the
project sponsors. The framework envisages debt financing from GCF and EBRD of up to USD
500 million for 8-12 individual subprojects. The aggregate value of the GCF loans would be up to
USD 150 million, which would co-finance up to 15% of total project costs in any single project,
with the amount allocated to each project decided based on specific needs. EBRD will provide
financing representing up to 35% of the cost of each project and the remaining debt is expected to
be provided by another development financial institution or, at a later stage of the programme, by
a commercial lender. The equity contribution is 25% of the project costs translating into
investment from private sector of USD 250 million.
The total financing expected from the GCF and the EBRD is provided in the table below:
Component
Total
amount
Currency
GCF
EBRD
1. Enhancing renewable energy
integration,
policies
and 7.0
planning
million USD ($)
4.7
2.3
2. Scaling up renewable energy
500
investments
million USD ($)
150
350
Total programme financing
million
($)
154.7
352.3
507
USD
Environmental and Social Context
Emissions baseline
Between 1990 and 2012, Egypt has more than doubled its GHG emissions, i.e. from 124 million
tCO2e to 288 million tCO2e (WRI, CAIT, 2014). Egypt has the fourteenth highest emissions growth
rate during this period in the world, and such surge is significantly higher compared to the growth in
global emissions, as well as in OECD and various European countries (Figure 1).
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Figure 1: GHG emissions indexed to 1990 level
Besides increased industrial output, population growth and other developments, this increase in GHG
emissions is due to the fact that power generation in Egypt is dominated by fossil fuels, which account
for over 90% of the electricity production; hydro and other renewables (solar and wind) represent
around 8% and 1%, respectively.
This mix translates into a relatively high grid emissions factor at 0.581 tCO2/MWh, which is likely to
increase due to the publicly announced plans to increase the fossil fuel-based generation capacity in
the medium-term.
Additionally, the structure of the power sector is such that private sector-driven expansion in
renewable generation has not been possible at scale until recently. The electricity sector is state
dominated, and has been until recently vertically integrated, and consumption is subsidized. Given the
pressures to expand generation, whilst limiting reliance on imported fuels and easing the fiscal burden
of subsidies, the Government has taken steps to setup a favorable regulatory climate for a higher
level of private sector involvement, including in expanding generation capacity. This includes the
launch of the Feed-in-Tariff (FiT) scheme for private sector renewable developers since 2014.
The Egyptian government has, since 2014, initiated a major reform programme to address these
challenges, combining subsidy reduction, liberalisation, structural reform and energy diversity. One
key element is an ambitious target to secure 20% of electricity generation from renewable sources, in
particular solar and wind, by 2022. This requires massive investment, most of which is expected from
the private sector. Central to the strategy is a plan to secure 4,300 GW of solar and wind projects
implemented by private developers relying on a long-term feed-in tariff (the FiT Scheme).
The launch of the FiT Scheme coincides with a transformation in the global renewable industry as
sustained reduction in cost and improvements in efficiency have reduced the cost per kWh, in
particular of solar power in sunny areas, to match or even beat the cost of conventional power. This
shift gives Egypt the opportunity to capitalise on its world class renewable resources to meet growing
demand, increase its energy diversity and reduce the power sector's environmental impact. It also
allows for the rapid introduction of a wide range of private investors. The successful implementation of
the FiT Scheme is therefore a critical landmark for the transformation of the Egyptian energy sector.
Environmental and Social Context of Feed-in-Tariff Sub-Projects
Each FiT subproject to be considered under the GCF-EBRD Framework will be subject to full project
and sponsor-specific environmental and social due diligence with the support of an independent
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consultant. EBRD anticipates that all solar projects under the FiT scheme will have an E&S
categorisation of B and the wind projects will be a combination of Category A and B. As a result each
Subproject will be individually reviewed and categorised and due diligence will be undertaken
accordingly.
Under GCF’s “Comprehensive Information Disclosure Policy of the Fund” it is understood that the
Framework would be categorised according to the anticipated risk profile of the individual Subprojects
would require site specific assessments consistent with the approach of EBRD. With this in mind it
has been agreed with GCF that Category A projects will be excluded from receiving GCF financing so
that this framework will overall be considered Category B.
Due to the specific nature of the projects being considered for financing the following sections have
been divided into Wind and Solar Subprojects:
Environmental and Social Context of Proposed Solar Projects
Solar Potential in Egypt
This following map shows Egypt's solar resources at a high level, with the colours reflecting average
annual irradiation in kWh per square meter. Indicated on the Map is the proposed site of the Benban
solar development, discussed in the following sections.
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Benban & other areas designated for solar development
The E&S risks and impacts associated with the development of an individual 50 MW solar
photovoltaic project in an area of low environmental and social sensitivity are likely to be readily
identified, assessed and mitigated through the adoption of good E&S practice. In the absence of any
site specific sensitivities or concerns associated with any one project it is anticipated that each solar
Subproject will be categorised B (I-2), and this will be confirmed during project appraisal.
Most of the Subprojects are expected to be implemented on one specific 37 km2 plot allocated to
NREA for these purposes near Benban in Upper Egypt. This plot is divided into 39 subplots, each
allowing for a plant of 20 MW or 50 MW, with a total capacity for the entire site of 1,800 MW. When
complete this site will be the largest solar complex in the world delivering significant environmental
benefits to a country that is largely dependent on fossil fuels for energy production. However, the
concurrent development of a large number of projects on such a site has the potential to give rise to a
number of cumulative risks and impacts such as: workforce sourcing; resource needs; logistical
arrangements; and the requirement for associated facilities including grid connection(s), even though
the impacts of each individual project are not anticipated to be significant.
Recognising this concern NREA, with EBRD support, initiated a Strategic Environmental and Social
Assessment (a SESA) to ensure that these cumulative impacts were identified and managed. The
EBRD has engaged with its clients and also worked with other IFIs and the Egyptian authorities to
ensure that Developers under the Solar FiT site cooperate in the management of these impacts. This
has extended to working with the authorities and the developers in building an E&S governance
structure and sufficient management capacity to deliver on the SESA commitments collectively. The
SESA and its related Non-Technical Summary have been disclosed in English and Arabic and include
a comprehensive E&S Action Plan (or ESMP in line with GCF terminology). The documents in
English and Arabic can be found here: http://www.ebrd.com/work-with-us/projects/esia/egyptrenewable-feedintariff-framework.html
Additionally, a number of various public consultations meetings took place in the last few years
targeting the affected communities and any identified stakeholders. Those are summarized in Annex
2 of this document.
At sites located outside the Benban complex where smaller (typically 3-8 projects) are planned at any
one location a similar approach to each Subproject will be adopted. Where necessary, an
assessment of cumulative impacts will also be required to be completed by the project sponsors in the
absence of an SESA applicable to those locations. The works that the bank has initiated and lead
with the Benban SESA has already had successful demonstration effect as NREA and the project
developers have initiated an equivalent study at other locations.
Each Subproject will be subject to the full E&S Due Diligence and the usual disclosure requirements,
during the ESDD period it will be confirmed that no Category A projects will be included in the
framework. Each subproject will be disclosed by EBRD and project specific environmental and social
action plans (ESMP) will be developed to ensure the objectives of the framework are met; that the
outcomes of the SESA are duly considered and actioned; and that the delivery of each Subproject is
undertaken in accordance with the PRs/PSs and GCF’s requirements.
Environmental and Social Context of Proposed Wind Projects
The FiT Wind programme has identified three geographies for wind development in Egypt, namely:
(i)
Gulf of Suez area (1,200 km2), Red Sea Governorate – north east of Egypt;
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(ii)
(iii)
West of Nile area 6,450 km2;
East of Nile area 2,200 km² area.
The following map shows Egypt's wind resources at a high level, with the colours reflecting average
wind speed in metres per second. The two main areas of development to date, Zafarana and Gulf El
Zeyt, are marked and the exceptional resource can be seen. Future developments are expected to
be in the large areas to the west and east of the Nile, south of Cairo. The resource here is less good
but still excellent by international standards.
Adopting a similar approach to the Solar FiT programme, EBRD and other agencies have recognised
that additional information regarding E&S sensitives is required in order for such developments to
progress in line with international E&S standards. As a result a series of Strategic Environmental and
Social Assessments of these areas that have been designated for development have been initiated.
West of Nile SESA is currently being completed by the Japan International Cooperation Agency
(JICA); Gulf of Suez / Ras Ghareb by the Regional Center for Renewable Energy and Energy
Efficiency (RCREEE); and East of Nile by EBRD. These SESAs are currently under preparation and
are expected to be disclosed during 2017 and prior to any EBRD / GCF funded projects being
considered for financing. A particular focus of these SESAs is the potential ornithological impacts of
projects individually and in cumulation with others.
The SESAs will show areas where the development of wind power will be possible with the least
environmental and social impacts. The results shall be mapped differentiating into zones where RE
development i) is possible without restrictions, ii) possible but with restrictions such as future
monitoring and verification, ii) critical and only possible with significant mitigation measures and iv)
precluded.
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It is anticipated that windfarms could be up to 250MW and some will therefore be Categorised A. In
addition there will be a series of smaller windfarms planned in low E&S sensitive areas that are likely
to be Category B (I-2) and these subprojects would be appraised by EBRD on a case by case basis to
ensure that these subprojects can be structured to meet the various E&S requirements, are disclosed
individually appropriately and that all relevant supporting documents have been prepared accordingly.
This method will screen out any Category A projects from receiving GCF financing under this
framework. The SESA will inform future projects and investment decisions, facilitate and inform future
environmental permitting requirements and project financing for the development individual
investment projects.
East of Nile Wind Projects
The GoE has identified three large areas suitable for development of renewable energy including a
2,200 km² area located to the east of the Nile River. This area has been identified based on existing
data wind power potential and existing land use.
To ensure a strategic level assessment of the potential environmental and social issues associated
with the development of renewable energy projects in this area (the "Project Area") and to inform the
decision making process for project development, the GoE, together with the NREA, is undertaking a
Strategic Environmental and Social Assessment (SESA) Study for the Project Area. A SESA is a
systematic decision-support process that helps to ensure that environmental, social and other
sustainability aspects are considered effectively in policy, plan and programme making. The SESA is
supported by the EBRD.
Figure: East Nile RE development areas
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SESA scoping has been completed and a scoping report has been disclosed here:
http://www.ebrd.com/work-with-us/projects/esia/egypt-renewable-feedintariff-framework.html. The full
SESA is expected to be disclosed in Q3 of 2017 ahead of any individual sub-project appraisal.
As an outcome of the scoping meetings, a list of potential and anticipated impacts, their potential
significance, the extent of assessment required and the assessment methodologies to be applied
were defined. The Scoping Report was then updated and serves to define the scope of the SESA.
The following impacts will be considered in the SESA:
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Impacts on existing land use through project land-take;
Socio-economic impacts and benefits;
Changes to the landscape character and visual impacts;
Impacts on terrestrial flora and fauna through land take and project activities;
Impacts to avifauna (birds) through loss of habitat, interaction with migrations routes and
collisions risks;
Use of water resources, waste water treatment and disposal;
Impacts associated with waste management and disposal;
Impacts on air quality;
Noise, vibration, electromagnetic interferences and light reflection/shadowing (wind RE);
Impacts on archaeological and cultural heritage construction and operational activities;
Occupational health and safety risks;
Impacts on traffic, utility services and other infrastructure;
Water run-off / flash flood risk; and
Seismicity risks.
The full SESA will make appropriate appraisal of each of these risks and impacts and propose
suitable mitigation measures to be applied at a sub-project level within this broader area.
West of Nile Wind Projects
A similar exercise for the FiT area located to the west of the River Nile is currently ongoing and is
expected to be disclosed in 2017. Due to the proximity of the East of Nile areas it is anticipated that
sensitivities, risks and impacts will be largely consistent with those identified in the area on the
opposite side of the Nile.
Under this EBRD-GCF Framework a consistent approach will be adopted for identifying the impacts
and appropriate mitigation measures in this area. This will include screening of projects and
excluding Category A projects from being financed under this framework.
Gulf of Suez Wind Projects
A Strategic Environmental & Social Assessment (SESA) of the Gulf of Suez area is currently under
preparation and it is understood that this will be disclosed in January 2018. Notwithstanding, there are
a series of project specific and wider area ESIAs available including: “Environmental and Social
Impact Assessment for an Area of 300 km² at the GULF OF SUEZ” Arab Republic of Egypt Ministry of
Electricity and Energy / New and Renewable Energy Authority (NREA) dated November 2013.
http://nrea.gov.eg/download/20160831_MASDAR_200MWwindfarmprojectnearRasGhareb_ESIAStud
y_Final.pdf
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The available documents to date include an E&S assessment of an area of approximately 300 km²
located 15 km inland from the Gulf of Suez to the west of Ras Gharib. The Environmental and Social
Impacts of potential wind power utilisation with up to 1,500 MW installed capacity was assessed. This
area is part of a total area of 1,229 km allocated by presidential decree of May 13th, 2009 to wind
power utilization as indicated below:
The ESIA area had been investigated during a site reconnaissance with the focus on all
environmental aspects except for Fauna and Flora. For the latter separate field investigations had
been carried out. The ESIA area is desert without any vegetation, except small spots of isolated
vegetation at wadi banks or in major wadis. The area is crossed by major wadis and the watersheds
of the wadis extent to the Jabal Gharib Mountain of about 1750 m a.s.l.
Further characteristics of the area can be summarised as:
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Land use & infrastructure: Land use within the project area is limited to Oil and Gas exploration
and production activities, associated infrastructure and power lines. The ESIA area has no public
infrastructure - except the asphalt road to Upper Nile crossing from east to west in the southern
part of the area – and no permanent settlements.
Settlements: The nearest settlement is located on the outskirts of Ras Gharib at a minimum
distance of 13 km from the north-eastern border of the project area.
Protected Areas: The area does not contain any historical sites or environmental protection areas,
nor is it located inside or nearby a protected area. No antiquities or other sites of historic and
cultural significance are located in the overall area.
Geomorphology: The area, especially the south and the Middle, comprises leveled land. To the
north some more hilly areas are met. Most of the area is covered with compact angular gravels
and pebbles forming a desert armour. The level of the whole project area above sea level ranges
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from 100 m a.s.l. in the east to 400 m in the west. The area is gradually sloping without any
pronounced escarpments. Stable underground, good foundation conditions; area is not affected
by fault lines, no special earthquake risk.
Water resources: No surface water except discharge in the major wadis that may occur quite
seldom. Groundwater is located at more than 100 m below surface.
E&S issues and impacts: similar impacts are noted in the ESIA as those in the East of Nile
scoping report. In particular the SESA provides some information on Avian Fauna, including:
o The Gulf of Suez, in particular the area near Gabel el Zayt, is well known as a bottleneck
for migrating birds. Large numbers of birds pass the area twice a year during spring and
autumn migration.
o Considering installation of wind farms within the ESIA area, the major potential hazards to
birds are collision risk and mortality but also barrier effects. Other possible impacts of
wind turbines, probably of minor importance, might be displacement due to disturbance or
direct habitat change and loss for roosting or local birds.
o Migratory activity within the ESIA area was (very) high. Hence, collision rates leading to
additional mortality potentially causing significant population effects for some species
cannot be excluded when building wind farms within the area. This applies in particular to
White Stork, Steppe Eagle and Egyptian Vulture (and possibly to Great White Pelican,
too).
o The proposed mitigation measures are therefore that an effective shutdown programme
has to be developed and established for spring migration period. With regard to the
development of such a shutdown programme, two alternate approaches are presented in
the ESIA including a fixed shutdown (FS) programme stopping all turbines from March 1st
th
to May 18 during daytime (1 hour after sunrise to 1 hour before sunset); or a tested
shutdown on-demand (SOD) programme. using radar technology.
The ESIA concluded that assuming that effective FS- or SOD-programmes are established, wind
farms within the project area are not expected to lead to relevant collision risks or barrier effects
for migrating birds.
Mitigation Measures following Best Practice
Relevant EBRD environmental and social safeguards standards will be applied in accordance with the
Accreditation Master Agreement and/or such other related arrangements. Each project under the
EBRD-GCF Program will be required to develop an Environmental and Social Impact Assessment
(EIA), which will include mitigation measures that draw from the results of the impact assessment and
good international industry practice. Projects considered for financing under the EBRD-GCF
Framework will undergo the appraisal process detailed below and will be evaluated against the
standards of EBRD’s Environmental and Social Policy, as well as best practice such as the IFC
Performance Standards. The WBG EHS General Guidelines and Guidelines for Wind Energy and
Electric Transmission and Distribution, the EU Birds and Habitat Directives will be used as a
reference together with other guidelines and standards developed by the EBRD and other
international institutions.
Environmental, Health and Safety
Internationally accepted guidance on environmental, social, health and safety mitigation measures for
renewable energy projects can be found in relevant EU Directives and Guidance Notes as well as the
WBG EHS Guidelines.
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Such guidelines are applicable for the construction and decommissioning phases of renewable
energy projects and provide guidance on mitigation measures and monitoring standards for projects.
The EHS General Guidelines are technical reference documents with general industry-specific
examples of good international industry practice. The guidelines contain performance levels and
measures that are generally considered to be achievable in new facilities by existing technology at
reasonable cost. The applicability of the EHS Guidelines should be tailored to the hazards and risks of
each project on the basis of the results of the impact assessment in which site-specific variables, host
country regulations, assimilative capacity of the environment and other factors should be taken into
consideration.
The General EHS Guidelines address mitigation measures associated with:
Environmental
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Air emissions and ambient air quality
Energy Conservation
Wastewater and Ambient Water Quality
Water Conservation
Hazardous Materials Management
Waste Management
Noise
Contaminated Land
Occupational Health and Safety
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General Facility Design and Operation
Communication and Training
Physical Hazards
Chemical Hazards
Biological Hazards
Radiological Hazards
Personal Protective Equipment (PPE)
Special Hazard Environments
Monitoring
Community Health and Safety
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Water Quality and Availability
Structural Safety of Project Infrastructure
Life and Fire Safety (L&FS)
Traffic Safety
Transport of Hazardous Materials
Disease Prevention
Emergency Preparedness and Response
For wind power projects specifically, the WBG EHS Guidelines for Wind Energy (2015) provide the
specific guidance and the WBG EHS Guidelines for Electric Power Transmission and Distribution
(2007) apply for projects involving transmission lines.
In general, many ESHS impacts from renewable energy projects and its associated facilities can be
avoided by careful site selection and alternatives analysis. Avoiding projects located within protected
areas or Important Bird Areas (IBAs) can significantly reduce the level of impacts and risks of a
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project. Similarly, avoiding resettlement, cultural heritage sites and indigenous territories can highly
improve the sustainability of a project.
Due to the nature of renewable energy projects, which are located in resource rich areas, cumulative
environmental and social impacts are particularly important to consider. If no relevant country-specific
guidance is available in relation to cumulative impacts assessment, international sources of good
practice guidance on this topic should serve as references. Cumulative impacts assessments are
especially warranted when multiple wind energy facilities are sited in close proximity to sensitive
receptors such as areas of high biodiversity value.
The following main mitigation measures are considered from the WBG EHS Guidelines for wind
power projects:
Landscape and visual impacts:
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Consider turbine proximity, layout, size, and scale in relation to the surrounding landscape and
surrounding visual receptors such as residential areas
Incorporate community input into the layout and siting
Maintain uniform size and design of turbines
Minimize ancillary structures on site
Noise during operations:
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Engineering design standards and turbine siting. Modern turbines have lower mechanical noise.
Operating turbines in reduced noise mode.
Building walls/appropriate noise barriers around potentially affected buildings
Curtailing turbine operations above the wind speed at which turbine noise becomes unacceptable
in the project-specific circumstances.
Biodiversity:
Careful site selection and layout should reduce adverse impacts on biodiversity. Any significant
residual adverse impacts will need appropriate mitigation, which could include the following:



Modify the number and size of turbines and their layout in accordance with site-, species-, and
season-specific risks and impacts. Fewer taller towers may reduce the collision risk for most birds
and reduce vegetation clearing for construction. The location of associated infrastructure—such
as transmission lines, substations, and access roads should also be accordingly informed by
biodiversity risk and impact assessments.
If the wind energy facility is located close to areas of high biodiversity value, active turbine
management such as curtailment and shut-down on-demand procedures should be considered as
part of the mitigation strategy, and factored into financial modeling and sensitivities at an early
stage. This method of mitigation should be adaptive and guided by a well-developed postconstruction monitoring program. Curtailment and shut-down on-demand measures should be
first conducted as an experiment, with control turbines that are not curtailed and with both sets
carefully monitored, to determine whether or not the curtailment is producing the desired fatality
reduction. Technology-led turbine shut-down should be considered in certain cases, although any
such system should be subject to a period of observer-led ground truthing and evaluation through
a process of adaptive management.
Avoid artificially creating features in the environment that could attract birds and bats to the wind
energy facility, such as water bodies, perching or nesting areas, novel feeding areas, and staging
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or roosting habitats. Capping or fixing any cavities in walls or buildings helps to remove potential
bat roosting sites.
Avoid attracting birds to predictable food sources, such as on-site or off-site waste disposal areas,
or landfills; this is especially relevant when vultures or other carrion-eating birds are present.
These types of mitigation measures may also need to be carried out in the surroundings of the
wind energy facility in order to be effective.
Consider adjustments of cut-in wind speeds to reduce potential bat collisions. The feasibility of
this measure should be informed by species- and site-specific data. A slight increase in cut-in
wind speed may have the potential to achieve significant reductions in bat fatalities, with minimal
reduction in generation or financial returns.
Eliminate “free-wheeling” (free spinning of rotors under low wind conditions when turbines are not
generating power).
Avoid artificial light sources where possible. White, steady lights in particular attract prey (e.g.,
insects), which in turn attracts predators. If lights are used, red or white blinking or pulsing lights
are best. Steady or slow blinking lights are to be avoided. Timers, motion sensors, or downwardhooded lights help to reduce light pollution.
Bury on-site transmission lines.
Install bird flight diverters on transmission lines and guy wires from meteorological masts to
reduce bird collisions when located in or near areas of high biodiversity value and/or where birds
of high biodiversity value are at risk of collision.
Use “raptor safe” designs for power line poles to reduce electrocution risk.
Assess the current state of the art of bird and bat deterrence technology, and consider
implementing any proven effective technologies where appropriate.
Shadow flicker:


Site wind turbines appropriately to avoid shadow flicker being experienced or to meet limits
placed on the duration of shadow flicker occurrence, as set out in the paragraph above.
Wind turbines can be programmed to shut down at times when shadow flicker limits are
exceeded.
Occupational health and safety:
The following occupational risks will be considered and the mitigation measures described in the
WBH EHS Guideline for Wind Power will be used as a reference:

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Working at Height
Working over Water
Working in Remote Locations
Lifting Operations
Community Health and Safety:

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Electrocution
Electromagnetic interference
Visual amenity
Noise and Ozone
Aircraft Navigation Safety
Involuntary Resettlement
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Projects that involve significant physical displacement and resettlement actions will not be eligible
under this Framework. Projects under the FiT programme are required to have obtained legal rights
on the property where the project will be developed (i.e., direct purchase, rent or easement). It is
expected that projects financed under the EBRD-GCF Framework will have negotiated agreements
for land tenure with agreed compensation for land and economic displacement.
The Environmental and Social Management System (ESMS)
Environmental and Social Sustainability Framework
EBRD will apply its comprehensive Environmental and Social Sustainability Framework (ESSF) for
the Facility. EBRD ESSF is based on the environmental and sustainability mandate in the Articles
establishing the EBRD, the Environmental and Social Policy (ESP) and Performance Requirements,
updated from time to time, and a dedicated Environmental and Sustainability Department (ESD)
discharged with the responsibility of its implementation, and dedicated Gender and Energy Efficiency
and Climate Change (E2C2) teams mandated to systematically identify environmental, social and
gender-related opportunities. EBRD was accredited by GCF Board in September 2015.
The latest version of the ESP and its Performance Requirements was approved by EBRD’s Board of
Directors on 7 May 2014. The ESP was revised to ensure EBRD remains aligned with other IFIs, such
as the IFC and Equator Banks, to address issues that had arisen during implementation of the
previous 2008 ESP, and to recognise a number of emerging sustainability issues. The revisions to the
ESP followed an extensive consultation with stakeholders, including civil society organisations,
industry associations, clients, other international financial institutions, and international organisations.
The ESMS is described in more detail in the Environmental and Social Procedures, which were
updated
in
2015
http://www.ebrd.com/what-we-do/strategies-and-policies/environmentalprocedures.pdf, and which outline the process by which Bank staff process and monitor projects in
accordance with the overall ESP framework.
In accordance with EBRD’s ESSF, all projects undergo environmental and social appraisal both to
help EBRD decide if the project should be financed and, if so, the way in which environmental and
social issues should be addressed in its planning, implementation and operation. The appraisal
process also identifies opportunities for additional environmental or social benefits. EBRD seeks
within its mandate to ensure through its environmental and social appraisal and monitoring processes
that projects are designed, implemented, and operated in compliance with applicable regulatory
requirements and good international practice.
All projects under the Facility will be categorised and structured to meet EBRD Performance
Requirements. These are further outlined below. Comprehensive monitoring, also further outlined
below, will be carried out by EBRD and technical consultants implementing the support of the
projects. Reporting to the GCF will be based on the results of this monitoring.
Sub-Project Categorisation
Each sub-project under the Feed-in-Tariff programme will be categorised either as A, B or C, to
determine the nature and level of environmental and social investigations, information disclosure and
stakeholder engagement required. The categorisation will be commensurate with the nature, location,
sensitivity and scale of the project, and the significance of its potential adverse future environmental
and social impacts. The rationale and justification for the assigned category of the project will be
documented.
A project is categorised:
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“A” when it could result in potentially significant adverse future environmental and/or social
impacts which, at the time of categorisation, cannot readily be identified or assessed, and which,
therefore, require a formalised and participatory environmental and social impact assessment
process.

“B” when its potential adverse future environmental and/or social impacts are typically sitespecific, and/or readily identified and addressed through mitigation measures. Environmental and
social appraisal requirements may vary depending on the project and will be determined by EBRD
on a case-by-case basis.

“C” when it is likely to have minimal or no potential adverse future environmental and/or social
impacts, and can readily be addressed through limited environmental and social appraisal.
In addition, a project will be categorised as “FI” if the financing structure involves the provision of
funds through financial intermediaries (FI) whereby the FI undertakes the task of sub-project appraisal
and monitoring.
Where insufficient information is available at the time of the categorisation, an Initial Environmental
and Social Examination will be carried out to collect sufficient amount of information on the nature,
location, sensitivity and scale of the project, and the significance of its potential adverse future
environmental and social impacts to allow for determining the appropriate category and scope of the
environmental and social investigations, information disclosure and stakeholder engagement
required.
Category A Projects
Within the Feed-in-Tariff programme projects likely to be categorised as A include larger wind farms
located in sensitive areas such as the Gulf of Suez. Such activities are also likely to be categorised
as I1, defined by the GCF as, “When an intermediary’s existing or proposed portfolio includes, or is
expected to include, substantial financial exposure to activities with potential significant adverse
environmental and/or social risks and/or impacts that are diverse, irreversible, or unprecedented.”
Projects categorised as A, or I1, will not be considered for financing under this GCF-EBRD
Framework.
Category B and C Projects
EBRD proposes to present to GCF for projects categorised as B or C on a non-objection basis. Such
projects will not be required to be brought to GCF’s Board for further assessment and approval, and
will be approved through EBRD’s established processes and implemented in line with the Bank’s
stringent Environmental and Social Sustainability Framework. Projects will be required to meet the
Bank’s Performance Requirements and GCF’s public disclosure requirements.
Performance Requirements, Exclusions, and Compliance with Relevant Laws and
Regulations
General
EBRD requires its projects to meet Good International Practice related to environmental and social
sustainability. To help clients and/or their projects achieve this, EBRD has defined specific
Performance Requirements (PRs) for key areas of environmental and social sustainability. EBRD has
adopted ten PRs, which are consistent with and mirror the overall structure, approach and issue
coverage of the IFC’s 2012 Performance Standards while specifically requiring projects to meet EU
environmental standards.
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Specific Performance Requirements
EBRD’s ten Performance Requirements are:
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PR 1 - Assessment and Management of Environmental and Social Impacts and Issues
PR 2 - Labour and Working Conditions
PR 3 - Resource Efficiency, Pollution Prevention and Control
PR 4 - Health and Safety
PR 5 - Land Acquisition, Involuntary Resettlement and Economic Displacement
If necessary, a Resettlement Policy Framework (RPF) will be developed to address potential land
acquisition or related issues in line with PS 5 requirements and those of the national laws and
regulations of the country. The RPF will also include screening criteria, eligibility criteria,
implementation procedures, institutional arrangements, valuation methods, generic entitlement matrix,
grievance and monitoring mechanisms, expected budget and capacity development plan (where
necessary). The RPF will also include procedures to develop a Resettlement Action Plan and
voluntary donation protocols.


PR 6 - Biodiversity Conservation and Sustainable Management of Living Natural Resources
PR 7 - Indigenous Peoples
There are no Indigenous Peoples in the Programme region, therefore an Indigenous Peoples
Planning Framework is not expected.
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PR 8 - Cultural Heritage
PR 9 - Financial Intermediaries
PR 10 - Information Disclosure and Stakeholder Engagement
Each PR defines, in its objectives, the desired outcomes, followed by specific requirements for
projects to help clients achieve these outcomes. Compliance with relevant national law is an integral
part of all PRs.
The full PRs can be found following this link.
Environmental and Social Assessment
Each sub-project considered under the EBRD-GCF framework will be assessed and approased
along the following lines:
Defining the scope and content of environmental and social assessment: For each project, the
EBRD will define the scope and content of the ESDD, information disclosure and stakeholder
engagement requirements that are proportionate to the potential environmental and social risks,
issues and impacts associated with the project, if known at this stage. For more environmentally
and/or socially complex or high risk projects, the EBRD may decide that a formalised ESDD plan
also needs to be prepared.
Reviewing existing information: ESDD starts with identification and a review of available relevant
environmental and social information related to the project. Such inf ormation is determined by
EBRD together with the client.
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Site visits: Depending on the nature of the project and the information received from the client,
EBRD may require a site visit to the project at the initial stage of the due diligence to determine
the detailed scope and content for the ESDD. Specific objectives will be defined for such visits.
Commissioning environmental and social assessment: The sub-project will be responsible for
ensuring that the environmental and social assessment complies with the PRs and provides the
Bank with adequate information to undertake the environmental and social appraisal. EBRD’s
role is to assist the client with this task and advise on the scope and content of the due diligence
studies required to meet the PRs.
The environmental and social assessment is expected primarily to be conducted by independent
consultants or other third party experts. In some cases the project or client may have in -house
specialist staff or retained consultants who can conduct the necessary work. The Bank may in
exceptional situations decide that the environmental and social assessment of a project is
appropriate to be undertaken internally by the Bank’s environmental and social specialists.
Environmental and Social Management and Action Plans
The client is required to take into account the findings of the environmental and social
assessment process and the outcomes of stakeholder engagement in order to develop and
implement a programme of actions to address the identified environmental and social impacts
and issues of the project as well as to determine any performance improvement measures to
meet the PRs.
Depending on the project, the ESAP may consist of a combination of documented operational
policies, management systems, procedures, plans, practices and capital investments,
collectively known as Environmental and Social Management Plans (“ESMP”). Components of
such plans or programmes may include, for example, a Biodiversity Action Plan, Emergency
Response Plan, Resettlement Action Plan, Livelihood Restoration Framework, Indigenous
Peoples’ Development Plan, Human Rights Action Plan, Stakeholder Engagement Plan and/or
other specific plans. Alternatively, these may be stand-alone documents.
Where the project does not meet the PRs from the outset, the client and the EBRD will in
addition to the ESMP agree on an ESAP, which will include technically and financially feasible,
and cost-effective measures for the project to achieve compliance with the PRs within a time
frame acceptable to EBRD. The ESAP is the key tool to structure projects to meet the PRs as
well as a key instrument for monitoring of the project’s ongoing environmental and social
performance by EBRD. The ESAP may also include measures for the client to manage
environmental and social risks and/or to improve their practices in line with the PRs in their other
operations that are associated with but not part of the project (see paragraphs 37 of the ESP
and 17-20 of PR 1).
If no corrective actions have been identified in the environmental and social assessment, an
ESAP would not be required.
Roles and Responsibilities for Managing Environmental and Social Requirements
EBRD’s Clients role and responsibilities
The Bank expects its clients to manage the environmental and social issues associated with the
projects to meet the PRs over a reasonable period of time. Projects involving new facilities or
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business activities will be designed to meet the PRs from the outset. If a proje ct involves
existing facilities or activities that do not meet the PRs at the time of Board approval, the client
will be required to adopt measures satisfactory to EBRD, that are technically and financially
feasible and cost-effective to achieve compliance of these facilities or activities with the PRs
within a time frame acceptable to EBRD. In addition, EBRD will work with its clients to manage
environmental and social risks consistent with the PRs in their other operations that are
associated with but not part of the project.
It is also the client’s responsibility to ensure that adequate information is provided so that the
Bank can undertake an environmental and social assessment in accordance with the ESP. The
client may be required to commission appropriate environmental and social studies and conduct
stakeholder engagement and cover the costs of these. The client is also expected to allow
EBRD representatives and independent consultants to access project facilities and records. The
client’s role also includes agreeing on the Environmental and Social Action Plan (“ESAP”) and
the environmental and social content of the Project Summary Document (“PSD”).
EBRD’s role and responsibilities
EBRD’s responsibilities are consistent with its role as an international financial institution
providing bank financing for projects through the use of EBRD’s resources approved by its
management and Board of Directors or other decision-making body. With respect to any
particular investment or technical co-operation project, the level of EBRD’s engagement is
determined by the nature and scope of the project, availability of donor funding, as well as the
specific circumstances of the collaboration and relationship with the client.
Stakeholder Engagement and Grievance Management
EBRD recognises the importance of open and transparent engagement between clients,
workers, local communities directly affected by projects and, where appropriate, other
stakeholders as an essential element of good international practice (GIP) and corporate
citizenship. Such engagement is also a way of improving the environmental and social
sustainability of projects. In particular, effective community engagement, appropriate to the
nature and scale of the project, promotes sound and sustainabl e environmental and social
performance, and can lead to improved financial, social and environmental outcomes, together
with enhanced community benefits. Stakeholder engagement is central to building strong,
constructive and responsive relationships which are essential for the successful management of
a project’s environmental and social impacts and issues. To be effective, stakeholder
engagement should be initiated at an early stage of the project cycle.
The Bank’s Performance Requirement 10 (PR10), as part of its larger Environmental and Social
Policy, requires all projects that are likely to have adverse environmental and social impacts and
issues on the environment, workers or the local communities directly affected by the project
(Category A) to identify and engage with stakeholders as an integral part of their overall
environmental and social management system (ESMS), the project’s environmental and social
assessment process and the environmental and social management plan.
Projects required to meet PR10 will need to conduct stakeholder engagement on the basis of
providing local communities that are directly affected by the project and other relevant
stakeholders with access to timely, relevant, understandable and accessible information, in a
culturally appropriate manner, and free of manipulation, interference, coercion and intimidation.
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More information on stakeholder engagement activities and PR10 can be found in EBRD’s
Environmental and Social Policy.
For projects that could have adverse environm ental and social impacts, clients are expected to,
as an integral part of the assessment process, identify all the project’s stakeholders and design
a plan for engaging with the stakeholders. Consultation should be meaningful to take the views
and concerns of stakeholders into consideration in planning, implementing and operating the
project. The client will identify the stakeholders potentially affected by and/or interested in the
project, disclose sufficient information about the impacts and issues arisi ng from the project and
engage with relevant stakeholders, in proportion to the potential impacts associated with the
project and level of concern.
For Category A projects, the client and the Bank will make available to the public the ESIA
documents. For private sector projects, the ESIA documents shall be available for a minimum of
60 calendar days prior to consideration of the project by the Board of Directors, for public sector
projects 120 calendar days prior to Board consideration. The ESIA documents are produced by
clients, and the EBRD makes them available without any comment or implied endorsement.
However, before disclosure, the ESD must consider the ESIA documents appropriate and fit for
purpose for the consultation process.
In addition, EBRD PRs contain specific requirements for consultation on projects that could
result in physical and/or economic displacement or affect Indigenous Peoples.
Grievance redress mechanism
EBRD requires its clients to be aware of and respond to stakeholders’ concerns related to the
project in a timely manner. For this purpose, the client will establish an effective grievance
mechanism, process, or procedure to receive and facilitate resoluti on of stakeholders’ concerns
and grievances, in particular, about the client’s environmental and social performance. The
grievance mechanism should be scaled to the risks and potential adverse impacts of the project:

The grievance mechanism process or procedures should address concerns promptly and
effectively, in a transparent manner that is culturally appropriate and readily accessible
to all segments of the affected communities, at no cost and without retribution. The
mechanism, process or procedure must not prevent access to judicial or administrative
remedies. The client will inform the affected communities about the grievance process in
the course of its community engagement activities, and report regularly to the public on
its implementation, protecting the privacy of affected individuals; and

Handling of grievances should be done in a culturally appropriate manner and be
discreet, objective, sensitive, and responsive to the stakeholders’ needs and concerns.
The mechanism should also allow for anonymous complaints to be raised and
addressed.
EBRD ha slaso established its own accountability mechanism, the Project Complaint Mechanism
(PCM), that has been established to assess and review complaints about Bank -financed
projects. It provides individual(s) and local groups that may be directly or adversely affected by
an EBRD project, as well as civil society organisations, a means of raising complaints or
grievances with the Bank, independently from banking operations.
PCM has two functions:
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•
a Compliance Review function which seeks to assess whether a Bank approved project
complies with relevant the EBRD’s policies, specifically relevant environmental policies
and project-specific provisions of the Public Information Policy, and
•
a Problem-solving Initiative which has the objective of restoring dialogue between the
parties, where possible, to trying to resolve the underlying issues giving rise to the
complaint or grievance. A problem-solving initiative might include independent factfinding, mediation, conciliation, dialogue facilitation, investigation or reporting.
Following the assessment of a complaint, there may be a recommendation for a Compliance
Review and/or Problem-solving Initiative, or neither.
E&S Monitoring
EBRD’s Environmental and Social Policy and Environmental and Social Procedures outline the
approach and process for monitoring Environmental and Social performance in its investments based
on tracking the implementation of the Performance Requirements. This covers monitoring activities
being undertaken by our clients, and the monitoring undertaken by EBRD staff through the review of
reports received, site visits and third party monitoring. The monitoring activities for each project are
determined on the basis of the environmental and social risks and impacts associated with the project
identified during the environmental and social assessment. They may also reflect any significant
stakeholder concerns and include an environmental and social project completion review or audit,
where relevant. As a minimum, EBRD reviews the Annual Environmental and Social Reports
prepared by clients on the environmental and social performance of the project, including updates on
the implementation of the Environmental and Social Management and/or Action Plans. EBRD staff
may also, as necessary, undertake site visits to review the compliance of the project with agreed
environmental and social requirements.
If the client fails to comply with its social and environmental commitments, as set out in the legal
agreements, EBRD may agree with the client remedial measures to be taken by the client to achieve
compliance. If the client fails to comply with the agreed remedial measures, the Bank may take such
action and/or exercise such remedies contained in the financing agreements that it deems
appropriate. EBRD will also review with the client any performance improvement opportunities related
to projects.
Annexes

Screening checklist
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Annex 1: Screening Checklist
Introduction
The Compliance Summary provides a checklist for a systematic review for identifying environmental and social riks and impacts in line with the EBRD
Environmental and Social Policy, as defined through the applicable Performance Requirements (PRs). Scope of compliance is all PRs applicable to non-FI
projects. The review is intended to provide a baseline against which to judge future performance of projects through the annual environmental and social
reporting process.
Guidance
For all PRs (Indicators with whole number references) provide a summary of overall compliance with the PR. Justification for any derogation from a PR should
be summarised and supporting documents referenced.
For each indicator within a PR, please complete the 3 steps below:
1.
Decide whether the indicator is applicable. For Category A and B projects the starting point is that all indicators are applicable unless the project
has no significant aspects relevant to the indicator (i.e. no risks), in which case the indicator should be scored "NA" and a brief summary of the reason
given. For Category C projects the starting point is all indicators are NA unless the project has a significant aspect relevant to the indicator (i.e. there is
a material risk).
2.
Decide whether an opinion is possible. If not (for example if the indicator will apply, but it is too early in the project) score as "NOP" and provide a
brief summary of why. Where lack of opinion represents a material omission to the review refer to where this is addressed in the report and summarise
any recommendations.
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3. Score the indicator as follows and provide brief justification.
EC
FC
PC
Exceeding Compliance:
The project has gone beyond the expectations of EBRD’s PR requirements. EBRD should be able to use
projects rated EC as a role model for positive Environmental and Social effects.
Fully Compliant:
The project is fully in compliance with EBRD’s requirements, and EU and local environmental, health and
safety policies and guidelines.
Partial Compliance:
The project is not in full compliance with EBRD’s requirements, but has systems, processes or mitigation
measure in place which are working towards addressing the deficiencies.
Material Non-compliance:
MN The project is not in material compliance with EBRD’s requirements, and the systems, processes and
mitigation measures in place are not working towards addressing the deficiencies.
4.
Comments/Issues: Provide a brief commentary on the relevance of this requirement for the project and an explanation of the chosen score.
5.
Actions Required: Where applicable, briefly describe any actions required by the client to achieve full compliance with each requirement. Where a
relevant action is included in the ESAP for this project, please provide a reference to the ESAP.
6.
PR Summary: Provide an overall summary against the PR, using the above compliance definitions with supporting commentary. In some cases it
may be sufficient to address a PR at summary level only, depending on Stage 1 above.
Note: The Material Non-compliance score (at both Indicator and PR level) has significant implications for Project approval and requires particular
care. In judging whether the measures sufficiently address deficiencies the consultant should consider in a structured way both the level of
residual (post-approval) risk and the level of confidence that the Project can successfully bring the issue into compliance with the Policy through
the ESAP. The table below illustrates the approach to be taken.
Risk
High
PC
MN
MN
Medium
PC
PC
MN
Low
FC
PC
PC
Medium
Low
High
Confidence
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KPI
Ref.
Performance Requirement
1
Score
Comments/ Issues
Actions Required
Assessment and Management of Environmental and Social Impacts and Issues
Summary:
1.1
Environmental and Social
Assessment
1.2
Environmental and Social
Management Systems
1.3
Environmental and Social Policy
1.4
Environmental and Social
Management Plan
1.5
Organisational Capacity and
Commitment
1.6
Supply Chain Management
1.7
Project Monitoring and Reporting
1
2
2
Labour and Working Conditions
Summary:
2.1
Human Resource Policies and
Working Relationships
2.2
Child and Forced Labour
1
Where the project represents a substantial extension to the client activities, confirm that Policy and supporting management systems and plans are
appropriate for the new activities.
2
At appraisal stage there will be limited information. Compliance assessment should address specific plans for monitoring and reporting (against for example
ESAP requirements) and also consider whether there is evidence of weak monitoring/reporting by client on other relevant projects - which may reduce
confidence in future performance.
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ESAP
Ref.
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KPI
Ref.
Performance Requirement
2.3
Non-Discrimination and Equal
Opportunity
2.4
Workers Organizations
2.5
Wages, benefits, and conditions of
work and accommodation
2.6
Retrenchment
2.7
Grievance Mechanism
2.8
Non-Employee Workers
2.9
Supply Chain
2.10
Security Personnel Requirements
Score
Comments/ Issues
Actions Required
ESAP
Ref.
3
Resource Efficiency and Pollution Prevention and Control
3
NB. Appraisal should carefully consider (and state) what regulations or standards have been applied to compliance assessment (eg EU, National, Sector Best Practice). Assessments
should address consideration of the performance of alternative techniques.
Summary:
3.1
Resource Efficiency
3.2
Pollution Prevention and Control Air emissions
3.3
Pollution Prevention and Control Waste waters
3.4
Greenhouse Gases
3.5
Water
3.6
Wastes
4
3
Will not be applicable to many projects at appraisal stage. However evidence, within the last 3 years of client approach to retrenchment which is not
compatible with the Policy should be taken into consideration.
4
Particular attention should be given to client demonstration of consideration of alternatives. Projects expected annually to produce more than 25,000 tonnes
of Co2 equivalent should provide an emission inventory and plans for annual reporting.
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KPI
Ref.
Performance Requirement
3.7
Hazardous Substances and
Materials
4
Score
Comments/ Issues
Actions Required
Health and Safety
Summary:
4.1
Occupational Health and Safety
4.2
Community Health and Safety
4.3
Infrastructure, Building, and
Equipment Design and Safety
4.4
Hazardous Materials Safety
4.5
Product and Services Safety
4.6
Traffic and Road Safety
4.7
Natural Hazards
4.8
Exposure to Disease
4.9
Emergency Preparedness and
Response
5
Land Acquisition, Involuntary Resettlement and Economic Displacement
Summary:
5.1
Avoid or minimise displacement
5.2
Consultation
5.3
Compensation for displaced
persons
5.4
Grievance mechanism
5.5
RAP/LRP documentation
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ESAP
Ref.
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KPI
Ref.
Performance Requirement
5.6
RAP/LRP implementation
5.7
Monitoring
6
Score
Comments/ Issues
Actions Required
Biodiversity and Living Natural Resources
Summary:
6.1
Assessment of Biodiversity and
Living Natural Resources
6.2
Conservation of Biodiversity
6.3
Sustainable Management of Living
Natural Resources
7
Indigenous People
Summary:
7.1
Indigenous People Assessment
7.2
Adverse Effects Avoidance and
Indigenous Peoples Development
Plan
7.3
Information Disclosure, Meaningful
Consultation and Informed
Participation
7.4
Grievance Mechanism and
Prevention of Ethnically Based
Discrimination
7.5
Compensation and Benefit-Sharing
7.6
Impacts/Relocation on Traditional or
Customary Lands and Cultural
Heritage
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ESAP
Ref.
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KPI
Ref.
8
Performance Requirement
Score
Comments/ Issues
Actions Required
Cultural Heritage
Summary:
8.1
Assessment and Management of
Impacts on Cultural Heritage
8.2
Consultation with affected
communities and other stakeholders
8.3
Project use of Cultural Heritage
10
Information Disclosure and Stakeholder Engagement
Summary:
10.1
Stakeholder Engagement Plan
10.2
Operational Grievance Mechanism
Overall Compliance
National Environmental, Social,
Health and Safety Requirements
EU Environmental, Social, Health
and Safety Requirements
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ESAP
Ref.
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Annex 2: Summary of Consultation Activities carried out for the Benban Solar Park site:
Date
Consultation
activity
Number of
participants
Phase
Information disclosed
Stakeholder(s)
engaged
Shared
documents
Community Feedback
15 Sep
2015
Scoping
meetings
84 persons
During SESA
preparation
- Information about the
SESA assignment and
the environmental
requirements
- EETC
- Developers
- Funding
Agencies (EBRD)
- NREA
- SESA consultant
PowerPoint
presentation
- Developers requested
information on the
environmental
requirements
- Cumulative impacts of the
project
- Their contribution to SESA
study
9 Sep
2015
Workshop
45 (about
half of them
are females
During SESA
preparation
- Information about the
project and CSR
- Information about
potential project
impacts
- 45 participants
aged between 11
to 39 years
Leaflet about
the project
- A list of community needs
was compiled
Sep
2015
Individual
interviews
20 persons
During the
data
collection for
the SESA
preparation
- Information about the
project in general
- Local
governmental
units and NGOs
- EETC
- NREA
No shared
documents
- Feedback about their
perception of the project
and their support and
positive attitude about the
Benban solar project.
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Date
Consultation
activity
Number of
participants
Phase
Information disclosed
Stakeholder(s)
engaged
Shared
documents
Community Feedback
8 Sep
2015
Radio
interview
NA
During the
public
consultation
project and
the SESA
preparation
- Information about the
project
- Information about
project impacts
- Community
engagement plan and
importance to
participate
- All community people
are invited to the
public events
NA
NA
NA
17 Sep
2015
Public
consultation
event in
Aswan
117 person
(89 males)
Public
consultation
phase of the
SESA
- All information related
to the project
- Potential E&S impacts
- Job opportunities
- Governorate
- Environmental
Affairs
- Media
- Electricity sector
- Water resources
- Benban villagers
- NGOs and civil
society
- Educational
sector
- Academic sector
- Local
Governmental
Units
- developers
- NREA
- Nontechnical
executive
summary
- Positive perception of the
project due to its limited
impacts
- Job opportunities to be
given primarily to the
community
- Capacity building activities
- Water resources
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Date
Consultation
activity
Number of
participants
Phase
Information disclosed
Stakeholder(s)
engaged
Shared
documents
Community Feedback
15 Nov
2015
Consultation
event with the
developers
42 persons
During the
SESA
preparation
- Information about the
Potential Impacts of
the project
- PowerPoint
presentation
- Developers requested
information on the
environmental
requirements
- Cumulative impacts of the
project
21 Nov
2015
Public
consultation
event in
Benban village
for two
developers
(FRV Shams
one and
Infinity solar)
350 person
(89 males)
Public
consultation
phase
- All information related
to the project
- Potential project
impacts
- Job opportunities
- EETC
- Developers
- Funding
Agencies (EBRD,
IFC and EIB)
- NREA
- SESA consultant
- Governorate
- Environmental
Affairs
- Media
- Electricity sector
- Water resources
- Benban villagers
- NGOs and civil
society
- Educational
sector
- Academic sector
- Local
Governmental
Units
- developers
- NREA
- Members of
People Assembly
- Nontechnical
executive
summary
- They were pleased with
consultation approach as
the project consulted them
in their village.
- Positive perception of the
project due to its limited
impacts
- Job opportunities to be
given primarily to the
community
- Capacity building activities
- Water resources
- Fares and other
surrounding villages roles
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