Ghoubet Djibouti Windfarm Project

The Ghoubet Wind Project (“the Project”) is being developed by a consortium, including African Finance Corporation (AFC), FMO (Dutch Development Bank), Climate Investor One (CIO) and Great Horn Investment Holdings (GHIH) (“the Consortium”). The Consortium has approached MIGA to guarantee their investment in the development of the Project. The Consortium will establish to a Project company to manage construction and operate the Project.

The Project involves the design, construction, operation and maintenance of a 60-megawatt (MW) wind farm in the Arta Region along the border with the Tadjura Region of Djibouti. The 395-hectare Project site is located approximately one kilometer west of Lake Ghoubet, where the N9 and N10 roads intersect. The Project will provide a total 60 MW of generating capacity, through approximately 15 wind turbines, each with a capacity of up to 4.8 MW and 150 m tip height (final number of turbines and turbine capacity will be determined in collaboration with the Engineering, Procurement and Construction (EPC) contractor). Approximately 10 km of access roads will be constructed within the Project area, and during construction, there will be a temporary construction compound with administration buildings and worker accommodation. A temporary concrete batching plant will also be required. Generated electricity will be fed via either above ground collector lines or buried cables to a substation within the Project site. A 230kV overhead transmission line, approximately 3.5 km in length, will be constructed by the Project to connect the windfarm substation to a planned Ghoubet substation (not funded as part of this Project) and the national grid system.

The Ghoubet substation and a double-circuit 230kV transmission Line from the substation to the existing Jaban substation (70 km approximately – near Djibouti City) is being constructed by Electricité de Djibouti (EDD)as part of the overall grid development plan for Djibouti. As the construction of this line is not dependent on the Project, it is not considered an Associated Facility (as defined in Performance Standard 1).

The nearest settlements are Lac Assal (approximately 24 households, 140 residents) located 500m north of the Project and Cité Moumina (approximately 105 households, 640 residents) located 600 m south of the Project. The Project site is rocky and barren with little vegetation and is not used by local communities other than intermittently as part of a migratory route for livestock. There are no Important Bird Areas (IBA) or Protected Areas within the discrete management unit considered for the Project.

The Project is currently in pre-construction phase, and an EPC contractor has yet to be engaged.  Construction of the Project is expected to start in mid-2019 and take up to 18 months. It is estimated that the Project will require around 300 people during peak construction and up to 12 during operations.

According to MIGA’s Environmental and Social Sustainability Policy (2013), the Project has been categorized B as the expected risks and impacts are site specific and can be managed through the appropriate application of internationally recognized practices and measures for this type of Project. Key environmental and social (E&S) issues are expected to include the establishment and implementation of suitable management system and procedures; appropriate Human Resources (HR) policies and procedures, including occupational health and safety (OHS) provisions for all workers, including contractor employees; waste and traffic management during construction; and finally, potential bird and bat mortality due to collision with turbines.

While all Performance Standards are applicable to this Project, based on our current information indicates that the Project will have impacts which must be managed in a manner consistent with the following Performance Standards:

• PS1: Assessment and Management of Environmental and Social Risks and Impacts
• PS2: Labor and Working Conditions
• PS3: Resource Efficiency and Pollution Prevention
• PS4: Community Health, Safety and Security
• PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources
• PS8: Cultural Heritage

PS 5 Land Acquisition and Involuntary Resettlement does not apply, as the land area required for the Project is owned by the Government. It is used intermittently as a transhumance route, which will not be not affected by the Project (i.e. the area will not be fenced, and people will be able to move through unencumbered). The land is not currently suitable for any other use.

According to the social assessment conducted for the project, the Afar people, who inhabit the Project area, are an ethnic majority in Djibouti (~30% of total population), as such, PS 7 Indigenous Peoples does not apply.

In addition to the Performance Standards, the World Bank Group (WBG) Environmental, Health and Safety (EHS) General Guidelines; Guidelines for Wind Power Projects; and Guidelines for Electricity Transmission and Distribution apply to this Project.

The following documents were reviewed by MIGA:

• Djibouti Windfarm Project (DWP) | Environmental and Social Impact Assessment – Non-Technical Summary. Volume I. August 2018
• Djibouti Windfarm Project (DWP) | Environmental and Social Impact Assessment – Final, Volume II, July 2018
• Djibouti Windfarm Project (DWP) | Environmental and Social Impact Assessment – ESIA Annexes, Volume III, July 2018
• Letter from the Ministry of Housing, Urban Planning, and Environment on the conditional approval of the Environmental and Social Impact Assessment Report, 27 September 2018
• Ghoubet Wind Project Birds and Bats Baseline Study. First interim report. Strix. September 2018
• Plan de Gestion Integree de la Zone Cotiere e Djibouti. Ministry of Housing, Urban Planning, and Environment, June 2005
• Ghoubet Wind Project Community Investment Programme: Proposed Actions and Schedule. Memo from Project E&S Manager to the E&S Committee for Review. 13 September 2018
• Djibouti Wind Project Stakeholder Engagement Plan draft, September 2018
• Note d’explication sur le concept de populations indigènes et autochtones. Populations indigènes et autochtones à Djibouti. INSUCO. January 2018.
• DWP Health, Safety, Social and Environmental (HSSE) Policy, October 2018

MIGA’s review also included a site visit in October 2018, which included a visit to the Project area, meetings with the representatives of the Consortium, social consultant (Insuco), local communities (Lac Assal and Cite Moumina) and relevant government authorities.

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 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 Performance Standards objectives.

PS1: Assessment and Management of Environmental and Social Risks and Impacts

The Project will have standard construction based risks and impacts, the most important resulting from: (i) the transport of turbines, machinery, material and workers into the Project site, (ii) the installation of electrical components, (iii) use of water resources (particularly in a water scarce region); (iv) activities involving workers working from heights, and (v) ensuring all contractors consistently apply E&S mitigation and management measures to potential risks and impacts.

While operational risks and impacts are generally low, the Project, in addition to standard mitigation measures, will: (i) carry out  post-construction monitoring of birds and bats and follow an adaptive management approach to mitigate impacts; and (ii) prevent and manage against potential OHS risks that result from activities that require working from heights.

Environmental and Social Assessment and Management System

An Environmental and Social Impact Assessment (ESIA) was developed for the Project by a consortium of international consultants (ERM, INSUCO and Combined Ecology). The ESIA is comprehensive; and was completed with reference to Djiboutian legislation, IFC Performance Standards (2012) and World Bank Group Environmental, Health and Safety (EHS) Guidelines. The ESIA was approved by the Ministry Housing, Urban Planning and Environment in September 2018. In addition to the ESIA, the Consortium prepared an internal gap analysis against the Performance Standards.

The ESIA baseline, impact assessment and recommended mitigation measures are largely in line with MIGA’s requirements; however, there are a few gaps related to biodiversity (see discussion under PS 6), cumulative assessment (primarily including the transmission line), and water resource use. Supplementary studies are ongoing to address these gaps.

To ensure better understanding of the potential risks and impacts associated with the 70 km transmission line to be constructed by EDD, the Consortium will undertake a desk-based risk assessment and expand their bird and bat study/risk assessment to include the potential impacts of the transmission line (ESAP item 1). As the Project has no control and very little influence over the construction of the transmission line; the results of the studies and any recommended measures will be communicated to EDD. Where possible, measures to address any identified impacts related to biodiversity will also be incorporated into the Project’s Biodiversity Action Plan (see PS 6).

Management Program and Monitoring

The Consortium’s Project Steering Committee has established a Health, Safety, Social and Environment (HSSE) sub-committee.  The HSSE sub-committee’s mandate is to oversee the HSSE aspects of the Project, including the development of the HSSE Management System (MS).

The HSSE MS is in the process of being established (ESAP item 2), and early drafts of the HSSE Policy and institutional structure were shared with MIGA. The HSSE MS will include: an HSSE Policy; organization structure; roles and responsibilities; identification of applicable environmental and social obligations; identification of environmental and social aspects and impacts relevant to the Project; an overview of the environmental procedures to ensure compliance with the Project’s environmental and social obligations; auditing requirements and reporting requirements.

The Environmental and Social Management and Monitoring Plan (ESMMP) included in the Project’s ESIA, describes measures to be implemented to avoid, reduce and / or mitigate identified impacts. To ensure that adequate resources are available, the government required the Project to estimate the budget needed for the implementation of the ESMMP as a condition of approval.

The Project is currently engaging with the preferred EPC contractor. HSSE requirements were incorporated into the EPC bidding documents and the draft contract. The Consortium’s Health, Safety and Environment (HSE) Manager also participated on the EPC contractor selection process. The EPC contractor will be required to develop an HSSE MS for construction (ESAP item 3), which is consistent with the overall HSSE MS of the Project. The EPC will require all sub-contractors to implement the construction HSSEMS. As part of the overall HSSE MS, the Project will develop a plan for the management of contractors and sub-contractors.

An Owner’s Engineer (OE) has been engaged, and will have a role in ensuring implementation of the HSSE MS. One person will be based on site throughout the construction period to monitor HSSE. The OE will also have one HSSE auditor, who will visit the project at least three times over the construction period, to verify HSSE compliance.

Organizational Capacity and Training

The Consortium has engaged an international HSE Manager with knowledge, skills and experience required to implement ESIA commitments, drive the development of the HSSE Management System (MS), and ensure that the Project is developed in accordance with the Performance Standards. In addition to the HSE Manager, the Consortium has engaged a suitably qualified Community Liaison Officer (CLO). An international social consulting firm is in the process of being engaged to provide ad hoc support to the CLO, and undertake discrete studies, as needed.  The consortium, with the support of the OE, will ensure that the EPC contractor engages suitably qualified HSE Manager and officers (ESAP item 4). All staff will receive HSSE training commensurate with their role (see PS 2).

Emergency Preparedness and Response

Framework Emergency Preparedness and Response Plan (“EPRP”) will be prepared by the Consortium as part of their HSSEMS (ESAP item 2). The EPC will be required to have its own site specific EPRP, based on the Consortium framework EPRP. The EPRP will include procedures for incident and emergency management, call out and mobilization, line of responsibilities and roles, interfaces with external organizations and institutions, contingency plans for specific scenarios and a communications directory. The EPRP will include consideration of worker and public injuries, property damage, fire, environmental damage and natural disasters.

Stakeholder Engagement

Stakeholder engagement was initially carried out as part of ESIA scoping in December 2017 and has been ongoing ever since. Extensive stakeholder engagement was undertaken as part of the social impact assessment conducted for the Project, including population census, household surveys, thematic focus groups, individual interviews and public consultation meetings. Information on Project risks, impacts and opportunities were provided. Reports indicate that community members and authorities expressed strong support for the Project. Community concerns primarily related to the impact of influx of workers on the community’s security and living standards, as well as expectations regarding potential job opportunities and development benefits, particularly, access to water. A Stakeholder Engagement Plan (SEP) has been drafted, which will be finalized and implemented prior to start of construction (ESAP Item 2). The Project will ensure that nomadic populations who may cross through the area are included in stakeholder engagement activities.

Reporting

As part of the HSSE MS, the Consortium will develop and implement a program of reporting for construction and operation of the Project. Reporting will be done in form of HSSE checklist, incident record register, and regular environmental and social performance reports. During construction, the EPC and OE will submit regular reports to the Consortium, which will be shared with MIGA. The Project will also provide MIGA with a semi-annual environmental and social monitoring report during construction, and an annual environmental and social monitoring report during operations.

PS2:  Labor and Working Conditions

As indicated above, at peak construction, there will be approximately 300 workers on site. During operations, up to 12 employees will be required. Local residents will be given preference for employment opportunities.

Human Resources Policies and Procedures

The Consortium will develop and implement a Human Resources Policy and Management Plan (ESAP item 5) setting out recruitment procedures, training requirements and targets around the hiring of local workers. The Human Resources Management Plan will also include measures to ensure non-discrimination and equal opportunity. The Human Resources Policy and Management Plan will adhere to Djibouti national labour regulations, ILO core conventions and MIGA PS 2. Priority will be given to suitably qualified local workers (inclusive of women). The Consortium will make a reasonable attempt to accommodate the employment needs of the communities by assessing the qualifications and developing a local content plan (ESAP item 5).

The EPC contractor will be required to develop their own human resource (HR) policies and procedures, which will be consistent with the overall policy and procedures developed by the Consortium.

Worker Accommodation

The Project workforce (up to 300 workers during peak construction) will be accommodated on site in a staff compound. A Worker Accommodation Plan will be prepared to ensure that all workers are provided with accommodation in accordance with the requirements of PS 2 and the guidance provided in the IFC / EBRD guidance note on Worker Accommodation (ESAP item 2).

Working Conditions and Terms of Employment

The Project will avoid discrimination and ensure equality of opportunity during the processes of employing its own and contracted workers, and such provisions will be included in the HR Policies, plans and procedures described above.

Employee Grievance Mechanism

As part of the HR policies and procedures, the Project will establish a workers’ grievance mechanism that covers all workers (including direct employees and contractors), and is accessible and transparent, providing timely feedback to claimants without risk of retribution and allowing anonymous complaints to be raised (ESAP item 6).

The grievance mechanism will be an internal process for responding to feedback and concerns; it will not impede access to other judicial or administrative remedies that are available to workers under law or through any collective (union) agreement.

Occupational Health and Safety

The Project will develop and implement an Occupational Health and Safety (OHS) Management Plan as part of the overall HSSE MS. The OHS Management Plan will incorporate measures to prevent accidents, injury, illness and disease. For construction phase, the Consortium will ensure that the OHS requirements are incorporated in the Contract with the EPC contractor and their sub-contractors and that the OHS MS is implemented on-site. To minimize the risks associated with the prevalence of khat use in the local community, the Project will develop and implement substance abuse policies and procedures. The Project will establish a site clinic to provide workers with emergency medical treatment. The site clinic will ensure there is sufficient capacity to meet the day to day needs of Project staff.

Workers’ Organizations

Djibouti law provides for the right to form and join independent unions, bargain collectively and strike and prohibit anti-union discrimination. The Project will ensure that project specific HR policies and procedures comply with the national law and engage with workers’ representatives and workers’ organizations and provide them with information needed for meaningful negotiation in a timely manner.

PS3:  Resource Efficiency and Pollution Prevention

Greenhouse gases

The Project will not contribute to greenhouse gases (GHG) emissions, except during the construction period due to the consumption of fuel by vehicles and heavy machinery. During operations, assuming a moderate average capacity factor of 40%, it is estimated that this Project will avoid the emission of approximately 150,000 tons of carbon dioxide equivalent (tCO2e) per year.

Water Resource Use

During construction, water will be required for construction activities (e.g. producing concrete for foundations), domestic purposes and drinking water for the construction teams. It is estimated that, in total, 4 million liters will be required for construction, approximately 2 million liters for installation of concrete foundations and 2 million for domestic use, basic sanitation and drinking. It is proposed that water for construction will be supplied by the Office National de l'Eau et de l'Assainissement de Djibouti (ONEAD), which has exclusivity to supply water in Djibouti. ONEAD, which primarily sources water from Ethiopia, has confirmed that they are able to supply the water required for the Project; however, the potential impact of that supply (i.e. if it will reduce the amount of water available to rural communities), has not yet been determined. A desk-based water resource study will be undertaken to determine whether the water allocated to the Project from ONEAD affects the availability of water available for rural communities in Djibouti. Depending on the results of the study, an alternative water source will be identified if needed (ESAP item 7).

Water requirements during operations are minimal and limited to domestic use, sanitation and drinking water. 

Wastewater

Wastewater will be generated from human activities such as hand washing on‐site and from water used for construction purposes such as washing tools covered in excess cement. Sewage will also be generated on site and thus self‐contained portable toilets will be installed in a designated space. As the Project is located in water scarce area, measures will be incorporated into construction process and camp design (e.g. low flow taps; covered storage) to maximize water re-use and minimize effluent. An approved contractor will be employed to regularly empty and maintain any portable toilet facilities and septic tanks. Sewage removal will be managed by ONEAD and is expected to involve use of a contractor to uplift and transport the sewage to a licensed sewage treatment facility.

Noise

All construction noise will be temporary in nature. The EPC will minimize noise disturbance impacts by restricting the use of noise emitting equipment to daytime hours where construction methods feasibly allow for this. Localized blasting and rock hammering will be required to excavate turbine foundations. The mitigation measures for these actions will be designed and implemented to reduce noise. This will include sharing of information with the community in advance of particularly noise activities. Noise modelling, considering turbine locations, dimensions and technical specifications was undertaken to determine the potential impact of operations on local communities. It is planned that turbines will be sited at least 500 m from any dwellings to mitigate noise impacts. Modelling indicates that noise emissions will be within WBG EHS Guideline limits at sensitive receptors.

Shadow Flicker

A shadow flicker assessment was undertaken as part of the ESIA, which indicated that 3 households may experience shadow flicker exceeding 30 hours per year. As the model was based on very conservative assumptions, it likely over-estimated the duration of occurrences at any specific location. The Project is designed to maintain a minimum of 500 m between the turbines and nearby dwellings, which will mitigate shadow flicker to within the levels recommended by the IFC. Monitoring will be undertaken during operations, and measures will be developed and implemented to address to any shadow flicker impact identified.

Solid Waste and Hazardous Materials Management

Solid waste will be generated during the construction phase and will likely consist of biodegradable waste such as cleared vegetation (very limited); general waste such as paper, packaging, plastics, food waste; and construction related waste such as rubble, metal off cuts, etc. This waste will be temporarily stored on-site and removed by the specialized contractor to the nearest suitable waste disposal. Due to the limited waste management facilities in Djibouti, a detailed assessment to identify suitable waste management facilities and / or contractors suitably qualified to process waste will be undertaken by the EPC contractor prior to construction (ESAP item 2).

Any spoil will be disposed of as close to the site as possible; it can be used for infilling other excavations, or used as fill material for building embankments, berms etc. Surface material and spoil will not be mixed and will be stored separately to be used as backfill or for on‐site landscaping.

A detailed Waste Management Plan will be developed and implemented by the EPC for the construction phase, which will list the quantities and types of waste to be generated, and identify recommendations of reuse, recycling and final disposal of waste material (ESAP item 2). Hazardous materials will be stored in containers transiently until their final disposal. A licensed contractor will be engaged to dispose of hazardous waste.

PS4:  Community Health, Safety and Security

Potential community health and safety issues associated with the Project include traffic safety (particularly during construction), impacts associated with blasting, impacts associated with in-migration of the project workforce and impact on community water resources. One of the most significant risks to the community is associated with the use of heavy vehicles to transport the turbines and other large equipment to the Project site during the construction phase. All components will be transported to the Project site via national roads- RN3, RN1 and RN9. National roads are generally in good condition and will be capable of handling up to 180 t loads. There will also be an increase in light vehicles transporting workers to and from site. The EPC contractor will be required to develop and implement a Traffic Management Plan, which will also include specific emergency preparedness and response measures to be implemented with the assistance of local authorities (ESAP Item 2).

An influx management plan, which will include consideration of gender-based violence and infectious disease transmission, will be prepared and implemented (ESAP item 2). The Project will implement a Workforce Code of Conduct for construction workers, governing their behavior and interactions with local residents. The Workforce Code of Conduct will be clearly explained to all workers, including contract workers, during inductions and toolbox sessions to ensure those who cannot read or write fully understand the expectations of the Project with respect to code of conduct.

As part of the Stakeholder Engagement Plan, the Project will implement a Community Grievance Mechanism, for local residents, allowing local residents to raise concerns about the behavior of Project and contract staff. Stakeholders will be made aware of the key guiding principles of the mechanism, as well as how and where they can submit grievances (ESAP item 6).

During construction, access to the Project site will be restricted by security stationed at the main access points. Active construction areas and areas that present potential risk (e.g. excavated areas) will be appropriately sign posted and fenced. The substation will also be fully fenced to prevent unauthorized access.

Security Personnel

The site currently has 2 unarmed security personnel guarding the meteorology mast. During construction, the EPC will engage a security contractor. A Security management plan will be prepared, and security personnel will be appropriately trained in the Code of Conduct to ensure that interactions with local communities are cordial and professional (ESAP item 2).

PS6:  Biodiversity Conservation and Sustainable Management of Living Natural Resource

Potential biodiversity impacts include land clearance and habitat destruction, disturbance to wildlife due to vehicles, machinery and workforce onsite and collision risk for birds and bats during turbine operation. The site lies in the Ethiopian xeric grasslands and shrublands global ecoregion. The Project site is dominated by undulating basalt outcrops with small rocky (dusty) plateaus surrounded by mainly southeast oriented rainwater drainage channels (dry wadis). Vegetation within the Project site and surroundings is very low in density and diversity and is mostly aggregated in the dry wadis. It is predominantly comprised of a few native drought resistant trees. It is expected that the avoidance of these channels and removal of these low numbers of trees and shrubs can be avoided through siting of turbines. Based on the findings to date, the Project Area is considered ‘natural habitat’ according to PS 6. ESIA studies indicate that the sensitivity of terrestrial biodiversity resources is low, as the habitats and majority of species present on site are common and widespread across Djibouti. A Biodiversity Action Plan (BAP) will be developed, which targets ‘no net loss’ of key biodiversity values (i.e. the Egyptian Vultures and Dorcas Gazelle – see below) (ESAP item 9). The BAP will include metrics for post-construction monitoring to confirm no net loss.

Vantage Point (VP) baseline surveys were undertaken in line with best practice guidance for onshore windfarms established by Scottish National Heritage (SNH, 2014) to estimate the time bird species spent flying over the defined survey area (project footprint and surrounding area), the relative use of different parts of the defined survey area and the proportion of flying time spent within the upper and lower height limits as determined by the rotor diameter, rotor hub height and rotor height. The VP surveys covered the late winter and early spring migration period and provide representative coverage of the use of the Project site and transmission line by birds during this period. Survey data, however, was not gathered during other seasons, particularly during the northern hemisphere summer and autumn seasons; and therefore, additional surveys are required to achieve a more comprehensive baseline and ensure variation between different seasons is captured.

Baseline surveys have identified 39 bird species in the Project area, including 7 raptor species and 5 soaring bird species. Of these, only one, the Egyptian Vulture (Neophron percnopterus), is IUCN-listed Endangered.  Egyptian vultures are in rapid decline and are susceptible to collision with turbines and transmission lines, as well as electrocution with some designs of transmission line. Field observations indicate that there is at least one pair of Egyptian Vultures residing close to the Project site. Based on the information received thus far, it is likely that the pair of Egyptian Vultures on site are resident birds, which are present year-round.  

One bat survey was undertaken as part of the ESIA, which recorded the presence of one individual bat, identified to likely be an African Trident bat (IUCN-listed Least Concern). There were no signs or sightings of bats during walk over surveys and surveys of potential roosting sites in local warehouse and buildings. The habitat on the Project site provides limited foraging opportunities for bats with no permanent water features and sparse vegetation. Regardless, as the one survey undertaken is considered only a snapshot in time, additional bats surveys are currently being undertaken, the findings of which will be incorporated into the BAP as required.

There is currently no baseline of bird species present in the right of way of the 70 km 230 kV transmission line, so it is not possible to determine the potential impact of this line. As indicated above, to ensure better understanding of the potential cumulative impacts in the Project area, the Consortium will expand the scope of the additional bird and bat studies which are currently being undertaken to include consideration of the potential impacts of the transmission line. These findings will be incorporated into the Biodiversity Action Plan (BAP) to the extent that the Project has control over measures. Additional measures outside of the control of the Project will be communicated to EDD (ESAP item 8).

Four mammal species were recorded on site within the three-month study period, one of which (Dorcas Gazaelle), which was spotted only twice, is IUCN-listed Vulnerable. Measures to avoid impact on the Dorcas gazelle will be incorporated into the BAP. Desk studies indicated that two further species of conservation significance may be present at site – the striped hyena (IUCN-listed Near Threatened) and the Djibouti whip snake, which is not IUCN-listed, but is endemic to Djibouti. Ongoing monitoring during pre-construction and construction will confirm whether the hyena is present on site, and the BAP will include measures (e.g. appropriate waste management) to reduce the potential for attracting this species to site. Construction staff will be sensitized to the behavior and habitat of the whip snake to ensure that this species can be identified during the walk-over surveys of turbine foundation sites, which will be undertaken prior to any disturbance.

The monitoring program in the construction environmental management plan includes monitoring of bird and bat impacts.  During operations, the ESMMP includes measures for regular monitoring of bird and bat activity and impact in the Project area. Such monitoring will include post-construction in-flight activity monitoring, bird and bat carcass search surveys. The Project will report priority bird fatalities to authorities and lenders in a timely manner and provide bi-annual monitoring reports.

PS8: Cultural Heritage

Thirty‐five non‐designated cultural heritage sites were identified within the study area, including two cemeteries and multiple stone enclosures. The layout of turbines on the site has been designed to avoid impact on the two identified cemeteries. Prior to construction, the EPC contractor will also be required to physically demarcate the cemeteries to prevent disruption (ESAP item 10). Consideration of potential archaeological and cultural heritage resources will be incorporated into pre-excavation site walk-over procedures, and the EPC will develop and implement a chance find procedure for the construction phase (ESAP item 2).

The ESIA regulation in Djibouti is still evolving. The ESIA is regulated by the Environmental Code (Law n°51/AN/09/6 L) and the updated Environmental Impact Assessment (EIA) Procedure (Decree n°2011‐029/PR/MHUEAT). EIA Procedure specifies categories of projects requiring either a summary EIA or detailed EIA.          

A full ESIA was undertaken for the Project in 2018, submitted to the Ministry of Housing, Urban Planning, and Environment, and was approved with conditions in September 2018. The condition of approval was the development of a budget and mechanism for budget disbursement for implementation of the ESMMP. This estimate was completed and submitted to the Ministry in January 2019.  

There are three villages bordering the project area: 1) Cité Moumina, 600 m south of the project perimeter with a total population of approximately 640 inhabitants; 2) Lac Assal village, 500 m north of the perimeter with a total population of approximately 140 inhabitants; and  3) Layta village, 1 km from the western limit of the perimeter where most of the inhabitants moved to the recently built Cité Moumina.

The Project has engaged a community liaison officer to manage implementation of the SEP. The project will develop and implement a Community Investment Program (CIP) in consultation with the local community prior to start of construction. The CIP will include consideration of the needs of all stakeholders including women, elderly, youth and vulnerable groups (ESAP item 11). To maximize the development impact, community investments should be coordinated to the extent possible with other developments in the area such as Salt Investment Company and the World Bank financed geothermal project (ESAP item 11).

MIGA supports its clients (as defined in MIGA Policy on Environmental and Social Sustainability) in addressing environmental and social issues arising from their business activities by requiring them to set up and administer appropriate grievance mechanisms and/or procedures to address complaints from Affected Communities.

In addition, Affected Communities have unrestricted access to the Compliance Advisor/Ombudsman (CAO), the independent accountability mechanism for MIGA. The CAO is mandated to address complaints from people affected by MIGA-guaranteed business activities in a manner that is fair, objective, and constructive, with the goal of improving environmental and social project outcomes and fostering greater public accountability of MIGA.

Independent of MIGA management and reporting directly to the World Bank Group President, the CAO works to resolve complaints using a flexible, problem-solving approach through its dispute resolution arm and oversees project-level audits of MIGA’s environmental and social performance through its compliance arm.

Complaints may relate to any aspect of MIGA-guaranteed business activities that is within the mandate of the CAO. They can be made by any individual, group, community, entity, or other party affected or likely to be affected by the environmental or social impacts of a MIGA-guaranteed business activity. Complaints can be submitted to the CAO in writing to the address below:

Compliance Advisor/Ombudsman
International Finance Corporation
2121 Pennsylvania Avenue NW
Room F11K-232
Washington, DC 20433 USA
Tel: 1 202 458 1973
Fax: 1 202 522 7400
E-mail: cao-compliance@ifc.org

• Djibouti Windfarm Project (DWP) | Environmental and Social Impact Assessment – Non-Technical Summary. Volume I. August 2018
• Djibouti Windfarm Project (DWP) | Environmental and Social Impact Assessment – Final, Volume II, July 2018
• Djibouti Windfarm Project (DWP) | Environmental and Social Impact Assessment – ESIA Annexes, Volume III, July 2018

The above listed documentation is available electronically as PDF attachments to this ESRS at www.miga.org.  It is also available for viewing at the following locations:

From the Djibouti Wind Project Consortium

C/O The Project Manager

Africa Finance Corporation

3a Osborne Road, Ikoyi Lagos, Nigeria

+234 1 279 9600

info@africafc.org

www.africafc.org