Environmental and Social Review Summary
This Environmental and Social Review Summary (ESRS) is prepared by MIGA staff and disclosed prior to the date on which MIGA’s Board of Directors considers the proposed issuance of a Contract of Guarantee. Its purpose is to enhance the transparency of MIGA’s activities. This document should not be construed as presuming the outcome of the decision by MIGA’s Board of Directors. Board dates are estimates only.
Any documentation that is attached to this ESRS has been prepared by the project sponsor, and authorization has been given for public release. MIGA has reviewed the attached documentation as provided by the applicant and considers it of adequate quality to be released to the public but does not endorse the content.
A consortium led by the Sponsors, JCM Power Corporation (JCM) and InfraCo Africa Limited, has been selected by Electrical Supply Corporation of Malawi Limited (“ESCOM”), the state-owned electricity utility of Malawi, by way of competitive tender, to develop, construct and operate a 20-megawatt (MW) alternating current solar photovoltaic (PV) power plant (“the Project”) in Golomoti in the Dedza District of Malawi. The PV power plant will include a short, approximately 0.5 kilometer (km) transmission line to connect the solar power plant to the existing substation (operated by ESCOM), as well as an 80 meter access road extending from the northeast highway (M5) to the Project site.
The electricity generated by the plant will be sold to ESCOM (off-taker) and will be transferred to the national grid via the existing substation. The Sponsors will also install a 5MW/10MWh battery energy storage system (“BESS”) co-located with the solar PV plant, the first such unit in Malawi. This BESS will be financed by a separate grant from the Innovate UK Energy Catalyst program.
JCM is a Canadian-based independent power producer (IPP) dedicated to accelerating social, economic and environmental sustainability in high growth markets through the development, construction and operation of renewable energy infrastructure. JCM’s focus is on projects in Sub-Saharan Africa, South Asia and Latin America. InfraCo, is a private investment company, established in 2004 and funded by the governments of Austria, the Netherlands, Switzerland, and the UK. Past projects have mobilized over US$2bn of investment in infrastructure sectors in Sub-Saharan Africa, including projects in Guinea, Malawi, Nigeria, Tanzania, and Zambia.
A special purpose entity Golomoti JCM Solar Corporation Limited (“Project Enterprise or PE”) was registered in Malawi for the purposes of developing and operating the Project. The Project structure includes two sponsors, JCM and InfraCo. JCM is investing through a UK-based intermediary company – JCM Golomoti UK Limited, which acts as a MIGA Guarantee Holder.
The Project site is located in the Central Region of Malawi, approximately 47 km from the Dedza District Centre and within the Kachindamoto Traditional Authority (TA) and the Pitala Group Village. The plant infrastructure will sit on 111.75-hectare (ha) plot of land on a greenfield site, and includes the components of a solar park, transformers, inverters, a substation, associated cabling, access road, a maintenance/workshop area, storage, workers’ accommodations, and offices. The plant is located on existing farmlands and a few residential areas exist near the Project and transmission line easement/wayleave.
The Engineering, Procurement and Construction (EPC) of the Project will be implemented through split contracts (e.g., civil works, electrical, engineering), overseen by the PE. A similar approach will be taken for Operations and Maintenance (O&M). The PE is responsible for construction of the 0.5 km transmission line from the Project site to the existing Golomoti substation, as well the 80m access road. Once the transmission line is constructed, the line will be transferred to ESCOM and as owners, ESCOM will be responsible for ongoing O&M.
The construction labor force is from the local communities which means they reside in their residences. Labor force from outside of the communities is residing on site in worker’s accommodations built by the PE. The Project is well under construction with commissioning expected to commence December 2021 and it is expected that the in January / February 2022 the Project will be commissioned. Once construction is completed, there will be a building dedicated to O&M, which will include storage space, offices, conference rooms and a kitchen.
This is a Category B project according to MIGA’s Policy on Environmental and Social Sustainability (2013). The Project is expected to have potentially limited adverse Environmental and Social (E&S) risks, which will be few, site-specific, largely reversible, and readily addressed through mitigation measures. These impacts can be avoided or mitigated by adhering to applicable Performance Standards (PSs), procedures, World Bank Group (WBG) Environmental Health and Safety (EHS) guidelines and design criteria.
During construction, key E&S risks and impacts include air and noise emissions, management of environmental, labor and occupational health and safety (OHS) practices, influx of construction workers, ground water abstraction, soil erosion and dust generation resulting from vegetation removal, community health and safety and gender contextual risks, economic displacement of 169 project affected persons (PAPs) in six villages and impacts on cultural heritage (e.g., pottery shards, baobab trees). During operations, key E&S risks and impacts include water consumption, hazardous waste management, site security, fair and safe working conditions for employees and contractors (including implementation of a worker grievance mechanism and compliance with applicable national labor, health and safety regulations), community health and safety, and management of community grievances.
JCM recently completed the construction of a 60 MW solar photovoltaic project in the Salima District of the Republic of Malawi. JCM is using the experience and ‘lessons learned’ from the Salima project in the development of the Golomoti Project, in particular, those related to contractor management, stakeholder engagement and development and implementation of grievance mechanisms.
While all PSs are applicable to this Project, current information indicates that the Project will have impacts which must be managed in a manner consistent with the following PSs:
- 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
- PS5: Land Acquisition and Involuntary Resettlement
- PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources
- PS8: Cultural Heritage
There is no indication or evidence of Indigenous Peoples residing in or having cultural ties to the Project area, thus PS7 Indigenous Peoples does not apply.
In addition to the PSs, the WBG General EHS Guidelines and sector-specific EHS guidelines for Electricity Transmission and Distribution apply to this Project.
The following documents were reviewed by MIGA:
- Hydrology and Flood Risk Assessment prepared by Power Engineers, February 2019
- Environmental and Social Impact Assessment (ESIA) for Proposed Golomoti Solar Project, Dedza (Final Report) prepared by ERM, February 2020
- Environmental and Social Due Diligence Final Report prepared by IBIS, December 2020
- Environmental and Social Policy prepared by JCM Power, November 2020
- ESIA for the Proposed Battery Energy Storage System for the Golomoti Solar PV Plant (Rev B), prepared by SLR, February 2021
- Clearance Letter: Project Impact on Golomoti Cultural Heritage Assessment prepared by Malawi Department of Museums and Monuments, February 2021
- Golomoti Cultural Heritage Impact Assessment: Technical Archaeological Report prepared by Malawi Department of Museums and Monuments, February 2021
- Key ESMS documents including the Construction Environmental and Social Management Manual, Construction Health and Safety Manual, and Labor Management Manual and supporting procedures prepared by JCM, February and March 2021
- Golomoti Health Safety Environment and Social Management (HSES) System prepared by JCM, March 2021
- Assessment of Potential Natural Habitats for Golomoti Solar PV prepared by Golder, March 2021
- Golomoti JCM Solar Project Archaeological Site Considerations Construction: Contractor Training and Awareness Programme Report prepared by Malawi Department of Museums and Monuments, April 2021
- Environmental and Social Due Diligence Final Report v1 prepared by IBIS, June 2021 (update of Dec 2020 Final Report)
- Socio-Economic Development Project Design Report for Golomoti Solar PV prepared by Community Insights Group (CIG), July 2021
- LRP Monitoring Report – 2021 Golomoti Project prepared by Community Insights Group (CIG), August 2021
- E&S Monitoring of JCM Golomoti 20 MW Solar PV Project (Malawi) prepared by IBIS, August 2021
- Climate Change Adaptation Project: Action Plan for JCM Power Projects prepared by IBIS, August 2021
- Golomoti Solar PV Influx Management Plan, prepared by JCM, August 2021.
In addition to the Project documents above, an Independent Environmental and Social Consultant (IESC) hired by JCM Power conducted E&S due diligence from October 12-29, 2020, which included reviews of E&S documentation, site visit by an in-country partner to the Pitala Group Village in Dedza district, and meetings with the PE Malawi Country Director, Community Liaison Officer, Gender Inclusion Specialist, Local Project Coordinator, representatives of local communities affected by the Project. In June 2021, the IESC updated its E&S due diligence report based on desk review and interviews and carried out virtual monitoring. MIGA conducted its initial due diligence virtually due to COVID-19 travel restrictions from October 19-23, 2020, and met with several project stakeholders including energy government agencies. Virtual updates to the initial due diligence were carried out between September and November 2021.
MIGA’s due diligence review considered the E&S management procedures and documentation being developed, and which will be implemented 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 MIGA’s PSs.
Key E&S issues associated with the Project’s business activities are summarized in the paragraphs that follow.
PS1: Assessment and Management of Environmental and Social Risks and Impacts
Environmental and Social Assessment and Management System
The Project is well advanced in the construction phase with site mobilization having occurred in February 2021 and construction started in March 2021. A project-level Environmental and Social Management System (ESMS) has been developed (using the Salima project ESMS as the basis) and is being implemented.
The ESMS for Golomoti, the Health, Safety, Environment and Social Management (HSES) System, includes health and safety, labor, and E&S aspects. The Golomoti ESMS reflects the site-specific conditions of the Golomoti Project including the Environmental and Social Management Plan (ESMP) from the ESIA. A Construction Environmental and Social Management Manual (ESMM), a Construction Health and Safety Manual and Labor Management Manual have been prepared and cover the requirements for controlling E&S risks related to the construction of the Project. These manuals are supported by approximately 50 policies, plans and procedures which cover key aspects of an ESMS (e.g., policy, risk assessment methodology, management programs, roles and responsibilities, emergency response, monitoring, stakeholder engagement, etc. The emergency preparedness and response plan (EPRP) will be reviewed to ensure all relevant components have been addressed (per discussion below) (ESAP #1a) The ESMS and supporting policies, plans and procedures will be revised for operations and maintenance (ESAP #1b).
The PE has developed the E&S Policy as part of the Project-level ESMS. JCM developed corporate policy statements demonstrating its commitment to E&S management which include the following policies: E&S, Health and Safety, Employment and Labor, Impact Policy) and Code of Conduct. These policies reflect the commitment of executive management to:
• Comply with E&S legislation, regulation, and standards/policies
• Prevent or minimize environmental impacts and pollution
• Prevent or minimize social impacts or conflicts; and
• Demonstrate continual improvement through performance monitoring and reporting.
Identification of Risks and Impacts
The land was selected for technical reasons, such as the proximity to the Golomoti substation, its flat gradient characteristics, and the absence of physical (residential) structures on the Project site. There were however subsistence agriculture plots on the site; thus, economic displacement occurred, and this is discussed under PS5.
After the alternative analysis was completed and the site was identified for the Project, JCM commissioned an ESIA for the Project which was finalized in February 2020. On February 25th, 2020 the Malawi Environmental Affairs Department (EAD) approved the ESIA on the basis that the ESMP (included in the ESIA) is implemented. In addition, the EAD specified that detailed conditions of the approval would be included in the ESIA certificate.
The ESIA outlined and assessed the key E&S impacts of the Project in line with local Malawian laws and the PSs.
Issuance of the ESIA certificate was originally delayed since April 2020 due to institutional reforms as result of changes in national government but has since been issued. In October 2020, the EAD issued a letter indicating support for the Project and authorizing the Project to proceed with all necessary processes for the implementation of the Project. This letter included additional conditions such as adopting and implementing an HIV and AIDS Workplace Policy, developing and implementing an acceptable OHSE Policy, compensating project affected parties in consultation with local chiefs and Dedza District Commissioner (DC) prior to Project implementation, ensuring formal agreements are made with the DC and local leaders in the surrounding communities on proposed corporate social responsibilities by the company, providing bi-annual progress reports to the EAD on the implementation of the Project’s ESMP, etc.
The addition of battery storage will help stabilize provision of power supply to the grid. The battery storage is a containerized solution where batteries are stored in a container. The battery storage is being installed within the existing Project footprint and no new land was required. The amendment process for the battery storage was completed and an amendment to the ESIA was approved by EAD.
The PE has finalized all E&S regulatory requirements and obtained the environmental license. To facilitate the integration of the ESIA and EAD letter requirements, the PE developed a ‘commitments register’. This register also captures lender and MIGA E&S-related commitments. The PE has also developed a legal register which specifies the permits/licenses required to be obtained for the Project. A similar register will be maintained during operations (ESAP #2).
JCM conducted a Climate Change Adaptation Project which aimed at assessing the risk of physical climate change on JCM’s renewable energy projects. The study included a landscape review of relevant information including internal documentation, external data sets, publicly available climate projection tools and literature. The approach included assessing the existing climate as well as the future projected climate at regional, country and project-specific levels. Key projection results for Golomoti indicated that average temperatures are expected to increase by up to 2°C by 2040. During September to December, the frequency of hot days (Tmax> 35°C) will increase notably (up to 40 days in the worst case), most prominently during the early summer months. This will also exacerbate the potential severity and frequency of wildfire events. The projections indicate that between 2020 to 2039, there will be a slight increase in annual average rainfall. In mid-summer, however, a large increase in total rainfall is expected, with an increase in the rainfall intensity and extreme rainfall events (noting that an increased frequency of cyclones over the South Indian Ocean may be a driver). Extreme heat experienced in the summer months, followed by more intense rainfall events, may result in an increase in flood events.
The expected increase in temperatures creates the possibility of reduced energy output, as solar equipment and module efficiency decreases as temperature rises. Heat stress also poses a health threat to employees and contractors working on site due to increasing temperatures. Anticipated increases in rainfall in the mid-summer combined with the likelihood of more frequent heavy rainfall events and cyclones could increase flooding resulting in infrastructure damage and reduced ability to access the sites for maintenance.
A high-level climate change adaptation plan was defined through risk workshops with JCM management based on the key risks identified. As such, a set of recommended adaption actions was developed and categorized into engineering, operational, financial, community and science. A set of recommendations and actions was developed and includes early-stage screening i.e., high level geographical and sector climate risk assessment; a pre-acquisition assessment i.e., desktop reviews using publicly available tools and sets of questions to determine asset-level vulnerability and post-acquisition assessment i.e., the management of site-specific physical climate risks and development of actions. These recommendations and actions will be incorporated into operations and maintenance plans, procedures, and activities where relevant (ESAP #1b).
The ESMS defines management programs related to risks and impacts identified in the ESIA. The PE has stated that relevant management plans are integrated in applicable contracts and sub-contracts, and fully implemented during the construction phase. For the operations phase, the PE will also ensure full implementation of the ESMS. The ESMS includes the procedures for E&S performance measurement and monitoring.
The E&S Management Manual (ESMM) includes an organizational structure for E&S management and statements of responsibility and authority and outlines environmental requirements for specific activities which may pose risks on the environment and people. The ESMM and supporting management plans and procedures also contains mitigation measures for air quality, noise, soil, groundwater, biodiversity, landscape and visual, land acquisition, sexually transmitted infections/human immunodeficiency virus (STI/HIV) and vector borne diseases, labor and working conditions, community health and safety, cultural heritage, and unplanned events (e.g., spills, accidents etc.). The ESMM and the associated documents are covered in the existing HSESL MS and those to be revised and/or finalized for the construction and operations phases are listed in the ESAP (#1a and 1b).
Organizational Capacity and Competency
JCM provided services and support to the PE, who coordinated and implemented the construction phase workstreams directly. The PE is responsible for overall E&S performance, including during the O&M phase of the Projec, and has a permanent in-country office that manages the Golomoti Project in addition to the existing Salima Project. Permanent E&S-related staff include an in-country Community Liaison Officer (CLO) responsible for stakeholder engagement. An Assistant CLO has also been recruited. In addition, the Gender Inclusion Specialist (GIS) hired on the Salima Project is responsible for gender related actions on the Golomoti Project. E&S organizational capacity in-country office is managed by the corporate Environmental and Social Governance (ESG) team based in South Africa.
Key E&S staff (Project Manager, Health, Safety, Environmental and Social (HSES) Manager, and HR Officer) from the Salima project were transferred to the Golomoti Project once Salima construction was completed. Additional E&S related staff have been hired (e.g., H&S Manager) and are onsite during construction.
The CLO and Gender Inclusion Specialist are well versed in stakeholder engagement and gender dynamics in Malawi and were transferred to Golomoti. The Senior CLO, Gender Inclusion Specialist, and HR Officer will work together to help mitigate risks which may arise during construction (e.g., recruitment, labor influx, and community health and safety issues, etc.).
Emergency Preparedness and Response
An emergency preparedness and response plan (EPRP) for the Project is developed and is part of the ESMS. The plan covers: administration; organization of emergency assembly points; roles and responsibilities; communication system; response procedures; resources; training including drills; checklists; and business continuity and contingency. The EPRP will be reviewed to determine if additional measures are required for wildfire response (ESAP #1a).
Safety measures for the BESS include a containerized approach with separation between containers, using a multi-level management system to prevent adverse situations such as overcharge, over-discharge, over-current, over-voltage, and under-voltage and an intelligent heating, ventilation and air conditioning, and an automatic fire suppression system (FSS). Specific emergency response measures for the BESS system are included in the EPRP and will be reviewed to determine if additional measures are required for response to a BESS related emergency (ESAP #1a).
The PE has confirmed that the procedures and responsibilities for emergency response actions and communication are clearly defined and available on site. Emergency response flowcharts with contact numbers will be posted on site. Firefighting equipment and fire alarms will be regularly tested. The PE have migrated ambulance and medical personnel to the Golomoti project site as the infirmary is fully functional at Salima and a medical emergency response plan was developed. The PE has put in place clear communication lines with the neighboring villages and ESCOM in case of emergencies.
The PE has put in place a COVID-19 risk management plan for the Project: the COVID-19 Infection Prevention and Control Measures Procedure. The plan includes roles and responsibilities, site access procedure, prevention measures, behavior guidelines, and cleaning and disinfection protocols. The site-specific plan was developed for the Project prior to construction.
Monitoring and Review
JCM’s corporate ESMS commits to measuring and tracking E&S performance and this includes contractors working on behalf of the PE. The corporate ESMS states that an independent audit of the implementation of the Project level ESMS should be undertaken at least once during construction and at least every two years during operations. Periodic independent monitoring is undertaken with the first independent monitoring event having been completed in June 2021. After each monitoring event corrective actions are identified which the PE then works towards closing out as part of their continual improvement process. These actions are reflected in and tracked in the Project commitments register.
The ESIA also includes provision for monitoring the implementation of the ESMP. Each mitigation measure or set of mitigation measures has a monitoring indicator and monitoring frequency.
Developing and implementing an ESMS and a monitoring plan are required under national law. Moreover, the Golomoti Project ESMS includes a provision for monitoring and evaluation. An assessment of the implementation of the LRP has commenced and is ongoing (see further details under the PS5 section below). The Project will be required to submit E&S monitoring reports to MIGA on an agreed frequency.
A Stakeholder Engagement Plan (SEP) for the Project was developed in February 2019 and updated in 2020 and 2021. The SEP includes stakeholder identification, stakeholder mapping, communication methods, and a stakeholder engagement strategy. The strategy outlines activities for both construction and operations phases of the Project. The Project has developed a mechanism and provided training for regular communication channels with affected communities per the stakeholder engagement plan. The PE carried out stakeholder engagement activities prior to commencement of construction to inform affected stakeholders of upcoming Project activities and schedule, along with updates on ongoing workstreams and coordination between these plans (LRP Monitoring, SED Planning, etc.). In addition, JCM’s Gender Inclusion Specialist will also be responsible for gender inclusion management for the Golomoti Project. Furthermore, ESIA disclosure was undertaken in September 2020. The Project disclosed a non-technical summary of the ESIA in English and Chichewa as part of the ongoing communications with various stakeholders.
In the preconstruction phase, engagement was focused on the ESIA, land acquisition and compensation process, livelihood restoration, and the establishment and implementation of a grievance mechanism for PAPs. Stakeholder engagement was conducted during the ESIA process and included scoping level engagement and baseline data collection. Records of these engagements are included in the ESIA Report. The Project engaged with a cross section of stakeholders including national and local government, affected communities, and NGOs. The ESIA Report includes the disclosure process for the LRP, which involved the submission of the Draft ESIA Report to the EAD for review, engagement on livelihood restoration, and provision of updates to affected communities on the Project.
The land acquisition and compensation process has been completed and is discussed further in the PS5 section below. Stakeholder engagement on the land acquisition process is detailed in the LRP and includes notification of a cutoff date, financial literacy training (which was conducted on two occasions and as part of the existing LRP activities), and disclosure of compensation payments. A village grievance mechanism (VGRM) has been established for the Project since March 2019.
External Communications and Grievance Mechanism
The PE has disclosed and implemented a grievance redress mechanism for community grievances, as noted above a VGRM was established. The VGRM is operationalized through a committee which was formed from representatives from each of the affected communities. A grievance log was made available for review during due diligence. Initial grievances recorded were around the land compensation process (e.g., compensation delays, amount of compensation agreed upon and understanding of the process for calculating this etc.) and these were recorded and closed out between April and September 2019. To date, land acquisition related grievances have been resolved, including the grievances related to the wayleave transmission line boundary. A land surveying exercise was undertaken to verify the initial surveying exercise to determine if the correct compensation was paid. The exercise was led by two surveyors from the survey department and assisted by two members of the Dedza District Lands Office. The remeasuring exercise of the wayleave boundary confirmed that the correct compensation was paid to landowners. Other resolved grievances were related to salary, construction damage to crops, increased noise and dust, and loss of access to cultivation areas.
The LRP was finalized in September 2020 and implementation is currently ongoing. LRP monitoring was conducted in August 2021, and the LRP will be updated to reflect findings and close gaps. The VLRP committee has been set up to oversee the implementation of the LRP and will serve as an additional communication channel for the Project.
In relation to gender-based violence, to the extent possible, the PE has included measures to coordinate with local police forces and relevant non-governmental organizations to ensure that gender-based violence survivors are treated with respect and dignity and receive the support they require.
Ongoing Reporting to Affected Communities
The PE has enhanced stakeholder engagement to ensure that PAPs are kept up to date on livelihood restoration activities, cultural heritage, COVID-19 risk management plans, land acquisition and compensation processes, and the Project schedule.
PS2: Labor and Working Conditions
During peak construction there were approximately 400 workers, including contractors (both general and skilled) on the Project site across the 10-month construction phase. Approximately 10 people will be employed during operations.
The PE has specified in accordance with Malawi national labor laws (Malawian Employment Act (2000) that the minimum working age is 18 years old for the Project in the HR policy and has defined and implemented a process for age verification checks to be undertaken as part of the recruitment process. The PE has also updated the worker contract template to include annual leave entitlement.
During operations, the solar PV power plant will be operated on a 24 hour, 7 days a week basis with an estimated 12 on-site workers. Workers will be employed by the PE in its role as the EPC and O&M contractor. Key operational activities will include cleaning of the modules; vegetation management for under and around the modules; maintenance of all Project components; and site security monitoring.
Human Resources Policies and Procedures
The PE adheres to the Malawian Employment Act (2000) and Labor Relations Act (1996). JCM has a corporate Human Resources (HR) Policy in place which has been updated to reflect the requirements of the Malawian legislation and PS2 requirements for the Golomoti Project.
The PE has developed and is implementing a Labor Policy and procedures for the construction and operations phases that cover all type of workers, including direct workers and contractor /sub-contractor workers and is consistent with PS2. The HR Policy includes the following provisions: working relationship; working conditions (including housing conditions for migrant construction workers); terms of employment; workers’ organizations; non-discrimination and equal opportunity; grievance mechanism; prohibition of child and forced labor in its direct operations; and occupational health and safety. The Project has developed and implemented a system to track worker hours and overtime.
The Labor Policy also covers the recruitment, dismissal, performance appraisal, equal opportunity and non-discrimination, rights to collective bargaining, commitment to health and safety at work and compensation systems. Individual job contracts for PE staff incorporate the requirements of national HR regulations as well as the requirements of PS2. Contractors and sub-contractors are required to adhere to JCM’s HR policy and procedures, and these requirements. The PE has developed a Code of Conduct (CoC) which is applied to all employees, contractors, and subcontractors. The CoC is presented during induction training and all employees are required to acknowledge their understanding of the CoC. An abridged version of the CoC is placed on Project notice boards.
The PE has recruited local labor to the extent possible. Host communities are provided with recruitment opportunities first before hiring from non-host communities. The HR policy and procedures include a recruitment procedure that reflects the structures developed for this Project. This recruitment procedure and Influx Management Plan include measures to manage influx into the Project area (see further details in the PS4 section below)
The PE has developed a training plan. Induction training on the Labor Policy and Procedures and basic safety awareness training is provided to all newly hired workers. Other types of technical skills training are identified for staff on an as-needed basis.
Workers’ accommodations have been built onsite to house approximately 70 skilled workers during construction. The Project is monitoring these accommodations to ensure they are compliant with MIGA’s PS2 requirements as well as the International Finance Corporation’s (IFC) and the European Bank for Reconstruction and Development (EBRD) guidance note on Workers' Accommodation: Processes and Standards. Unskilled workers and security personnel live in nearby villages and leave for home at the end of their shifts. During operations, there will be no worker accommodation on-site.
The Project’s monitoring plan includes internal and external labor audits (including contractors labor management system) and a detailed schedule is being developed as per ESAP #4.
The PE has developed and is implementing a Gender-Based Violence and Harassment (GBVH) policy which contains the establishment of mechanisms to mitigate GBVH risks in the workplace. The policy includes rules and prohibits conduct such as engagement in sexual relationships with a minor, engaging in sexually suggestive physical contact, etc. The policy also includes disciplinary measures such as potential dismissal, based on the outcome of the prescribed disciplinary process, for Project employees that perpetrate GBVH. The GBVH Policy includes: (i) procedures for handling claims or reports of GBVH and referral pathways for survivors of GBVH; and (ii) a GBVH grievance committee protocol and GBVH training. A targeted gender assessment was conducted by the PE’s GIS between November and December 2020. The gender assessment provided the identification of a gender and GBVH baseline. The findings of the assessment have been updated to inform a detailed Gender Action Plan which is being implemented by the Project.
The PE follows the requirements of the Malawi Employment Act (2000) and Labor Relations Act (1996) which protects employees’ rights to freedom of association and collective bargaining in line with the requirements of PS2. The Malawi Congress of Trade Unions (MCTU) is the national trade union in Malawi. It is a federation of 20 trade unions, with a membership of approximately 300,000 workers. MCTU works to promote human rights standards and the social welfare of employees in the workplace, however the focus is largely on the tobacco, tea, and sugar industries as the biggest exports of Malawi. The PE has no restrictions on freedom of association; however, no unions are currently active at the Golomoti Project site.
Non-Discrimination and Equal Opportunity
The PE has committed to the principles of employment equity, equal opportunities, and empowerment, regardless of gender, race, color or creed or medical status. The PE includes in their HR Policies and Procedures a formal policy on non-discrimination and equal opportunity. The policy covers all aspects of the Project, and such requirement will contractually pass down to all third parties, including contractors and subcontractors.
Worker Grievance Mechanism
The Worker Grievance Redress Mechanism (WGRM) provides employees of the PE and/ or its contractors with a clear process through which to raise issues, concerns or complaints. Each grievance form has a unique reference number on it which enables the employee to log a grievance, remain anonymous and yet still track whether their grievance has been addressed. The mechanism also provides for the establishment of workers’ grievance and GBVH committees and defines the roles and responsibilities of all parties involved. The WGRM has incorporated lessons learned and external independent assessments on the Salima Project.
Occupational Health and Safety (OHS)
The main OHS risks and impacts include heat exposure, traffic safety, exposure to welding light and fumes, work at height, electrocution, and potential for fires and/or explosions resulting from ignition of flammable materials or gases. The PE has developed an OHS Management System which contains procedures for site-specific HSE risk assessment including the hazard and risk identification process, emergency response, first aid, working at heights, hazardous materials, thermal stress, and food safety etc. The PE has indicated that the HSE documentation is available on site and that the site staff are trained on the full range of HSE procedures. A full-time on-site H&S Officer has been appointed for the duration of the Project (as described above in the organizational capacity section in PS1). The HSE officer is responsible for coordinating health and safety audits, identifying potential hazards and risks, participating in accidents/ incidents investigations, making recommendations regarding health and safety, conducting safety inductions, organizing health and safety meetings, ensuring regular HSE reporting and managing HSE documentation. Contractors are also required to provide onsite HSE officers to oversee their respective work programs.
As part of the ESMP, an Event and Non-Conformance Procedure has been developed for reporting incidents, accidents and near misses. Major accidents and incidents are reported to the Department of Labor and the Department of Environmental Affairs. A procedure for accident/incident investigation is included. Investigation results are used for learning and training purposes. Near-miss reporting figures are also a part of the key health and safety performance indicators (KPIs) which are regularly monitored and reviewed by PE Management on a monthly basis. Internal reporting includes quarterly reporting to JCM Power Corporation Management HQ.
Throughout the construction phase, the PE monitors OHS performance using a number of Health, Safety, Environmental, Social and Labor (HSESL) metrics. To date, the PE has not recorded serious medical treatment injuries or fatalities on site and continues to maintain a safe environment by conducting site inductions, risk assessments, job safety analyses, and toolbox talks for work conducted on-site. The PE also provides task specific training relevant to the construction activities on-site to maintain a safe work environment.
Visitors and employees are provided with HSE induction, and the PE maintains an induction log. Site employees and visitors are provided with appropriate PPE.
Workers Engaged by Third Parties
Contractors and third parties involved during operations include security personnel, sanitation services workers and sewage removers who come once a month. In addition, there is a waste management and collection company, and a vegetation control service that is scheduled once per annum. As part of the ESMS, the PE developed a contractor management plan, which includes procedures and a template for standard contractual obligations to ensure that contractors’ labor and working conditions comply with the requirements of PS2 and Malawian laws. The PE has included HSE provisions in the EPC and O&M contracts and contracts of other sub-contractors providing services to the company’s operations. These provisions include as a minimum: compliance with labor legislation, terms of OHS management, fair working conditions and access to a workers’ grievance mechanism including review and response to anonymous complaints. The PE will monitor third-party compliance with approved HSE requirements.
The PE has developed a Labor, Environmental, Social, Health and Safety (LESHS) contractor screening tool for use during the procurement of new contractor(s). The tool includes the provision of a questionnaire to potential contractors that focuses on project resourcing, with specific reference to EHS and HR, request for evidence of a documented ESMS, training on E&S and H&S, incident management and record keeping, monitoring and evaluation in the form of internal and external audits, labor and working conditions and business ethics.
JCM Power has developed requirements and engaged in dialogue with suppliers and sub-contractors in relation to managing E&S risks within their supply chain. The PE currently has a system which assesses contractors on the following: health and safety, environmental and social and labor practices. Going forward, JCM Power is incorporating assessment of primary suppliers in line with the Performance Standards (ESAP #5).
PS3: Resource Efficiency and Pollution Prevention
During construction and operations, the main issues relate to air emissions, water consumption, pollution prevention, solid waste management, and hazardous material management. Mitigation measures have been included in the Project ESMP and will be implemented, in accordance with MIGA’s PSs.
As this is a solar project, the Greenhouse Gas (GHG) emissions associated with the operations phase of the project are expected to be minimal and therefore reporting GHG emissions to MIGA is not required under MIGA’s PS3. Based on JCM’s Power latest Sustainability Report (2019) the company’s power plants globally resulted in avoiding more than 75,864 metric tons of carbon dioxide emissions in 2019. The generation of greenhouse gases associated with the Project will be minor and will be limited to fuel combustion and transportation of equipment to the site during construction. During operations, the Project will be supplied with solar-generated electricity and electricity purchased from ESCOM when the Project is not generating electricity.
Due to the rural nature of the Project area, there are no existing continuous air emissions near the Project site. Occasional air emissions may result from minimal burning or clearing activities occurring in and around the Project area. There are residential communities in the immediate vicinity of the Project site. The main sources of air emissions during the construction phase relate to dust caused by earthmoving equipment and the removal of vegetation, and combustion emissions from vehicles and earth moving equipment.
Air emissions during construction vary in magnitude, frequency and duration based on the various construction activities required. These impacts are temporary and management measures for limiting air emissions have been included in the ESMP. The PE has developed a management and monitoring program which includes measures on the use of proper equipment, vehicle and roads maintenance and safety, timely dust suppression measures, and speed restrictions among others. The PE continues to monitor dustfall and monthly dust samples are collected and analyzed. The dustfall rates are measured against the South African standards for the non-residential limit and will be assessed against the World Bank Group General EHS Guidelines (ESAP #6). The PE has dust suppression mitigation measures in place including the dampening of roads and the restriction of earthmoving activities during extremely windy periods.
During operations, air emissions will be limited to vehicles.
Water consumption and supply
The Project is using various sources of water: a borehole provides water for domestic and irrigation use, surface water from a nearby river was used during construction and is used for dust suppression, and bottled treated water is used for potable water at the site. Water volume usage is tracked on a monthly basis.
Permission has been granted to abstract groundwater from one borehole on site for domestic purposes. The borehole was drilled in accordance with applicable evaluation and permitting processes. In addition, pump tests were undertaken and tests were conducted to identify whether the abstracted quantity of water required will have any potential impacts on other groundwater users/community wells in the nearby villages. No impacts were identified, and the PE has a water management procedure in place. Bottled drinking water is brought onto site for all workers
In line with the Project’s permit, water is also sourced from the nearby Livulezi River which is currently in a high flow cycle. This water is used for construction activities and dust suppression.
During operations, water usage will include domestic use and panel cleaning. All water for the operations and maintenance phase of the Project is expected to be obtained from the borehole within the facility.
Mitigation measures have been provided in the ESMP with regards to the abstraction of groundwater including the installation of water storage tanks to store groundwater and/ or water brought in by bowsers for use during the dry season and regular monitoring of affected village water supplies.
Electricity during the construction phase is provided using diesel-powered generators. Five 24 kW generators are providing electricity to the office trailers during construction with an estimated total fuel consumption of 58,050 Liters (L). Ten 8 kW generators will be required for the operations of equipment during construction with an estimated total fuel consumption of 21,930 L. The Project is storing diesel in an above ground storage tank (AST).
During operations, the facility will be supplied with solar generated electricity and electricity purchased from ESCOM when the plant is not generating electricity. Backup generators will be installed on-site as backup for potential grid failures.
The ESMP includes individual plans to address pollution prevention in line with PS3. Key findings are summarized below.
Solid Waste Management: Waste generated during the construction phase includes general domestic waste, including sanitary and food waste, office waste, and organic material. Petrol and diesel by-products are generated from the transportation of goods and personnel, generators, and heavy construction equipment. Large quantities of non-hazardous waste are generated from the solar PV panel packaging material, which typically arrive in wood pallets. Waste is separated at source and labelled bins are located within the Project site for the storage of the various categories and either disposed to a local registered waste dump or recycled, where possible, by licensed contractor.
During operations, waste is estimated to be minor and limited to general office and administrative products, minor maintenance wastes (empty paint tins, oil containers etc.), and redundant or damaged plant equipment. It is understood that an authorized contractor will remove waste to either recycle or dispose.
The PE has identified that there are no licensed waste disposal areas in Dedza District. Permission has therefore been granted by Salima District to dispose the waste at the Salima waste disposal facility and a waste disposal permit has been received from the Salima District Council.
The PE is leveraging its experience on the Salima Project by using the existing management system documentation including the Waste and Wastewater Management Procedure, which includes measures for the identification and classification of waste, waste separation and storage, collection and transportation, waste disposal facilities and reuse and recycling programs.
A detailed decommissioning and rehabilitation site closure plan will be developed in line with the PSs and General EHS Guidelines prior to decommissioning the solar PV plant and associated infrastructure in consultation with the various stakeholder groups (ESAP #3). This plan will include, but will not be limited to, management of socio-economic aspects such as employment loss, removal, re-use and recycling of materials and vegetative rehabilitation to prevent erosion.
Wastewater: As indicated above, a Waste and Wastewater Management Procedure has been developed. Wastewater is estimated to be minimal both during the construction and operation of the Project. Wastewater from construction activities includes temporary sanitary facilities, stormwater, and drainage over potentially contaminated areas (e.g., concrete batching/mixing areas and equipment storing areas). The ESIA’s ESMP indicates that any hazardous wastewater will be stored on site, prior to disposal. Wastewater from operations will comprise of on-site sanitary facilities and run off from panel cleaning activities. There will be minimal sewage from sanitary facilities during operations. These facilities will operate on a septic tank system, and it was reported that the PE will arrange for safe disposal of waste from the septic tank.
Hazardous Materials Management: There will be a small amount of hazardous materials located on site, including fuel (diesel by-products and petrol), heavy construction equipment oil, herbicides for weed control, specialized gases (for use in switchgear), cleaning and maintenance chemicals such as soaps, solvents, paints, etc., and lubricants. The PE received the permit from the Malawi Energy Regulator Authority (MERA) for a Storage License in accordance with the Liquid Fuels and Gas (Production and Supply) Regulations (2008). Mitigation measures have been provided in the ESMP including the refueling of equipment and vehicles in a designated area with hard standing flooring, to prevent seepage of any spills into the ground, and the development of a Hazardous Spill Response Plan.
All wastes will be segregated and labeled. The Project has developed a Hazardous Materials Procedure and spills are covered under the EPRP. All spills will be immediately contained and cleaned up contaminated areas will be remediated. Used oil will be recycled, if possible, or safely stored and removed from the site and correctly disposed. These materials are stored in a secured cabinet, locked to prevent unauthorized access and appropriate signage deployed. Material safety datasheets are available for all materials present on site. During operations, the quantities of hazardous materials will be minimal, and the materials are expected to be managed in a suitable manner to avoid community exposure to these materials.
PS4: Community Health, Safety and Security
The Project site is located within the Kachindamoto TA. It is approximately 0.5 km east of the Golomoti Substation and about 1 km southeast of the Golomoti Trading Centre in the Dedza District. Existing 132 kV and 33 kV transmission lines run past the project affected community on the northern and western boundaries. The Project site is situated on, and surrounded by, land used for subsistence farming. The closest residents are those to the northwest of the Project, namely Nsamala, Chinianipa, and Chisaka; the latter two border the main fence of the project but are approximately 130-200m away for the infrastructure of the plant. The village of Thondoya sits to the South East of the Project and is approximately 130m away from the infrastructure of the plant.
Community Health and Safety
Community health and safety is currently managed by JCM’s CLO and Gender Inclusion Specialist. During the construction phase, potential risks have been identified such as nuisance from noise and dust, traffic accidents, accidents and injury on active construction sites due to presence of equipment and machinery, and risks of increased GBVH and STIs due to worker community interactions or potential influx of economic migrants (workers). The PE have developed a Project Disease Management Plan which addresses the risks related to STIs as further detailed below. Through JCM’s CSR program and in alignment with the Traditional Authority (TA) in Golomoti, JCM will support the empowerment of girls through education, to help combat GBVH incidences. JCM’s Influx Management Plans address the risks associated with the potential influx of migrant workers. To date, JCM reported that influx has not occurred. During operations, the potential risks are anticipated to be minimal.
For Golomoti, JCM has adapted several policies and procedures that were developed for the Salima Project to cover the management of project-level community health and safety risks to an adequate level for this Project during the construction. The policies and procedures will be updated for the operations phase and decommissioning phase (ESAP #1 and #3).
JCM’s existing HSES MS covers key aspects such as: protection of community water sources; ensuring communities are protected against potential health and safety hazards arising from project equipment and project activities; and ensuring project-related vehicle traffic does not pose unnecessary risk to communities. In accordance with the SEP, JCM has partnered with the District Gender Technical Working Group (DGTWG) in the implementation of all community-related activities in the GBVH Action Plan. The DGTWG will be crucial in building GBVH capacity and knowledge in the local community.
JCM has developed a Traffic Management Procedure in line with the requirements of MIGA’s PSs. The PE has developed and implemented safe driver and transport safety vehicle procedures. Unskilled labor come from the surrounding villages and employees use their own sources of transportation, mainly bicycles, or walking to the Project site.
The Project has developed a Project Disease Management Plan (including STI and HIV management), which commits the PE to providing awareness and education amongst the community with regards to occupational diseases and to help to facilitate the logistical arrangements for the services provided by the local health clinic. JCM has a dedicated nurse on the Project site who undertakes entrance and exit medicals of workers and provides basic medical care for workers. The Project maintains a working relationship with the Golomoti Health Centre and the Dedza Hospital for more serious cases.
The installation of the 132 kV transmission line in proximity to the local community would ordinarily necessitate community safety awareness training. However, the Project and Project affected community are located in close proximity to the Golomoti substation with existing 132 kV and 33 kV transmission lines running past the project affected community. The community are therefore familiar with transmission line wayleaves and associated safety and security behavior.
Site security is contracted to a professional private security firm who has provided trained security personnel. All security personnel have been screened to ensure personnel do not have criminal records or have previously abused or violated human rights. JCM does not sanction any use of force except when used for preventive and defensive purposes in proportion to the nature and extent of the threat. The PE will update their Security Management Plan (SMP) to require that the security contractor operates in a manner which meets the requirements of MIGA’s PS4 and local regulations (ESAP #7).
The PE has updated their grievance mechanism for nearby communities to express concerns about the security arrangements and acts by security personnel if required. The site is fenced and public access to the solar plant is restricted to authorized personnel.
PS 5: Land Acquisition and Involuntary Resettlement
The Project site is located in the Central Region of Malawi, approximately 47 km from the Dedza District Centre and within Kachindamoto Traditional Authority (TA) and the Pitala Group Village. Six villages under the Group Village Head (GVH) Pitala were directly affected by the Project through economic displacement –Kalumo, Chisaka, Kapesi, Chitseko, Msamala, and Ching'anipa. Physical displacement did not occur.
The Project site is generally flat and was predominantly used for subsistence agriculture. Trees on the Project site included natural and planted trees, such as mango, acacia, and baobab trees. There were also several footpaths that traversed the Project site.
The land acquisition process for the Project site commenced in 2019 and was completed in 2021. It consisted of three phases: Phase 1 for the PV area, Phase 2 for the wayleave and Phase 3 for an extension of the wayleave. It was a government-led process, led by the Dedza District Commissioner Office and the Ministry of Lands (MoL). A total of 111.75 hectares (ha) of land was leased for the Project site, all of which was individually claimed customary land. The land comprised of 172 plots belonging to 169 Project Affected Peoples (PAPs). This includes Phase 1 for the PV area (December 2019, 108 ha, 147 plots & 144 PAPs), Phase 2 for the wayleave (December 2020, 3.23 ha, 15 plots and 15 PAPs), and Phase 3 for an additional wayleave area (August 2021, 0.52 ha, 10 plots and 10 PAPs).
Compensation and Benefits for Displaced Persons
Prior to the formation and acquisition of land leases, the land ownership of the Project site was customary. This land was held in trust and fell under the jurisdiction of the Traditional Authority.
In line with local requirements and MIGA PS5, a Livelihood Restoration Plan (LRP) was developed as part of the ESIA. The LRP set out the extent and scale of economic displacement, engagement activities, eligibility and entitlements of PAPs, and implementation, monitoring and evaluation requirements. Although replacement land was offered to all PAPs, only one PAP accepted replacement land. All other PAPs opted for cash compensation. All PAPs were also offered financial literacy training prior to compensation.
The PE contracted an international livelihoods specialist consultancy to scope and undertake livelihood restoration monitoring to assess the LRP. The scope of work included an initial status assessment of PAPs to understand any potential vulnerability resulting from the economic displacement and to develop, where applicable, priority measures for support which can be implemented immediately (ESAP #8). As a result of the first monitoring event, recommendations were made to strengthen the LRP and its implementation. The PE is committed to revise the LRP, including a monitoring framework, based on these recommendations. (ESAP #8).
Before land acquisition planning commenced in 2019, stakeholder engagement, especially at the community level, intensified with frequent contact between JCM’s in-country team, National and district level stakeholders, the Project Committee, the Grievance Redress Committee, and with community members at large. Initial disclosure for the first phase of the process was undertaken September 2019. Alongside the individual disclosures, the MoL ran an objections desk, where. concerns were raised by PAPs which were then addressed, and verification of land parcels was completed. Engagement with the communities remains ongoing.
The Grievance Mechanism has been established by the PE in the communities and is deployed via the Village Grievance Redress Mechanism (VGRM) committee structure. As per the above, examples of grievances that were logged and resolved were based on the land measurement process. Other compensation process-related grievances received by the IESC during due diligence were also logged and resolved.
Resettlement and Livelihood Restoration Planning and Implementation
Once the LRP has been strengthened to address the gaps identified, the PE will engage delivery partners for various LRP interventions. The PE will commence implementation of LRP interventions as a priority, along with the monitoring workstream, to identify any vulnerability which may have resulted from the delay to commencement of LRP or the inability to plant crops on displaced fields during the transition period (ESAP #9). Where vulnerable households or PAPs are identified, in consultation with LRP monitoring specialists, the PE is targeting these households with employment opportunities during construction (ESAP #9).
The PE will collaborate with the Dedza District Commissioner Office to ensure that the land acquisition process and outcomes were consistent with MIGA PS5 requirements for government-managed resettlement. If necessary, the PE will prepare supplemental measures to complement government actions (ESAP #10).
The PE will carry out an interim implementation audit approximately 12 months after commencing LRP measures. After completion of LRP measures, the PE will commission an external completion audit of the LRP to assess whether the provisions have been met and if not, implement supplemental measures. The completion audit will include, at a minimum, a review of the totality of mitigation measures implemented by the PE, a comparison of implementation outcomes against agreed objectives, and a conclusion as to whether the monitoring process can end (ESAP #11).
PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources
Protection and Conservation of Biodiversity
The Project site is heavily modified (92.7% crop land) and as such, a single wet season field survey was undertaken from March 29 to 31, 2019.as part of the ESIA.
The 111.75 ha Project site is generally flat and predominantly (92%) heavily modified habitat used for subsistence agriculture including maize, sorghum, groundnuts, cotton, maroon cucumber, watermelon, mango, sweet potato, cucumber, cowpea, pigeon peas and common pumpkin. This habitat type also supports some scattered indigenous and planted trees, and shrubs including mango, and acacia. The Malawian Ministry of Land (MoL) conducted a detailed land and asset survey (18 July 2019) which identified five protected tree species within the Project boundary. Of these species, three Baobabs (Adansonia digitata) were deemed as irreplaceable and sensitive due to their age, cultural value and keystone role within the ecosystem. The baobab trees are also protected under the Malawian Forestry Act Amendment Bill of 2019. The PE redesigned the original Project design to avoid and protect three baobab trees (refer to PS8 Cultural Heritage below).
Apart from the baobab trees and in accordance with JCM’s Tree Replacement Plan in their ESMS, the PE will ensure that for each individual protected tree cut down during the land clearing, five or more individual trees of the same species will be planted in areas adjacent to the Project. Other than the nationally protected trees, no threatened, endangered or endemic species were noted. In addition, none of the amphibians, reptiles, avifauna or mammals identified during the survey were noted to be endemic or of conservation concern. Based on these observations, no Critical Habitats were identified, and a Critical Habitat Assessment was not deemed necessary.
The ESIA identified a 3.8 ha seasonal wetland in the southern portion of the Project site, dominated by white buffalo grass (Urochloa mossambicensis) and used for livestock grazing. A rapid Wetland Assessment was conducted by a Freshwater Ecologist in November 2020. The findings of the assessment indicate the presence of seasonal wetland systems on site. However, the systems are not considered to be ecologically significant. In addition, the most important service provided would be food harvesting which is addressed by the LRP (refer to Resettlement and Livelihood Restoration Planning under PS5). As such, no further mitigation is required. In addition, the habitat assessment undertaken in March 2021 concluded that the Project is considered Modified Habitat.
Although the ESIA did not expressly confirm the existence of Natural Habitats on site, it was noted that the Project site could support degraded Natural Habitat. Therefore, a habitat assessment was undertaken in March 2021 by a suitable biodiversity specialist including a site visit to the Project area. The assessment concluded that the Project area is classified as Modified Habitat, although the extent of modification varies across the Project site. There are also no threatened or restricted-range species present in the Project area and it is not classified as an area of high biodiversity value. As noted in PS3, there is one abstraction borehole on site and permission has been granted to abstract groundwater for domestic purposes. The borehole was drilled in accordance with applicable evaluation and permitting processes. Pump tests and quality tests were conducted prior to the use of the groundwater and the PE conducts monthly water quality tests.
Water is also sourced from the nearby Livulezi River where permission has been granted by the Water Abstraction Authority. This water is used for construction activities and dust suppression. The PE is undertaking a water resource impact study to determine the potential impacts on the surface water body and assess potential impacts to freshwater ecology resulting from water abstraction for the project (ESAP #12). The findings of the study will be reviewed, and if needed, corrective actions will be developed (ESAP #12). If necessary, and in light of the findings of the water resource impact study, the PE will review the Water Management Plan to enable sustainable use of natural resources and prevent impacts on water users. If necessary, this will include corrective actions based on the water resource impact study (ESAP #13).
Legally Protected and Internationally Recognized Areas
The Project site does not intersect with any protected areas or internationally recognized sites of conservation concern. The northeast boundary of the Bangwe Forest Reserve is located approximately 400m southwest of the Project Site. Forest reserves are managed by Forestry Department and they protect important water catchment areas.
Alien Invasive Species
Clearing of vegetation will result in the loss of degraded habitats and potentially increase the risk of invasive alien species. The Project ESIA includes an ESMP which contains mitigation measures on alien invasive species. In accordance with the PE’s Site Rehabilitation Plan, the PE will use only native species in site restoration activities.
Management of Ecosystem Services
As part of the ESIA baseline studies, the use of ecosystem services, dependence of local beneficiaries, and an assessment of replaceability was assessed through consultation. Local communities reported utilizing various natural resources including fuelwood (for cooking and charcoal production) and grass (for construction), with some use of timber, medicinal plants, bush meat (e.g., birds and hare), and mushrooms. The majority of households (87%) reported that these resources were for consumption rather than sale. The priority ecosystem services identified were crop farming, the loss of which is addressed by the LRP and water which has been addressed under PS3.
PS8: Cultural Heritage
The Project triggers PS8 due to significant cultural heritage located in the Dedza District where this Project is located. During the ESIA cultural heritage survey of the Project area, 27 cultural heritage resources were identified: twenty-two archaeological finds, one local historic schoolhouse site, and four living heritage resources (three baobab trees and one cave). All of these, except the cave site, were located within the Project footprint.
The archaeological finds were grouped and collectively described as the ‘archaeological site’ and one of the three baobab trees was identified as a living heritage site. Upon site investigation, the historic schoolhouse was not considered culturally significant. The construction of the Project resulted in the permanent loss of the ‘archaeological site’. The ESIA stated that the ‘archaeological site’ is not a protected monument at the local or national level and, based on the number of similar Iron Age sites found across Malawi, meets the criteria for replicable cultural heritage under MIGA’s PS8. The ESIA listed three mitigation measures related to cultural heritage; development and implementation of a Chance Finds Procedure, additional excavations to determine the ‘integrity and significance’ of the archaeological site and stakeholder engagement to determine the significance of the baobab tree.
The PE developed provisions for managing chance finds through a Chance Find Procedure which will be implemented consistent with the requirements of PS8. The PE also contracted the Department of Museums and Monuments (MoM) of Malawi to conduct a Cultural Heritage Impact Assessment (CHIA) and rescue archaeology for the Golomoti Project. The CHIA cleared the PE to continue with the Project since no significant finds preventing development were identified. The field survey and subsequent cultural heritage impact assessment were reviewed and were found to align with MIGA’s PS8 requirements, the Malawi Cultural Policy, and the Malawi Monuments and Relics Act (1991). Where finds were identified, they were rescued and sent for further analysis or for storage by the Department of MoM.
The PE reported that the Project layout was redesigned, and no culturally significant baobabs will be removed from the Project site. Additionally, stakeholder engagement on the cultural value of the baobab tree was undertaken in October 2021. Through this engagement it was reported that the community did not require ongoing contact with the aforementioned baobab tree.
Based on available information during the due diligence, the removal of non-replicable cultural heritagewill not take place during the construction and operation phases of the Project.
 Nonreplicable cultural heritage may relate to the social, economic, cultural, environmental, and climatic conditions of past peoples, their evolving ecologies, adaptive strategies, and early forms of environmental management, where the (i) cultural heritage is unique or relatively unique for the period it represents, or (ii) cultural heritage is unique or relatively unique in linking several periods in the same site.
- ERM - Environmental and Social Impact Assessment (ESIA) for Proposed 20 MW Golomoti Solar Project, Dedza (Final Report), February 2020.
- SLR – ESIA for the Proposed Battery Energy Storage System for the Golomoti Solar PV Plant (Rev B), February 2021
- JCM Stakeholder Engagement Plan for the Golomoti Solar Project, 2021
- Golomoti Project Environmental and Social Action Plan, November 2021
The above listed documentation is available electronically as a PDF attachment to this ESRS at www.miga.org
Local Access of Project Documentation:
Contact Person: Mr. Jonas Sani
Company Name: Golomoti JCM Solar Corporation Limited (PE Representative)
Address: Plot 608, Area 12, Lilongwe, Malawi
Phone: +265 99 9415 049
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:
International Finance Corporation
2121 Pennsylvania Avenue NW
Washington, DC 20433 USA
Tel: 1 202 458 1973
Fax: 1 202 522 7400