Kube Energy Baidoa
Environmental and Social Review Summary
Kube Energy Hybrid Solar Power Project
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 proposed Guarantee Holder, 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.
MIGA has been asked to provide guarantees covering war and civil disturbance and expropriation to Kube Energy (Mauritius) in support of the development, design, construction, operation and maintenance of a solar hybrid power plant (the Project) with a capacity of 1.92 MW in Baidoa, Federal Republic of Somalia. In 2018, Kube Energy and the Government of the South West State (GoSWS) of Somalia entered into a Memorandum of Understanding (MoU) guiding the development of the power plant. Subsequently, the commercial entity Kube Energy Somalia was registered in Somalia to undertake the Project.
The Project is located 240 km inland from Mogadishu in the protected ‘green zone’ on the outskirts of Baidoa, the interim capital of South West State. The ‘green zone’ is the security perimeter protected by African Union Transition Mission in Somalia (ATMIS) forces, formely known as the African Union Mission in Somalia (AMISOM) at the Baidoa airport. Baidoa is a strategically important city and economic center in southern Somalia, located along a key trade corridor connecting to the seaport of Mogadishu. Within the green zone, the Project will be located on a 4 hectare vacant lot near to the United Nations Support office in Somalia (UNSOS) compound, land which is owned by the GoSWS.
The Project will comprise of 1.92 MWp of solar photovoltaic (PV) panels, 3.2 MWh battery energy storage, and 3 x 500 kVA synchronized diesel fuel generators (1.2 MW). The addition of battery storage (containerized solution) will help storing energy produced by the solar PV during the day to discharge it back to the grid during the night or to stabilize provision of power supply to the off takers. The Project also includes electrical equipment (e.g., inverters, transformers) and the interconnections to the off takers via a medium voltage 3 km transmission line and ancillary facilities such as offices and water and diesel storage tanks, all located within the green zone. The power plant ownership will be transferred to the GoSWS after 15 years of commercial operation.
The power plant has been designed to provide electricity 24 hours / 7 days to international organizations and local government offices in the green zone. The Project has the capacity to generate an estimated 4.8 GWh of electricity per year, of which approximately 60% would be provided by the solar array and battery storage. Some off-takers will receive a higher proportion of renewable energy based on contractual arrangements. Kube Energy Somalia (the Project Enterprise or Project proponent) will own and operate the Project. See the Summary of Proposed Guarantee for more details.
There is the potential to expand the Project within the existing project site up to approximately 2.4 MW generating capacity at a future date to include additional solar PV generation for the sale of electricity to the local utility distribution company during the daytime (the expansion project). Any potential expansion will be presented to MIGA as part of a separate due diligence and underwriting process.
Kube Energy is a Norwegian renewable energy services company established in 2015 which provides access to renewable energy in remote and fragile areas. The company currently operates four solar power plants supplying the United Nation entities in South Sudan and Kenya and is developing projects is other countries in Sub-Saharan Africa (Central African Republic, Democratic Republic of the Congo, and Mali). Kube Energy partnered with CrossBoundary Energy (CBE) Holdings for the financing and further development and implementation of the Project, including CBE’s provision of the environmental and social risk management framework. CBE was launched in 2015 and is Sub-Saharan Africa’s first investment platform for commercial and industrial solar. It provides solar electricity to African enterprises, through fully financed Power Purchase Agreements (PPAs) or leasing solutions.
Construction of the Project is anticipated to take about ten months. Kube Energy will utilize a multi-contract approach for the Project’s engineering and design, construction, and equipment procurement. Soventix GmbH (Germany) is responsible for the engineering, design, construction and commissioning of the Project including the management of the local contractor. D-Hybrid Power Systems GmbH is responsible for supplying the battery energy storage system (BESS) and the thermal generation facilities, and will provide remote assistance to Soventix GmBH for the installation on site. A local company will serve as the local construction contractor to supply construction materials, labor, etc. and will support Soventix.
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), good international industry practices and 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 working conditions (including occupational health and safety (OHS), overseeing contractors and suppliers); soil erosion and dust generation; water quality; waste management (including hazardous); community health and safety (including traffic management, emergency response) and contextual risks related to gender, fragility, conflict and violence.
During operations, key E&S risks and impacts include water and waste management (including hazardous waste), labor and working conditions (including OHS), emergency response, community health and safety (including glare and glint from the PV panels), and contextual risks related to gender, fragility, conflict and violence.
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) is not applicable as the Project site is located on public land within the green zone perimeter and is leased from the GoSWS for a 15-year period, commencing on the commercial operations date. Access to the site has been restricted since the green zone was established in 2012. The ESIA did not identify resettlement, legacy or compensation issues relating to the establishment of the green zone or Project site.
PS6 (Biodiversity Conservation and Sustainable Management of Living Natural Resources) is not applicable as the site is located in an already built-up airport complex and next to ATMIS military structures, has degraded vegetation, and no unique biological diversity.
PS7 (Indigenous Peoples) is not applicable as there are no indigenous peoples in the Project area. Although PS8 (Cultural Heritage) is not applicable as the site is disturbed and there are no registered archaeological or cultural heritage features in the Project area, a chance finds procedure will be required for the Project.
In addition, the following World Bank Group Environmental, Health, and Safety (WBG EHS) Guidelines are applicable to the Project:
- General EHS Guidelines (2007)
- EHS guidelines for Electricity Transmission and Distribution (2007).
The following documents were reviewed by MIGA:
- Environmental and Social Impact Assessment for Kube Energy Somalia, Baidoa Solar PV Plant, prepared by EMC Consultants and Wilson Peak AS, dated May 2022.
- Project Appraisal Document (PAD) on a Proposed Grant in the Amount of SDR 106.5 million (US$150 million equivalent) to the Federal Republic of Somalia for the Somali Electricity Sector Recovery Project (Report No: PAD4224), prepared by the International Development Association, dated November 2021.
- CrossBoundary Energy policies, including Policies and Procedures: Personnel Policy and Procedures Manual (May 2021), Code of Conduct (September 2020), and Environmental, Social and Governance Policy (July 2020).
In addition to reviewing the above documents, due to COVID-19 travel restrictions and security risks, MIGA conducted virtual due diligence from November 2021 – April 2022, including calls with key Kube Energy, CBE representatives and their E&S consultants.
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
Many policies, laws and regulations related to environmental and social assessment, environmental protection, energy, and labor and working conditions are in the process of being developed or are under review in Somalia at both the Federal government and State government levels.
Even though environmental assessment regulations are yet to be implemented, an environmental and social impact assessment (ESIA) was completed for the Project and was carried out based on the agreed high-level design, plant components and parameters of the Project. As per the request from the GoSWS, a copy of the ESIA will be shared (ESAP item). The ESIA includes a framework for an environmental and social management plan (ESMP) and reflects commitments to use CBE’s environmental and social management system (ESMS), supported by E&S policies, plans and procedures and implemented by qualified E&S and Human Resources (HR) specialists.
Based on the high-level commitments and ESMP framework in the ESIA, CBE’s ESMS will be used for this Project and supporting documentation will be developed and implemented in line with MIGA’s PSs (ESAP item). CBE’s corporate policies are reflected in the ESMS such as the Code of Conduct (September 2020) and Environmental, Social and Governance Policy (July 2020) (both further described below).
The construction contractors will be required to develop and implement applicable elements of a site level ESMS including a policy, baseline and task level risk assessments, roles and responsibilities, Health & Safety (H&S) Program, construction Environmental Management Plan (EMP), Emergency Response Plan, etc. as well as monthly and quarterly monitoring and reporting (ESAP item). The Project’s E&S and Occupational Health and Safety (OHS) requirements (including the PSs) are defined in the respective construction contracts, and will be defined in the O&M services agreement, including provisions for the O&M contractor to comply with all applicable laws and requirements (including the PSs) relating to occupational health, safety, labor, and the environment.
The corporate CrossBoundary Energy Holdings policies and guidelines will apply for the development and implementation of the Project and will be followed by Kube Energy Somalia. CrossBoundary Energy Holding’s Code of Conduct and Environmental, Social and Governance (ESG) Policy is applicable to this Project and contractors/sub-contractors are required to abide by it. The Code of Conduct establishes the ethical standards and principles for staff and contractors and integrates ESG factors throughout its operations. Kube Energy will review this code and policy to ensure it aligns with the PSs (ESAP item).
Identification of Risks and Impacts
An ESIA was undertaken for the Project by an independent consultant. The ESIA describes the Project, summarizes E&S related legislative and regulatory framework, describes the E&S baseline conditions in the Project area, summarizes stakeholder engagement and findings, identifies potential positive and adverse environmental and social impacts and appropriate mitigation measures, summarizes an analysis of alternatives, and includes a high-level ESMP outline. The ESIA covers construction, operations and decommissioning of Phase 1 of the project (i.e., not the potential expansion).
In addition, a climate risk screening was performed for the Project - climate change projections indicate the Project region is expected to see an increase in daily temperatures and rainfall totals. The frequency of extreme weather events such as droughts, heavy rains, and wildfires is also projected to increase. Based on a preliminary site assessment, both riverine and overland flood risks are expected to be low due to the hydrological and physiographic characteristics of the Project site. Once a local contractor has been selected, an assessment of potential future flood risks to the Project site will be completed. This will include identifying if detailed hydrological studies are required and if the drainage design should be modified to improve flood resilience (ESAP item). Vegetation near the Project site is minimal, accordingly, wildfire risks are expected to be manageable. Overall, while the Project region is expected to observe several shifts in climatic conditions as a result of climate change, these shifts are not expected to result in unmanageable impacts to the operation of the Project.
A high-level outline of an ESMP is included in the ESIA, with commitments to develop various E&S related management plans and procedures. CBE’s corporate E&S related management plans will be used to form the project-level ESMP. The ESMP will be implemented by the construction contractors and local construction company and will include a set of programs covering for example health & safety, pollution prevention, and emergency preparedness and will be supported by the EPC Contractor’s Risk Assessments and Method Statements which highlight all scopes of work, hazards present and relevant mitigation measures (ESAP item). The operations and maintenance (O&M) contractor will also be required to develop and implement an ESMP (ESAP item). Kube Energy will be ultimately responsible for E&S performance of the Project and will develop and implement robust E&S management programs (including monitoring) as part of the ESMS.
The expected lifetime of the Project is between 25-30 years. The handover strategy of the plant back to local government will include an E&S component (ESAP item). The GoSWS or the selected receiving entity will manage and be responsible for the decommissioning as Kube Energy Somalia will no longer be involved in the Project. The decommissioning process should typically provide for restoring the site to baseline conditions and should include dissembling the PV modules, mounting structures and electrical components. In the event that decommissioning occurs before the transfer of ownership to GoSWS period, Kube Energy Somalia will undertake this responsibility (ESAP item).
Organizational Capacity and Competency
Kube Energy Somalia is responsible for E&S performance of the Project and for ensuring that contractors commissioned during the construction and operations undertake necessary measures to comply with the ESMP. Kube Energy Somalia will be supported by the CBE corporate-level EHS Manager to oversee and approve E&S related policies, plans and procedures at the Project level.
The Project proponent will designate a qualified Health, Safety and Environment (HSE) Project supervisor who will be field-based and supported by other specialists and management as needed (including the project manager) (ESAP item). The HSE Project supervisor will coordinate with the Project Supervisor and oversee the implementation of CBE’s ESMS at the Project and the construction contractors to ensure that there is adequate and effective Environmental and Social compliance. The HSE Project supervisor will be responsible for communicating standards and expectations for E&S performance to contractors, monitoring the regulatory environment and ensuring operations are compliant with applicable legislation and MIGA PSs. The HSE Project supervisor will also be responsible for ensuring inspections and audits are undertaken and corrective actions are taken in a timely fashion where necessary.
The contractors commissioned during the construction and operations phases will be required to develop a Risk Assessment and specific Method Statement plan which covers all construction works prior to the commencement of work. These policies and procedures will need to be approved by CBE EHS Manager. Contractors’ scope of work will include provision for training of workers and of local sub-contractors as necessary for them to effectively implement HSE policies, procedures and processes.
Although the Project will likely use a local construction company which has experience working in the green zone and with the United Nations, EHS capacity may be low and/or inconsistent. Furthermore, there will likely be a lack of E&S supervision by regulatory agencies. Therefore, robust capacity building and monitoring by construction contractors, the O&M contractor, and Kube Energy/CBE should be factored into their respective training, monitoring, and budgetary components.
Emergency Preparedness and Response
The Project proponents will identify and assess major accident hazards, and will develop an emergency prevention and management plan, to prevent major accidents and to limit their adverse impacts on workers, affected communities and the environment (ESAP item). This plan will set out the principles for safety and emergency management and define the roles and responsibilities of the Project proponents and contractors, including the organizational structures, responsibilities, procedures, communication, training, resources or other aspects required to prevent and respond effectively to emergencies associated with Project hazards. Furthermore, the plan will identify emergency services potentially provided by other stakeholders such as the UN, ATMIS or GoSWS.
Monitoring and Review
Kube Energy (through one of its legal entities) will be the contractual counterparty for all construction and procurement contracts. Kube Energy Somalia will be the contractual counterparty for the operations and maintenance (O&M) services agreement, and will be responsible for O&M oversight, remote performance monitoring and business management services over the 15-year period.
It is anticipated that the construction contractors will undertake monthly site audits of all construction related activities. The Project HSE supervisor will effectively monitor all site activities and ensure that there is weekly submission of HSE reports (e.g., Job Hazard Analysis, PPE inspections, tool box talks, incident reports) for the scope of work. CBE will also conduct monthly site visits to ensure compliance standards are adhered. On completion of the construction activities, the contractor’s Project supervisor along with the HSE supervisor will conduct a site inspection to identify any items requiring attention. These items will be summarized in a post- construction audit report to be shared with MIGA and will be addressed by the contractor in a timely manner.
The HSE supervisor will maintain a register of all HSE related incidents and such incidents will be investigated to determine root cause analysis and corrective actions. These procedures will be reflected in the ESMS supporting documents (ESAP item).
During construction, the Project will submit quarterly E&S reports to MIGA reporting on compliance with MIGA E&S requirements, the reporting format to be agreed with MIGA (ESAP item). During the first two years of operations, the Project will submit E&S reports bi-annually (every six months) and thereafter, annually reporting on compliance with MIGA’s E&S requirements.
As part of the ESIA, 27 interviews were carried out with various stakeholders (government, community representatives, and international organizations). The main goals of the stakeholder consultation process were to engage with key stakeholders who have an interest in or may be affected by the Project, to provide information, to establish relationships and to provide an opportunity for them to share feedback during the Project’s planning and preparation stage.
Overall, stakeholders are supportive of the Project and are aware of positive impacts (e.g., reducing GHG emissions and air emissions, creating limited jobs, increasing electricity generation capacity, creating cost savings, etc.). Key issues raised during the consultations included management of waste (including e-waste), creating employment opportunities for particular groups (especially for women, youth and Internally Displaced People), and ensuring access to Project information in a safe area outside the green zone which community members can access. Stakeholders also recommended that the Project ensure early planning and preparation for the handover of the plant to the local government. Some community members had expectations which are beyond what this Project can deliver due to the conditions in the governing agreements, such as provide power for 24-hour street lighting. Stakeholder engagement is continuing after the ESIA process.
The Project has committed to develop a Stakeholder Engagement Plan (SEP) to communicate and disclose project-related information to key stakeholders, as well as the establishment of a Grievance Redress Mechanism (ESAP item). The SEP will be updated before construction and will apply for the duration of the Project. It will be further updated when necessary.
External Communications and Grievance Mechanism
The issues raised during the consultation process have informed the ESIA and the development of the ESMP for the Project. The ESIA and ESMP will be publicly disclosed and available online through Kube Energy’s website (http://www.kubeenergy.com/). Physical copies of the Executive Summary will be available in both English and Somali at a publicly accessible location in town.
A project-level Grievance Mechanism (GM) will be developed, and socialization of the GM will be carried out (ESAP item).
PS2: Labor and Working Conditions
The direct labor force required for the civil works and construction of the plant is estimated to be approximately 40 unskilled workers who will be recruited mainly from Baidoa by the local construction contractor. In addition, a small team of technical, engineering and supervisory staff from outside Baidoa will oversee the construction.
The operation of the plant is expected to require approximately ten full time personnel. Additional temporary workers from the local area may be hired for panel cleaning and other maintenance activities. Technical staff will come from outside Baidoa to carry out maintenance as required.
The contractors will publicize information about open positions and the recruitment process through locally appropriate communication means, recognizing workers will need to pass a vetting process to enter the green zone. The majority of the workforce will be recruited locally from Baidoa and will stay in their own residences. The small number of engineering and supervisory staff who come from outside Baidoa during construction and scheduled maintenance will be accommodated within the green zone at the UN accommodations. They are not expected to leave the green zone. The Project has committed to take into consideration the Guidance Note jointly developed by IFC and EBRD for workers’ accommodation: Workers’ Accommodation: Processes and Standards (2009).
CBE’s Code of Conduct commits to adhere to the IFC/MIGA Performance Standards and WBG EHS guidelines in implementing its projects, including PS 2. All contractors are required to comply with this Code of Conduct.
A Human Resources policy and supporting procedures will be developed for the Project (ESAP item).
Working Conditions and Management of Worker Relationship
A clear and understandable employment contract will be made available to all workers explaining working conditions. The HR policy will include providing all workers with information regarding their rights and responsibilities, including freedom of association and collective bargaining (ESAP item).
Contractors must be committed to establishing and maintaining a work environment in which all individuals are treated with respect and dignity. Per the ESIA, each individual has the right to work in a professional atmosphere which promotes equal employment opportunities and prohibits discriminatory practices, including harassment. The company’s Code of Conduct also supports a respectful workplace.
An internal grievance mechanism (GM), including an anonymous channel, will be developed as part of the HR Policy and procedures in line with PS 2 requirements and will be available to use for harassment complaints (ESAP item). Staff who are responsible for managing harassment complaints will receive relevant training from a qualified provider (ESAP item). The Project will communicate the GM to contractors and will provide training on how to submit a grievance. The contractor will explicitly prohibit retaliation by any employee against any other employee who has brought forward an issue or complaint in good faith through the Project’s GM, per the Code of Conduct.
Protecting the Workforce
The approach to human and labor rights in the Project is governed by the principles included in the ESMP framework in the ESIA. The Project will not employ persons (formally or informally) under the age of fifteen (15) for general work and under the age of eighteen (18) for work involving hazardous activity. In recognition of the vulnerability of migrant workers and trafficked persons who lack legal status in a country, it is expected that the Project will conduct adequate diligence in selecting contractors that will be supplying labor and ensure that terms of employment for migrant and non-migrant workers engaged in comparable work are substantially equivalent.
Occupational Health and Safety (OHS)
The Project will develop an OHS plan and related procedures which include for example a health and safety policy, risk assessments, hazard analysis, mitigation measures, incident reporting and root cause analysis, audits and inspection, etc. (ESAP item). The OHS plan should incorporate temperature and weather-related impacts (such as extreme heat, dust storms, etc.) and include management and monitoring related to the Covid-19 pandemic.
OHS training matrices will be developed to ensure appropriate training is provided to workers (including contractors) and will be reported in quarterly construction and O&M reports. The Training Matrix should include detailed training requirements for key workers, contractors, and subcontractors. In addition, weekly (or daily) toolbox talks should occur on a regular basis.
Workers Engaged by Third Parties
Human resources policies and requirements are extended to contractors and other applicable contractors as required by PS2, as described above. The contractors for the Project will be required to have a recruitment process which ensures equal opportunities in employment.
The Project proponent will implement a code of conduct that covers suppliers and carry out supply chain screening to assess health and safety, environmental and labor practices within their supply chain in line with the Performance Standards (ESAP item). The Project proponent will undertake supplier screening covering forced labor and child labor as part of its due diligence process in line with PS 2 requirements.
The construction and O&M contractors will also be contractually required to follow the Project proponent’s Code of Conduct. Kube Energy’s and CBE’s respective Codes of Conduct include commitments related to responsible procurement and they will be reviewed to ensure alignment with PS requirements related to supply chain (ESAP item).
PS3: Resource Efficiency and Pollution Prevention
Resource efficiency initiatives is integrated into the ESMS. Drinking water for the site is supplied by an external contractor and water for sanitation, construction and panel cleaning will be obtained from private service providers. Water consumption will be captured in the monthly O&M report. To encourage resource efficiency, usage will be compared against targets or defined industry benchmarks and key performance indicators (KPIs) will be monitored and reported (ESAP item).
The ESIA included an estimation of Greenhouse Gas (GHG) emissions associated with the operational phase of the Project. GHG emissions are expected to be minimal from the PV solar component, operational emissions will be associated with the use of the diesel gensets. The Project will include 3 diesel gensets (500 kilovolt-ampere (kVA)) with a total rate heat input capacity of 1.2 Megawatts Thermal (MWth). Based on the manufacturer’s specifications for the gensets, 570,000 liters of fuel will be consumed per year during the Project’s operation. This fuel usage translates to gross GHG emissions of 1,539 tons of carbon dioxide equivalent (CO2e) per year.
Construction activities will result in localized air quality impacts resulting from dust/particulate matter from earthworks, and gaseous emissions from construction equipment, transport vehicles and generators used to supply electricity during construction. Dust management and suppression measures will be implemented such as covering excavated materials, sprinkling water, and maintaining vegetation to reduce windblown matter. Areas to be cleared of vegetation or topsoil shall be minimized. Vehicles and machinery will be maintained in good working condition to reduce noxious emissions and exhaust. During operations, generators will be maintained in good working condition. Diesel will be transported to the site by third party providers. Fuels will be stored in covered/sealed containers and safely handled on site to minimize spills or leakage and to avoid potential fugitive emissions. Above ground diesel storage tanks will be fully bunded with 110% maximum volume capacity. Pollution prevention mitigation and monitoring measures will be detailed in the Environmental and Waste Management Plan (ESAP item).
Construction activities will generate waste which includes: packaging and wood scrap; unused construction materials and off-cuts; civil wastes such as sand, cement and aggregates; and domestic waste generated by the workforce. Excavated materials generated will be re-used for site filling and leveling. Construction and operations wastes generated will also include small quantities of hazardous wastes such as oils used in the maintenance of equipment and human waste from the workforce. Wastes generated during O&M will include e-waste (e.g., damaged solar panels and obsolete batteries and electronics). The productive lifetime of solar PV equipment is generally 30 years, with solar PV panels having a 20-year performance guarantee, after which they will continue to produce electricity, although the level output is no longer guaranteed by the manufacturer. The lifetime of solar panels and other electronic equipment will be maximized to reduce equipment disposal rates.
Commercial waste disposal operators exist in Baidoa; however, recycling facilities do not currently exist. Somalia does not currently have facilities for the recycling of e-waste or hazardous wastes such as waste oils. Several countries in the region are establishing such facilities, and therefore, e-waste and hazardous waste will be stored safely at the site until it has been collected in sufficient quantities to warrant transporting to appropriate recycling facilities in the region or returned to the supplier for recycling. Plant maintenance and waste management procedures will be designed to minimize the quantities of hazardous wastes generated, and a Environmental and Waste Management Plan will be developed prior to start of construction (ESAP item).
The plant is located in an area with high baseline noise levels due to its proximity to the airport and the traffic from military and supply vehicles in the area. Machinery use during site preparation and construction is expected to result in temporary, localized increase in ambient noise. During operations, generators and other noise generating equipment will be housed in an acoustic enclosure. Construction activities generating noise levels over 70 dBa will be limited to 7 am to 6 pm. Impacts to local communities and UN/ATMIS personnel are expected to be minimal. Overall, once operational the Project is expected to lead to reduced noise levels because the diesel generators currently used by off-takers will be substituted by the electricity generated by the solar power plant.
The site is flat and slopes gradually to the east/northeast and the substrate is suitable for construction, thus reducing the need for earthworks during construction. Fixed PV panels will be anchored using piles driven into the ground instead of using concrete. A small amount of concrete will be required for foundations for batteries, generators, inverters and liquid storage tanks.
Water will be required for sanitary purposes, maintenance of machinery, mixing of concrete, dust suppression, fire fighting, and PV module cleaning. Water will be obtained off-site from a municipal supply point or from a UNSOS managed borehole, transported to the site via bowsers and stored in two 10,000 liter tanks. Grey and black water will be stored in septic tanks and removed by a qualified third-party service provider. Wastewater management will be addressed as part of the Environmental and Waste Management Plan.
PS4: Community Health, Safety and Security
Community Health and Safety
All components of the Project are located in the green zone and the nearest residential area is Wadjadir, a sub-village of Isha, approximately 100 meters from the perimeter of the Project site on the other side of the fenced green zone perimeter. The area to the west of the green zone is primarily agricultural land. South of the green zone is a gravel road leading to Bardera. Internally displaced persons (IDP) settlements are primarily located on the outskirts of Baidoa, including along the Baidoa-Bardera road south of Wadjadir.
Kube Energy is coordinating with ATMIS and the UN to carry out risk assessments with regard to the location of the project in the green zone. Any required safety mitigation measures will be coordinated with MIGA and implemented prior to commencing activities at the Project site.
During construction and operation of the Project, a small number of technical and managerial personnel will come from outside Baidoa. These personnel will travel to the site by air, be housed within the UN compound and are not expected to leave the green zone. The remaining workforce will be residents of Baidoa and therefore, the impact of the workforce on the surrounding communities is expected to be negligible.
Most project components will be transported to the site by air, which will reduce the impact on traffic as well as the security risks associated with road transport. During construction, Project-related vehicle traffic (including diesel delivery) to and from the site will be limited and will not lead to noticeable traffic increases. The roads leading to the green zone pass through the urban area of Baidoa and are used as supply and transport routes for the UN, ATMIS and other commercial entities with traffic from heavy vehicles and suppliers. Therefore, the overall impact on traffic is expected to be minor. A transport plan for the delivery of main components to and movement within Mogadishu and to the Project site during the construction period, as well as for regular supply activities to the Project site during operations will be developed and implemented (ESAP item). Project related vehicles will use well maintained vehicles and reduced driving speeds. Detailed route surveys will be carried out to conduct a route hazard survey to ensure all mitigations are in place prior to teams embarking to the site.
The power plant will not utilize high voltage transmission lines or equipment. It is expected the electromagnetic field (EMF) level will be below the safe exposure levels set by the International Commission on Non-Ionizing Radiation Protection guidelines and will have a negligible effect.
Solar PV modules are designed to absorb rather than to reflect light. Nonetheless, panel glass can produce a concentrated reflection which may cause glint (a quick reflection) or glare (a longer reflection). Due to the location of the Project site near Baidoa’s airport, the potential impact of glint and glare on the flight path has been assessed as part of the ESIA. This assessment considered the orientation and tilt of the solar panels and direction of the flight path to predict the times of day and year where glare could occur. It was determined that the potential negative impact was very low and limited. The Project, including site location, was described to the SWS Minister of Transport and Civil Aviation and the latter agreed and provided his full support. The Project is committed to continue working with the operator of the Baidoa airport if there is any need in the future.
The Project is located in a post conflict setting with a fluid security situation. The Project is located in the Baidoa green zone which is an area with restricted civilian access that is secured by ATMIS peacekeeping forces and houses the airport; ATMIS military structures and sector headquarters; several international organizations including the United Nations (UNSOM, UNSOS, etc) regional hub, offices and operational structures; and local and state government offices. Access is heavily controlled and all people and vehicles are searched before entering through checkpoints and the main gate.
The Project site itself will be secured by fences and secured gates with 24/7 guards. A private security provider will provide site-specific security services at the Project site as an additional layer of security to monitor and observe the site, control access to the site and deter theft or damage of equipment. Because the site-specific security personnel will be deployed in the green zone, they are not expected to interact directly with the surrounding community. The Project proponent will ensure that adequate modules on human rights issues and gender topics are integrated into the training program and well communicated to security guards. A module on the Project’s GM to support security-related grievances will also be included (ESAP item).
Guided by relevant policies, an in-depth Project-level security risk assessment (SRA) will be undertaken to ensure the safety of Project workers, contractors and service providers. A Project-level security risk management plan (SMP) will be prepared in line with the requirements of PS4 to ensure adequate security risk management, emergency responses (including roles and responsibilities of private security and public forces) and duty of care for project workers, project-affected parties and contractors (ESAP items). Kube Energy will provide ultimate oversight of the project security guards and will record all security incidents and investigate all allegations of unlawful or abusive acts by its security personnel (ESAP item).
The documentation listed below is available electronically as a PDF attachment to this ESRS at www.miga.org:
- Environmental and Social Impact Assessment for Kube Energy Somalia, Baidoa Solar PV Plant, prepared by EMC Consultants and Wilson Peak AS, dated May 2022.
- Environmental and Social Action Plan, dated May 2022.
Local Access of Project Documentation:
Contact Person: Kristen Petillon, Chief of Business Development/Project Manager
Company Name: Kube Energy Somalia
Address: Geneva, Switzerland
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