Scatec’s Feed-in-Tariff Program projects in Egypt
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 Projects 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.
Scatec Solar ASA (“Scatec” or developer) is seeking MIGA coverage for convertibility and transfer restriction risks for 6 Scatec operational Projects within the Benban Solar Complex. All the 6 Projects are currently in operation (Commercial Operation Date (COD) for each project is provided in brackets) and they include; Aswan PV Power S.A.E.( April 10, 2019), Daraw Solar Power S.A.E(June 2, 2019), Upper Egypt Solar Power S.A.E.(June 10,2019), Zafarana Solar Power S.A.E.(August 19, 2019), Kom Ombo for Renewable Energy S.A.E.(August 30, 2019), and Red Sea Solar Power S.A.E.(Oct 17, 2019). These Projects are hereafter referred to collectively as the ‘Project Enterprise’(PE), as they are all Special Purpose Vehicle (SPV) companies owned and managed by Scatec Solar, a global leading independent solar power producer and developer. Its current operations are in Czech Republic, South Africa, Rwanda, Honduras, Jordan, Malaysia and Brazil follow an integrated business model across the complete lifecycle of their solar power plants, including Projects development, financing, construction, ownership, operation and maintenance. Scatec Solar Solutions Egypt will undertake the role of the Operations and Maintenance (O&M) contractor for all six Project. Scatec Solar Solutions Egypt was established as an Egyptian limited liability company on February 10, 2016. It was established between Scatec Contractors B.V. and Scatec Solar ASA. Scatec Contractors B.V. is a private company with limited liability, registered with the Netherland Chamber of Commerce. Scatec Solar ASA, is a Norwegian company that develops, builds, owns, operates, and maintains solar power plants and installation.
Each project comprises a single axis tracking system of approximately 209,408 PV panels (polycrystalline silicon modules) with installed capacity 65 Mega Watts alternating current (MWAC) (so a combined capacity of 390 MWAC for the 6 projects). Ancillary infrastructure for each project includes access roads, storage, laydown areas and office buildings. The Projects form part of the Egyptian government feed-in-tariff (FiT) scheme aimed at diversifying and securing Egypt’s electricity supply. The European Bank for Reconstruction and Development (EBRD) is also providing long term senior debt financing to the Project. MIGA already covers 9 projects in the Benban Solar Complex, and the ESRS’ for these projects are available on MIGA’s website.
The Benban Solar Complex comprises a 37.5-square kilometer (km2) area in the Aswan Province of Egypt allocated to Egypt's New and Renewable Energy Agency (NREA) located in the western desert, 15 km west of the River Nile and approximately 1 km west of Aswan – Luxor highway. The complex is approximately 650 kilometers (km) from Cairo. The Projects area is all desert land, largely unused and unpopulated. The area is mainly flat, with sand and gravel dunes, and with no notable natural vegetation and no human activities. The nearest villages are Benban village, about 12 km east and Fares village about 25 km northeast, with 26,200 and 11,000 inhabitants respectively. The nearest cities are Aswan, 40 km south and Luxor 140 km north.
The Benban Solar Complex was developed in 2016 and sub-divided into 39 plots each allowing for a solar plant of up to 50 megawatts (MW) with a total capacity for the entire site of up to 1.8 Gigawatts (GW). The 32 Projects in the Egypt FiT Program have mostly completed (including Scatec’s 6 Projects) the design, procurement, construction, erection, installation, testing and commissioning phases and are in Operation and Maintenance (O&M) phase. There are seven plots, which remain to be allocated.
During Construction, a Facilities Management Company (FMC), Hassan Allam, was collectively appointed by NREA and the Egypt Electricity Transmission Company (EETC) in conjunction with the Benban Developers Association (BDA) on 23 January 2018. FMC was responsible for managing the cumulative E&S aspects of construction in the Solar park on behalf of all sponsors and developers. As the construction phase for all projects is almost complete, the FMC construction-phase contractual agreement is coming to an end and the Benban Developers Association (BDA) is tendering for the services of an Operation and Maintenance Facility Management Company (O&M FMC) to manage the Benban Solar Park E&S risks and issues for the operation phase. International development finance institutions, which are funding some of the projects within the complex (e.g. International Finance Corporation (IFC), MIGA and EBRD), have also provided advice during the procurement of the FMC. BDA confirmed in September 2019 that the O&M FMC will be delayed due to coordination process with all stakeholders (NREA, EETC, BDA and developers) to hire the O&M FMC taking longer than expected, and therefore, in the interim they have extended the construction FMC contract for the next 6 months to continue to manage E&S aspects of the common facility on behalf of the BDA. The FMC coordinates the management of environment, social and health and safety (ESHS) risks to ensure that issues are managed consistently throughout the solar park.
Power will be sent to an inverter and fed into the utility power grid system through EETC substations (SS) 1, 2 and 3. The 6 Scatec Projects will be linked to the following substations: Aswan, Daraw, and Kom Ombo Projects will be linked to substation 2 (SS2) on the eastern part of the Benban complex. Upper Egypt and Zafarana Projects will be linked to substation 3 (SS3) also on the eastern side of the Benban PV solar park and Red Sea Project will be linked to substation 1(SS1) on the North eastern part of the Benban complex. All the Projects will be linked to nearest 4 Egyptian Electricity Transmission Company (EETC) high voltage substations that were constructed and completed within the Benban complex in 2018, via an underground 22 kV transmission line installed by EETC. The output generated by the Projects will be sold to EETC under a 25-year Power Purchase Agreement
The 6 projects collectively are classified as a Category B Project under MIGA’s Policy on Environmental and Social Sustainability (2013) as the E&S impacts associated with the Projects are limited, generally project-specific and can be addressed through the implementation of good international industry practices and mitigation measures. The Key risks and impacts include water consumption, occupational health and safety (OHS), waste management, transport /traffic management, security, life fire and safety, community engagement and corporate social responsibility among others.
The 6 Scatec projects are each with installed capacity of 65 MWAC, which are located in a solar park with at least 26 other 50 MWAC solar plants. As such, there are potential cumulative environmental and social impacts such as occupational health and safety, community safety, water consumption, dust, waste associated with construction, and to a lesser degree the operational and decommissioning phases, which will need to be managed in a coherent and coordinated manner.
While all Performance Standards are applicable to these Projects, MIGA’s environmental and social due diligence indicates that the 6 Projects will have impacts which must be managed in a manner consistent with the following Performance Standards (PS):
- 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
The Benban Solar Complex land was previously open desert. It is now owned by NREA and leased to the developers for a 25-year period. No displacement (physical or economic) was required for the Project, thus PS5 on Land Acquisition and Involuntary Resettlement is not applicable. The area comprises desert with minimal vegetation and surveys have not identified any features or species which would trigger PS6 for Biodiversity Conservation and Sustainable Management of Living Natural Resources. There are no Indigenous Peoples in the Projects area, and therefore PS7 on Indigenous Peoples is not applicable. The studies as part of the ESIAs did not reveal cultural heritage, therefore PS8 on Cultural Heritage is not applicable. However, prior to construction, the Projects developed a chance finds procedure in case of the identification of cultural/archeological resources in the area.
World Bank Group (WBG) EHS General Guidelines and Guidelines for Electrical Power Transmission and Distribution also apply to this Project.
The following documents were reviewed by MIGA
- Environmental and Social Impact Assessment for Aswan PV Power SAE 50 MW(AC) in Benban, Aswan (scoped form B study) (Environics, April 2016)
- Environmental and Social Impact Assessment for Kom Ombo Renewable Energy SAE 50 MW(AC) in Benban, Aswan (scoped form B study) (Environics, April 2016)
- Environmental and Social Impact Assessment for Red Sea Solar Power S.A.E. 50 MW(AC) in Benban, Aswan (scoped form B study) (Environics, April 2016)
- Environmental and Social Impact Assessment for Upper Egypt Solar Power SAE 50 MW(AC) in Benban, Aswan (scoped form B study) (Environics, April 2016)
- Environmental and Social Impact Assessment for Daraw Solar Power S.A.E 50 MW(AC) in Benban, Aswan (scoped form B study) (Environics, May 2016)
- Environmental and Social Impact Assessment for Zafarana Solar Power S.A.E 50 MW(AC) in Benban, Aswan (scoped form B study) (June 2016)
- Strategic Environmental and Social Assessment – Benban 1.8 GW photovoltaic solar park (NREA), Egypt (Eco Con Serv, February 2016)
- Benban Solar FiT Scatec Solar – First Quarterly Environmental and Social Construction Monitoring Report (Mott MacDonald, August 2018)
- Benban Solar FiT Scatec Solar – Second Quarterly Environmental and Social Construction Monitoring Report (Mott MacDonald, November 2018)
- Benban Solar FiT Scatec Solar – Third Quarterly Environmental and Social Construction Monitoring Report (Mott MacDonald, February 2019)
- Benban Solar FiT Scatec Solar – Fourth Quarterly Environmental and Social Construction Monitoring Report (Mott MacDonald, May 2019)
- Benban Solar FiT Scatec Solar – Fifth Quarterly Environmental and Social Construction Monitoring Report (Mott MacDonald, September 2019)
MIGA’s E&S due diligence of the 6 Projects consisted of: (i) review of client’s E&S and independent lender’s E&S advisor documentation, (ii) discussions with the client to assess its capacity to manage ESHS risks and compliance with the Egyptian regulatory requirements and MIGA’s PSs; and (iii) discussions with the EBRD regarding the Projects E&S risks and impacts during construction and operations, Projects specific details and an overview of the Benban Solar Complex.
PS1: Assessment and Management of Environmental and Social Risks and Impacts
Environmental and Social Assessment and Management Systems:
The PE developed an Environmental, Social, Health and Safety Management System (ESHS MS) specific to each Project during construction phase that was reviewed and approved by the EBRD, which financed the projects. The ESHS MS provides an overarching ESHS policy; identifies environmental and social risks and impacts; outlines a framework for the development of specific management plans; and briefly outlines roles and responsibilities. Moreover, at the corporate level, Scatec’s management system is ISO 14001:2004 (Environment) and ISO 45001 (OH&S) certified. For the operation phase, the PE will be required to update and develop a common ESHS MS for the 6 projects and ensure it is in line with MIGA PS1 requirements and FMC’s ESHS MS for the complex per the ESAP. The operation’s ESHS MS will include programs, plans and procedures, an overarching system for reporting and tracking non-compliances, and an organizational framework. In addition, the ESHS MS will include an emergency preparedness and response plan, reflect the current Projects structure and arrangements, and include the implementation mechanism. The PE will ensure that the Projects ESHS MS is aligned with the FMC ESHS MS for the Benban Solar Complex.
Identification of Risks and Impacts:
A Strategic Environmental and Social Assessment (SESA) for the Benban Solar Complex was prepared for NREA with funding from EBRD and in consultation with IFC with the objective of providing an overarching assessment of the E&S impacts of the Benban development. The SESA considered cumulative impacts with respect to the additional impacts expected beyond the development of a single solar power plant with individual developers responsible for defining and implementing site specific mitigations/ recommendations as appropriate within their environmental management plans. Due to the development of the SESA, the individual projects within the solar park were categorized as requiring a Form B EIA by the Egyptian Environmental Affairs Agency (EEAA). As a result, the SESA supported the ESIA process for the project, resulted in a more consistent approach at the individual Project level for the Form B EIA preparation, and reduced the need for, and cost of, additional baseline studies. It also removed the need for a project-specific consultation process.
In order to address project-specific impacts, ESIAs were undertaken for each Project, and covered the construction, operation and decommissioning phases and included an Environmental and Social Management Plans (ESMPs) which will be updated for the operation phase in line with MIGA’s PS, WBG EHS Guidelines, SESA commitments and permit requirements.
The SESA concluded that the Environmental Social, health and safety (ESHS) risks from individual solar developments at the Benban Solar Complex could be adequately managed through application of good practice management, but the cumulative impacts from several developments advancing in the same area at the same time could pose potential significant construction challenges and risks related primarily to traffic and transportation, occupational health and safety, accommodation, labor management, waste management, security and the management of stakeholder expectations from nearby local communities. The SESA also concluded that to address these common issues, a coordinated approach was needed. It further noted opportunities for positive impacts related to engagement with the local communities and community investment efforts if carried out strategically and in a coordinated manner.
As such, the BDA was created in 2016 and reactivated in February 2017 to coordinate the various developers’ responses with regards to the management of common or shared facilities, activities or issues across the entire Benban Solar Complex. Scatec is a member of the BDA and was selected through a voting process to have a representative as one of the seven board members of the BDA.
Under an amendment to the Cost Sharing Agreement (CSA) between the EETC, NREA and the BDA, EETC and NREA are required to appoint an FMC on behalf of the developers to managecross cutting construction and operation activities for the Benban Solar Complex. These activities include: managing labor and workers’ strategy which includes (among other things) sourcing workers worker accommodation and establishing a common set of standards on employment (wages and benefits); water and wastewater services; waste management services; logistics and security services; stakeholder engagement and community investment. This approach will ensure a consistent approach to management of ESHS risks and impacts, including cumulative issues. The FMC developed and implemented the overarching ESHS management plans for the construction phase and is expected to update these management plans for the operation phase. The FMC will be contractually obligated to provide construction and operation services in line with MIGA PS, EBRD PR, and European Investment Bank (EIB) E&S Standards.
An FMC was appointed in January 2018 (refer to the Project Description) for the construction phase, and EETC and NREA are currently tendering for an operations phase FMC. During operations, the FMC will provide “mandatory” services to all developers (whether they are in the BDA or not), including EHS management, traffic management, community stakeholder engagement and grievance management and waste management. The PE will coordinate with the FMC to comply with all required items outlined in the SESA as “common issues”.
Under the ESHS MS, an ESHS Management Plans (ESHS MPs) were prepared for the Projects by the EPC for the construction phase. The PE implemented the ESHS MPs effectively during the construction phase per Mott MacDonald the lenders Independent Environmental and Social consultant (IESC) assessments and reports. For the operation phase, the PE will be required to update and develop a common ESHS MPs for the 6 projects and ensure it is in line with MIGA PS1 requirements and FMC’s ESHS MPs for the complex per the ESAP. The ESHS MPs will include plans for management of air quality, noise, water resources, solid and hazardous waste, and health and safety among other topics. The ESHS MPs include details on monitoring actions, and the frequency of monitoring, along with the performance indicators.
PE will ensure that the workers are made aware of the requirements, measures, and protocols stipulated within the ESHS MPs for the operations phase through induction training and a workers’ manual that will be translated into Arabic.
Organizational Capacity and Competency:
The E&S organizational structure for the operations has been developed. At the start of the operations, there will be approximately 25 people at the 6 Scatec Projects (will not exceed 40 persons as operation progresses), which include an O&M Manager, a Plant Manager, and a team of electrical engineers and assistants. Each one of this team has HSE responsibilities, however, a full-time safety officer is being appointed for the plant(s), supported by an Health, Social, safety , Environmental and Quality (HSSEQ) advisor based on South Africa (bi-annual visits) and an E&S compliance manager based in Cairo (approximately visits every 6 weeks).The PE will ensure the HSE personnel for the operation phase are competent to carry out their roles and responsibilities effectively, or, where necessary, provide them with tailored training to achieve the level of competency required for the Projects operations.
Emergency Preparedness and Response:
During construction, the PE developed an Emergency Preparedness and Response Plan (EPRP) that was in line with EBRD standards and aligned with the FMC’s EPRP. For the operations phase, the PE will be required to updated and develop a common EPRP for the 6 Projects and ensure it is in line with MIGA PS1 requirements and FMC’s EPRP for the complex per the ESAP. The EPRP will also describe reporting requirements and roles and responsibilities in relation to the FMC’s EPRP.
Monitoring and Review:
During the Projects Operations phase, the PE will be responsible for reviewing and auditing Scatec Solar Solutions Egypt HSE performance and compliance against its ESHS MS, Egyptian legislation, MIGA’s PS and WBG EHS guidelines. ESHS monitoring requirements will be included in the ESMP for the operations phase of the project. MIGA will require that the Scatec submits annual monitoring reports (AMR) containing relevant E&S information throughout the guarantee period.
Stakeholder engagement activities were carried out as part of the development of the SESA. Moving forward, all stakeholder engagement will be managed through the FMC and will build on the engagement undertaken as part of the SESA which included meetings with local villagers, both individually and as a group. According to its Terms of Reference, FMC will develop a Stakeholder Engagement Plan (SEP) for the Benban Solar Complex in order to coordinate efforts and resources. The PE will be required to develop a stakeholder strategy to outline how the 6 Projects will interact and implement the FMC’s SEP per the ESAP.
Community development planning is led by the BDA on behalf of all operators within the Solar Complex A number of potential opportunities for community development were identified in the SESA including training (for local employment), health services (improving health units), and infrastructure (including schools and roads). BDA is leading the efforts to finalize the CSR program and strategy in coordination and collaboration with governments, developers, communities, and lenders. Scatec have developed a Corporate Social Responsibility (CSR) plan for all of its operations in the Complex, which is in line with the strategic community investment efforts of the BDA. Scatec as a member of the BDA is committed to the CSR program once agreed and approved.
The FMC will develop a community grievance mechanism for the Benban Solar Complex in alignment with PS1 and will be responsible for responding to any grievances which are raised in relation to the overall site or individual developers. The PE have developed a community grievance mechanism for the Projects during construction phase. For the operation phase, the PE will be required to update and develop a common community grievance mechanism for the 6 projects and ensure it is in line with MIGA PS1 requirements and FMC’s community grievance mechanism for the complex per the ESAP. The grievance mechanism will include details of how any grievances identified by FMC as being caused by the activities of the Projects will be recorded and addressed by the PE. All responses to grievances will be processed by the FMC to ensure a consistent approach to stakeholder consultation from the whole complex.
PS2: Labor and Working Conditions
Combined, the 6 Projects employed approximately 1,000 workers during the construction phase and will employ 30 personnel for the operation phase. Scatec personnel include the O&M manger, engineers, HSE teams and solar panel cleaners (approximately 10-15 per plot per washing cycle). For the operations phase, the PE will ensure that the recruitment of workers complies with the recruitment procedures developed by the FMC and will recruit from the FMC-maintained database of local workers prior to recruiting any worker from outside Aswan.
Human Resources Policies and Procedures:
The Projects Human Resources (HR) policy and procedures was developed during construction in line with MIGA PS2, Egyptian labor law and aligned with FMC HR policies and procedures. The PE will continue to implement it for the operations phase. PE will be required to conduct induction training on the HR policy and procedures and basic safety awareness training to all newly hired workers. Other types of technical skills training will be identified for staff on as-need basis.
Working Conditions and Terms of Employment:
The project’s HR policies, procedures will stipulate the terms of employment (wages and benefits, hours of work, overtime arrangements and overtime compensation, annual and sick leave, maternity and paternity leave, vacation and holiday, health insurance and end of service benefits) according to Egyptian national labor regulations and will also include provisions on restrictions to child labor and prevention of forced labor as well as commitment to non-discrimination and equal opportunities for employees and contractors and will be shared with all new hires.
In line with PS2, the project’s and FMC HR policies and procedures will not impede workers from freedom of association and collective bargaining. Workers will be able to organize among themselves and will not be intimidated, punished or discriminated against for doing so. Workers will be allowed to join unions or otherwise allow collective bargaining. If unions are formed, the PE will communicate with the workers’ organizations and their representatives.
Non-Discrimination and Equal Opportunity:
Scatec is committed to non-discrimination based on the age, gender, sexual orientation, health, race, nationality, political opinions or religious beliefs of its counterparties. The requirements of non-discrimination and equal opportunities will be extended to all contractors and sub-contractors as part of contractual obligations.
A workers’ grievance mechanism was developed during construction and thePE will continue to implement it for the operations phase. The PE will ensure it is made available to all workers including contractors and sub-contractors. The grievance mechanism clearly defines the response timeframes to grievances and incorporates a grievance log as part of the grievance redress mechanism process.
Occupational Health and Safety:
During the Projects operations phase the key Occupational Health and Safety (OHS) risks include exposure to electric shocks and burns, potential fires from faulty transformers, safety issues related to PV module cleaning and driving risks (i.e. accidents). Taking into account the hot and arid Projects location, during the operations, workers might also be at risk of dehydration, heat exhaustion and heat stroke if not properly hydrated.
The PE developed Projects OHS procedures during construction, which will be revised and updated for the 6 projects for the operation phase per the ESAP. These procedures will cover the following issues: hazard identification and assessment and the operation site safety (access control, clear demarcation of areas and provision of safety information to visitors); specific procedures for hazardous works; workers’ safety and training plan; personal protective equipment needs; site supervision and audit procedures; incident intervention measures and reporting. The procedures will be specific to the PV solar sector (in terms of industry-specific hazards) and the project. The OHS procedure will also link with the project’s EPRP which will include fire risk assessment and control systems, fire alarm systems and drills, emergency preparedness and planning. The project’s OHS performance will be tracked, recorded and reported to the PE on a regular basis and to MIGA on an annual basis.
The PE has also established and implemented the global Plant Safety Regulations (PSR) and Operating Regulations for High Voltage Systems (ORVHS) to ensure safe operations of plant equipment. The ORVHS training program has been put in place to train employees (on-the-job) to safely work on critical plant equipment, particularly electrical switching. The Control Officer is responsible for overseeing all electrical switching operations.
For the driving related risks, the PE will ensure that vehicles are checked regularly, and defensive driving training is provided to all drivers in accordance with the Projects EHSS plan. The minimum PPE requirements on site include helmets, reflective vests, safety shoes and goggle. Other PPE (Gloves and masks) are available for workers as requested.
Prior to construction, the PE conducted a supply chain assessment of the nominated primary PV supplier to identify key E&S risks/impacts and ensure that the supplier complies with the principles of good international industry practice to appropriately manage these risks. The assessment confirmed the adequacy of the manufacturing facility’s management of hazardous material storage, waste storage/disposal, compliance with working conditions and occupational and community health and safety requirements in line with international requirements. Scatec solar ASA(SSO) and its subsidiaries (“Scatec Solar Group”) developed supplier conduct principles reflecting the SSO’s basic values and selected principles including complying with laws, safeguarding the environment, health and safety, prohibition of forced and child labor, human rights and working hours and corruption prohibition etc. The SSO ensures that all their suppliers sign and adhere with these principles.
PS3: Resource Efficiency and Pollution Prevention
Resource consumption for the 6 Projects is expected to be minimal, with the main resource utilized during construction being water for dust suppression, concrete production, and domestic usage. During operations, the main water use will be for cleaning the PV modules and domestic usage.
The estimated water consumed during the construction phase was approximately 4,320 m3 per year for the 6 Projects (720 m3 for each Project) which includes site activities and civil activities (concrete production, equipment cleaning, dust suppression and sanitary purposes). The estimated water required for 6 Projects during the O&M phase for activities and sanitary purposes will be 7,200 m3/ year (1,200 m3/year for each Project) for panel cleaning and approximately 500-700m3/year for general sanitarian use, which will be supplied by trucks and stored in tanks located close to sanitary and welfare facilities. Wet cleaning technology will be used to ensure that dust and other particles accumulated on the panels do not compromise the efficiency of the PV facility and the cleaning will be a combination of semi-automated cleaning (brushes) for the front PV Panels and manual cleaning (two cycles per year) for the back side of the PV panel. The industrial and potable water are sourced from the New Aswan water company, which has been approved and certified to supply water to the Project. Original receipts from water company are kept and logged (each water load entering the site is registered in cubic meters), and water use is closely tracked. The Projects uses bottled drinking water. For the operation phase, the PE will develop a common water management plan for the 6 Projects which will include water quantity estimates and reporting of water use per the ESAP.
Greenhouse gas emissions savings from the projects during operations are expected to be approximately 400,000 tons of carbon dioxide per year (tCO2e/yr). During operations, emissions are expected from the use of back-up generators, transport, on-site equipment, and machinery. Although the emissions have not been calculated, these are expected to be below 25,000 tonnes CO2e per year.
Solid and Hazardous Waste Management:
During operations, waste generated will be largely limited to domestic waste, and waste generated from maintenance. These wastes will be collected, segregated (in closable containers) and disposed of by the FMC mainly through recycling and possibly landfilling in a designated site in Aswan. Hazardous materials will be stored in a dedicated area and handled with care. A register will be maintained, and Material Safety Data Sheets displayed in Arabic and English. The overall volumes of both solid and hazardous waste generated by the Projects during operations are expected to be low. For the operation phase, PE will develop a common waste management plan for the 6 projects in line with MIGA PS 3 requirements and aligned with FMC waste management requirements per the ESAP. PE have stored all the broken modules from the construction phase on the sites as they discuss with FMC and other recycling companies the disposal mechanisms that meets Egyptian laws and the lenders requirements. PE will develop a procedure for managing the disposal of broken and ‘end of life’ modules, which will be in line with MIGA PS 3 requirements, Egyptian laws and FMC requirements per the ESAP.
During operations phase, wastewater from sanitary facilities will be stored in suitable septic tanks and transported off-site. The FMC will have the overall responsibility for the management, collection and disposal contracts for sewage and other wastewater from the Benban Solar Complex. Management of wastewater will be addressed in the waste management plan.
During operations, backup diesel generators and vehicles (e.g. passenger cars, light trucks and cleaning tractor) will be the main sources of air and noise emissions. Fuel use and storage will also need to be appropriately managed. The PE will be required to have a generator management plan that defines fuel use, regular maintenance and provision of adequate measures for air quality (such as the use of air filters), noise control and waste management. The PE will implement the Projects environmental management plans and/or procedures to effectively manage pollution related aspects of the Projects in line with the WBG’s EHS Guidelines.
PS4: Community Health, Safety and Security
The Scatec Projects are located on desert land which is owned by the NREA and Projects access is along the newly constructed NREA roads from the local public highway. There will be no road or land impacts on the local villages, and there are no stakeholders directly affected by the project.
Community Health and Safety:
For the operations phase it is expected that there will be minimal community health and safety issues. However, the PE will be required to implement fully the community health and safety plan and the worker’s code of conduct developed during construction which will also apply to all sub-contractors to ensure they maintain high standards within the community and meet the requirements of PS4.
The Projects traffic will need to be coordinated with the BDA and FMC and aligned with the FMC’s traffic management plan to ensure that risks to workers and community members are mitigated. As such, a Projects will continue to implement the traffic management plan developed during construction, which is aligned with the FMC’s overarching traffic management plan.
For the operation phase, the PE is finalizing a security contract with a private security company that will provide security services for the project. The Projects will utilize 24-hour security guards (3 shifts), CCTV cameras for intrusion detection and have only a single controlled entry. To ensure alignment with MIGA performance standard requirements, the PE will conduct screening to ensure that the private security provider’s team are not implicated in past abuses; will train them adequately in the use of force, and appropriate conduct toward workers and nearby communities; and require them to act within the applicable law.
The FMC is responsible for the security of the Benban Solar Complex and have developed a security management plan for the Benban Solar Complex in line with MIGA requirements. The PE will update and develop a common security management plan for the 6 projects that captures key elements of PS 4 and is aligned with FMC’s security management plan for the operations phase per the ESAP.
Environmental Permitting Process:
The Egyptian Environmental Affairs Agency (EEAA) is the primary regulatory body responsible for environmental matters in Egypt and operates in accordance with the Law of Protection of the Environment (Law No. 4, 1994) and its executive regulations established by Prime Minister Decree no. 338/1995. The national law for environment requires that an EIA be completed and submitted to the competent administrative authorities (CAA) which in the case of PV power plants is NREA.
The EEAA categorizes projects in accordance with the predicted environmental impacts in the form of:
- Category A: projects with minor environmental impacts
- Category B: projects which may have substantial impacts and require a scoped EIA
- Category C: projects which require a full EIA due to their potential severe impacts.
PV power plants are generally categorized as B (requiring an abbreviated environmental approval process), however EEAA has the authority, depending on the scale of the Projects to request a more detailed assessment and to classify it as category C (requiring an ESIA and Public Consultation meeting). In consultation with EEAA, NREA reached an agreement with EEAA to conduct an overall SESA study for the Benban Solar Complex that meets the requirements of C category projects. All individual power plants were considered as components under the SESA and were required to submit Form B which is a scoped ESIA with project/plot specific information to the EEAA. The approval of the Form B, together with the SESA approval, constitute the Environmental Permit required for the project. The 6 Projects prepared the Form B ESIA and it was approved by EEAA as follows:
- Aswan – Form B ESIA prepared on April 2016 and EEAA approved on June 13, 2016
- Daraw – Form B ESIA prepared on May 2016 and EEAA approved on June 23, 2016
- Upper Egypt – Form B ESIA prepared on April 2016 and EEAA approved on June 22, 2016
- Kom Ombo – Form B ESIA prepared on April 2016 and EEAA approved on June 13, 2016
- Red Sea – Form B ESIA prepared on April 2016 and EEAA approved on July13, 2017
- Zafarana – Form B ESIA prepared on June 2016 and EEAA approved on August 28, 2016
BCS for this project will not be required as FMC conducted the BCSs for the Benban Solar Complex on behalf pf the developers prior to the Projects Constructions.
The documentation listed below is available electronically as PDF attachments to this ESRS at www.miga.org.
- Strategic Environmental and Social Assessment – Benban 1.8 GW photovoltaic solar park (NREA), Egypt (Eco Con Serv, February 2016)
- Environmental and Social Impact Assessment for Aswan PV Power SAE 50 MW(AC) in Benban, Aswan (Environics, April 2016)
- Environmental and Social Impact Assessment for Kom Ombo Renewable Energy SAE 50 MW(AC) in Benban, Aswan (Environics, April 2016)
- Environmental and Social Impact Assessment for Red Sea Solar Power S.A.E. 50 MW(AC) in Benban, Aswan (Environics, April 2016)
- Environmental and Social Impact Assessment for Upper Egypt Solar Power SAE 50 MW(AC) in Benban, Aswan (Environics, April 2016)
- Environmental and Social Impact Assessment for Daraw Solar Power S.A.E 50 MW(AC) in Benban, Aswan (Environics, May 2016)
- Environmental and Social Impact Assessment for Zafarana Solar Power S.A.E 50 MW(AC) in Benban, Aswan (June 2016)
- Environmental and Social Action Plan
- Hydrological Study Benban Park
The documentation is also available for viewing at the following locations:
23, Sobhy Fahmy St., Ard El Golf,
Heliopolis, Cairo 11341 - Egypt
For additional information, please contact:
- Mohamed Taha -Mohamed.Taha@scatecsolar.com
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