Sidi Bouzid II Solar PV

MIGA guarantee has been requested to provide political risk insurance to cover the equity, shareholder loans, and/or quasi equity investments of Aeolus SAS (France), and/or any of the group companies; and any other investor yet-to-be identified (the Guarantee Holder) with an guarantee amount up to €14.25 million for a period up to 20 years against the risks of War and Civil Disturbance (WCD), Expropriation (EXP), Transfer Restriction (TR) and Breach of Contract (BoC). 

The Project entails build-own-and-operate (BOO) of a 100MW grid-connected solar power plant in Mezzouna delegation of Sidi Bouzid governorate, c. 260 kilometer south of Tunis (the Project) and adjacent to the first 50MW grid-connected Sidi Bouzid solar plant being developed jointly by Aeolus SAS and Scatec ASA, also supported by MIGA (click here to learn more about the MIGA guarantees issued to Aeolus SAS for their investments in  the 50MW grid-connected Tozeur and Sidi Bouzid 1 solar projects in Tunisia). The Project comprises two main components: (i) a photovoltaic (PV) plant including solar modules, a tracking system, inverter stations, step-up transformer station and associated facilities for power generation; and (ii) a high-voltage (HV) infrastructure consisting of a 12-kilometer 225kV overhead transmission line, a bay extension at the STEG Mezzouna 1 substation, and the upgrade of the existing STEG Meknassy substation — with all HV infrastructure to be transferred to the Tunisian Company of Electricity and Gas (STEG) upon commercial operation. The Project is being developed jointly by Scatec/Aeolus and is expected to be financed by EBRD and EIB. Project Enterprise (PE) was established in August 2025.  

The 180-hectare land required for the PV plot will essentially be used for the installation of solar panels and trackers. The other infrastructures that will be built in the PV land plot include electric equipment, roads, operation & maintenance buildings, a substation, laydown area, a security guards’ building/kiosk at the entrance and a fence around the PV plant. 

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. 

Key Environmental and Social (E&S) issues associated with this Project relate to land acquisition process, biodiversity conservation, stakeholders’ engagement, water use, labor influx and workers accommodations, labor and working conditions, security management, solar panels supply chain, and community health and safety. There are also contextual, and project specific risks related to Gender Based Violence (GBV). These risks will be assessed against MIGA’s Performance Standards and relevant World Bank Group Environmental and Health and Safety Guidelines.  

Aeolus is a repeat MIGA’s client. Most recently in August 2024, MIGA issued political risk guarantees to two solar projects in Tunisia, including the 50MW Sidi Bouzid 1 project adjacent to the Sidi Bouzid 2, and the 50MW Tozeur project. MIGA E&S specialist conducted a site visit to Sidi Bouzid 1 and Tozeur. Almost all the E&S Management Plans (ESMPs), procedures, and policies developed for Sidi Bouzid 1 will be relevant for Sidi Bouzid 2. Sidi Bouzid 1 and Tozeur projects are currently under construction, and agreed ESAP are being implemented for these previous transactions. 

MIGA’s due diligence review considered the E&S management planning process and documentation for the Project and identified gaps (if any) between these and MIGA’s requirements. Where necessary, corrective measures intended to close these gaps within a reasonable time 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 the Performance Standards. 

Key potential environmental and social (E&S) issues associated with the Project 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:  

Aeolus’ consortium partner, Scatec, is also a repeat MIGA client which has an Environmental and Social Management System (ESMS) and Occupational Health and Safety Management Systems (OHSMS) which are certified ISO 14001:2015 (environmental management) and ISO 45001:2015 (occupational health & safety management). These certifications cover a large scope: the planning, design, engineering, construction, leasing, operation and maintenance of solar plant installations and storage solutions globally.   

The PE will develop a Project-specific ESMS and OHSMS manuals covering both the construction and operation stages, which will specify compliance with applicable E&S laws and MIGA PSs and which is suitable to be inserted into the tender documents (ESAP item). The ESMS will include the following elements: (i) policy; (ii) identification of risks and impacts; (iii) management programs; (iv) organizational capacity and competency; (v) emergency preparedness and response; (vi) stakeholder engagement (including grievance management); (vii) monitoring and review, and (viii) contractor management. The main elements that make up the OHSMS Manual or Health Safety Security and Environment Plan (HSSE Program) will include amongst others (i) an HSSE Key Performance Indicator (KPI) reporting and statistical analysis system; an incident reporting and investigation process; (ii) training, competence, and communication programs; (iii) working at height and fall protection plans; (iv) health management protocols, and procedures for managing climate and extreme weather conditions; (v) a fatigue management plan; (vi) working at night procedures; (vii) measures for managing contractors and subcontractors' HSSE performance and ensuring their alignment with program requirements; (viii) regular internal and external audits to evaluate the effectiveness of the HSSE Program and identify areas for improvement.   

The PE will ensure that the Project E&S standards and MIGA’s E&S requirements (including the agreed ESAP) are cascaded in legal agreement with the Engineering Procurement & Construction (EPC) contractor (ESAP item). The EPC contractor will design and implement  a set of distinct yet harmonized and compliant management plans—such as, but not limited to, the Occupational Health & Safety Plan, Environmental Management Plan, Labor Management Plan, Community Health & Safety Plan, Human Resources Policies, Traffic and Transport Management Plan, for the construction stage and that are aligned with the Project’s requirements, Tunisian laws, MIGA’s PSs and WBG EHS guidelines (ESAP item). 

Policy: 

The Scatec corporate’s Sustainability (April 2025) and, Health, Safety, Security & Environment (HSSE, September 2024) policies set out the company’s commitment to sustainability and to achieve zero harm, including protecting the environment and contributing to local communities. They also describe commitments to provide a safe workplace, transparent governance, compliance with laws and regulations and adhering to the requirements of the PSs in all projects. At corporate level, Scatec has a Diversity, Equity, Inclusion and Belonging (DEIB) policy (May 2025) which applies to all employees, managers, and consultants of Scatec, including subsidiaries and affiliates, and which highlights that Scatec is committed to a safe workplace with equal opportunities for all, free from any discrimination, bullying or harassment. The DEIB policy also includes a zero-tolerance approach for any form of sexual harassment in the workplace, where all complaints of sexual harassment will be taken seriously and treated with respect and in confidence, and no one will be victimized for making such a complaint. 

Identification of Risks and Impacts:  

Power projects of less than 300 MW installed capacity do not require an environmental permit under the Tunisian Legislation. The transmission lines that will connect the PV plants to the grid also do not require an environmental permit under the Tunisian Legislation (Decree n° 2005 - 1991 of July 11, 2005). Therefore, this Project is not subject to an environmental and social impact assessment (ESIA) or to mandatory information disclosure.  

However, as part of the bidding process for the award of solar concessions by Tunisian authorities, Scatec hired an E&S consultant to draft a preliminary ESIA for the PV plant’s component of the Project (in May 2024 and updated in February 2025). An Environmental and Social Action Plan (ESAP), a Non-Technical Summary and a Stakeholder Engagement Plan (SEP) were also developed by the LESA in parallel to their E&SDD report. Terms of Reference are also being developed for a Land Acquisition and Livelihood Restoration Framework as the preliminary ESIA and the LESA reports identified potential limited economic displacement but no physical displacement (more detail in PS5 section). 

Management Programs:   

In addition to its own environmental and social management plans (ESMP), Occupational Health and Safety Management Plans (OHSMP) and procedures, the PE will require the EPC contractor to develop Construction ESMP and OHSMP. The PE will review and approve required management plans prior construction (ESAP item). These plans and procedures will include but not be limited to: waste management; pollution prevention (including emissions, spill response); water management (including supply, treatment, disposal); hazardous materials; emergency preparedness and response; community health, safety and security; road safety and traffic management; accommodation management; local recruitment and labor management; influx management; environmental monitoring plan; stakeholder engagement (including grievance management); chance find procedure, pylon routing procedure, workers grievance redress mechanism, and  GBV. The management plans include details on monitoring actions, and the frequency of monitoring, along with the performance indicators and the responsible entity.  

Organizational Capacity: 

For its ongoing projects in Tunisia, Scatec has recently put in place an E&S structure in country inclusive of an E&S Manager which oversees the existing two projects, an Occupational Health and Safety (OHS) Manager, and a Community Liaison Officer (CLO) for each site. The E&S Manager reports directly on E&S matters to the Corporate Director of E&S Advisory based at the headquarter in Oslo (Norway), and has overall responsibility for the project’s E&S management. For this Project, a similar approach will be used, and the PE will mobilize a dedicated CLO and OHS manager (ESAP item). The E&S and OHS Managers who are based in Tunisia, directly report to Sustainability and HSSE functional lines and to the Project Manager. 

The E&S and OHS Managers will be responsible for the development and implementation of the Project ESMS and OHSMS, and related plans and procedures including monitoring and reporting. They will also oversee the ESAP implementation. The CLO will support land acquisition related actions and social risks management including the implementation of the SEP and the management of the external Grievance Redress Mechanism (GRM). The PE will also ensure that the EPC contractor has required capacity including E&S and OHS staff to ensure a proper implementation of requirements (ESAP item). 

Emergency Preparedness and Response:   

As part of its HSSE Policy, Scatec is committed to ensure effective emergency and recovery management for people, environment and assets against unplanned events and disasters. The Scatec Emergency Response Procedure defines three tiers of emergency response management, grouped as: 1st Line, the local site or plant level, 2nd Line, the regional or country specific level and 3rd Line, global incident crisis management support. In line with this commitment the PE will develop a 1st Line Emergency Response Plan (ERP) (ESAP item).   

The 1st Line ERP details emergency preparedness and response protocols in the event of emergency situations. It will reflect emergency scenarios determined by the project risk assessment, but typically include emergency evacuation, fire/explosion, medical emergencies, pandemic outbreaks, security, terrorism or bomb threats, floods, transportation and vehicle related accidents, prolonged power outage, severe weather/storms, hazardous material spills and civil unrest and earthquakes. The ERP will cover both the construction and the operation phase of the Project and will outline (i) Accident and emergency risk identification and management;(ii) Emergency response procedures; (iii) Liaison with local emergency authorities; (iv) Engagement with communities on incidents and emergencies; (v)Specific response procedures for key risks; (vi) Emergency response training; (vii) Snakes and scorpions bite prevention procedure; and (viii) Record keeping on emergency response procedures and incidents.  

Monitoring and Review:    

The PE will provide effective oversight of the EPC Contractors’ management of E&S risks and impacts in accordance with the Contractor Management Plan and check that ESAP items and the mitigation measures included in the ESMP are being implemented adequately. This must include a schedule of audits and inspections, including worker accommodation facilities (ESAP item).  

As a condition of MIGA’s contract of guarantee, the PE will be required to provide MIGA with an Annual Monitoring Report that evaluates E&S performance against MIGA’s E&S requirements and will include sections on E&S risks and impacts, updates on development effectiveness indicators throughout the guarantee period.  

Stakeholder engagement:   

A SEP has been developed as a result of the E&SDD process. It presents the planned stakeholder engagement activities for the project and outlines a systematic approach aimed at developing and maintaining transparent relationships with stakeholders throughout the Project’s lifetimes. The PE will implement the SEP and update it regularly to ensure it reflects the current status of the Project and addresses all stakeholder engagement needs (ESAP item). 

External Communication and Grievance Mechanisms: 

Per its existing projects in Tunisia, Scatec already has a GRM available in French and Arabic, consistent with MIGA’s PS 1 requirements, so that stakeholders can raise any concern, provide feedback and comments about the Project. All grievances are registered and acknowledged within 5 working days and responded to within 20 working days of receiving the grievance. Individuals who submit their comments or grievances have the right to request that their name be kept confidential. This mechanism does not limit the public’s rights to use conventional routes to place grievances and the available legal system. 

Scatec has a website where general information about the company and its activities can be found. The website is in English only: https://scatec.com/. The Scatec whistleblower is also available through this website and allows confidential grievance in order to prevent retaliation risks. The PE will include its current GRM forms and digital tools in the Project specific SEP and maintain records of grievances by category and status (open, closed, escalated to the court, etc.) (ESAP item).  

Ongoing Reporting to Affected Communities: 

The engagement process is a continuous dialogue carried out on an on-going basis throughout the Project’s cycles. It enables the inclusion of all relevant views of stakeholders into decision-making and Project implementation. The SEP is a living document and is meant to be updated and developed further as the Project progress, particularly before the operations phase. The E&S manager will oversee the implementation of the SEP. The manager will regularly update the SEP and will provide information, collect feedback, as well as provide answers to incoming communications (via email, telephone or in person). To provide ongoing general information about the Project, the information disclosure methods identified in the SEP also include the creation of Facebook pages in local languages.  

PS 2: Labor and Working Conditions   

The Project is expected to employ up to 400 workers at the peak of the 15-month construction phase, of which 40 would be skilled and 360 unskilled workers. The operation phase will require no more than 20 workers, with a few highly qualified staff (technicians, engineers – typically less than 5 full time) and some unqualified for housekeeping, cleaning, and security. Scatec Solar Tunisia Construction SARL and Scatec Solar Tunisia Operation SARL, both fully owned subsidiaries of Scatec, will be the main employers.  

There are high expectations of employment opportunities amongst the local communities; therefore, the PE will collaborate with the EPC contractors, and the local authorities to ensure that recruitment from these communities is maximized and equitable to the extent possible. The PE will design and implement a Labour Management Plan and a transparent procedure for the recruitment of local workers by Scatec Solar Tunisia Construction SARL and its subcontractors and consult the local authorities and employment bureau before finalizing the procedure and implementing it (ESAP item). 

In addition to the corporate whistleblower tool, Scatec employees at the Tunisian projects have access to the company’s grievance mechanism available in five foreign languages, including Arabic and aligned with MIGA’s PS 2 requirements. Considering the increasing number of the PE’s direct employees during the operation phase and in order to ensure broader accessibility to its internal grievance system, the PE will be required to develop and implement a workers grievance mechanism, meeting PS2 requirements, for the operation activities under its control (ESAP item). The PE will also require its contractors to develop a grievance mechanism available to their workers and their sub-contractors and monitor its effectiveness and ensure that workers are informed of their right to resort to Scatec’s grievance mechanism (for communities and all stakeholders) in case their concerns are not satisfactorily handled (ESAP item). 

Working Conditions and Management of Worker Relationship:  

The Project will ensure that all employee contracts are consistent with Tunisian labor codes and MIGA PS2 

requirements. The PE will be required to ensure that (i) all employees (including those employed by contractors and subcontractors) will be provided with a contract and HR policies in French/Arabic, stipulating their terms of employment, working conditions (including health and safety requirements), wages and benefits, hours of work, overtime arrangements and overtime compensation, annual and sick leave, vacation, holidays as well as other leaves stipulated by national legislation; (ii) contracts of the construction phase workers shall have a clear description of the short-term nature of the project and provide an indication of the potential employment duration; (iii) during induction training, the new hires are made aware of the terms and conditions of their employment, including the HR policy, DEIB policy and Code of Conduct, as part of the hiring package (ESAP item).  

The global HR policy (October 2024) states that Scatec is also an equal opportunity employer which does not discriminate against any candidate or employee based on color, race, nationality, ethnic or national origins, sex, age, gender reassignment, sexual orientation, pregnancy, and maternity, marriage, and civil partnerships, pay, religion or belief, political belief, part-time work, fixed-term work, marital status, or disability. The PE will be required to design, build, and operate the Project with a work environment that is suitable for both men and women (notably with separate toilets and change/rest rooms) and specifying on job announcement that positions are open to both men and women (ESAP item). 

Scatec has also global Code of Conduct (July 2025), which applies to all employees, contractors, and subcontractors, includes rules of interaction with customers and communities and reflect respect for local beliefs and customs. In addition, the Code of Conduct includes provisions related to protection of personal data and privacy, prohibition of all forms of slavery, forced labor, human trafficking, child labor and violations of human rights, corruption, and bribery. Scatec is also drug-free workspace, and alcohol consumption is not permitted when operating machinery, driving or being on-site. Anyone who violates this Code may face disciplinary sanctions which can include termination of employment and the involvement of relevant authorities. Scatec also has a Human Rights policy (March 2024) which is made available at the company website. Scatec require all its employees and hired contractors to comply with this policy and commits to offer necessary capacity building and training to this end. 

Tunisia has ratified the International Labor Organization (ILO) Convention concerning Freedom of Association and Protection of the Right to Organize and the Convention concerning the Application of the Principles of the Right to Organize and to Bargain Collectively. Trade union pluralism is also a constitutional right in Tunisia. In addition, Scatec’s Global HR Policy (October 2024) acknowledges freedom of association and collective bargaining as a labor right of all employees. Scatec’s employees have the right to join labor unions or form workers’ organizations with the aim of engaging the Company on common issues and conclude a collective agreement. 

The EPC staff will be housed in the same workers’ camp that was used for the Sidi Bouzid 1 project. .The camp is located approximately 20 km from the Sidi Bouzid 2 Project.  This accommodation will be required to be compliant with the IFC/EBRD Guidance Note on Workers’ Accommodation: Process and Standards. EPC contractors and subcontractors typically rent houses in nearby towns for their permanent and skilled staff (as there are no hotels near the project area). All accommodation facilities, including rented houses, will be subject to monthly inspections by the PE to ensure compliance with MIGA PS 2  requirements (ESAP item). Unskilled labor will be locally hired and will commute daily from their homes. The PE will develop a transportation management plan assessing and addressing the risks associated with workers commuting to and from the worksite (ESAP item). 

Protecting the Work Force:  

Tunisia has ratified the ILO Convention concerning Minimum Age for Admission to Employment. According to the Tunisian labor code: “the minimum age for admission to any type of work likely, by its nature or the circumstances in which it is executed, to expose the health, safety or morals of children, cannot be less than 18 years.” The Scatec Global HR Policy (October 2024) also prohibits the use of any form of forced or compulsory labor, and Scatec is committed to neither employ any person who is below 18 years of age nor utilize any products produced with child (persons under 18 years of age) labor. Scatec is also committed to conduct business only with third parties that follow the same ethical and human rights standards. All employees are required to provide their national identification document highlighting their birth date before their employment. 

Occupational Health and Safety:   

During the construction phase of the Project, key risks, and impacts include health and safety (H&S) risks intrinsic to construction activities such as physical hazards related to the installation of poles, working at heights, and electrical components including exposure to live electrical current, slips and falls, potential hazards from on-site moving machinery, heavy load lifting, exposure to electric shocks and burns, and safety issues related to panels module assembly. During operations, key environmental and social risks include waste management, dust emission, site security and access control, road safety, external and internal grievances management. 

Workers Engaged by Third Parties: 

The PE will conduct  internal audits of contractors staff and accommodations (monthly during construction, then twice a year during operation) to verify that people working on activities under Scatec control are legally hired as per the Tunisian legislation, and to ensure compliance with MIGA’s PS 2 requirements. (ESAP item). 

Supply Chain:  

According to their corporate Procurement Framework disclosed on their website and to be signed by the Suppliers, Scatec expects "all vendors to act in accordance and demonstrate compliance with their Supplier Conduct Principles (April 2025)", which includes the requirement to conduct business consistently with the UN Guiding Principles on Business and Human Rights, including the elimination of all forms of forced and compulsory labor and effective abolition of child labor.  

The PE will be required to (i) conduct a supply chain risk assessment of the nominated primary solar suppliers and develop supply chain risk assessment procedure and a screening mechanism against risks for alleged forced labor in the solar supply chain; and  (ii) incorporate or require the EPC Contractor to incorporate the provisions related to child labor and forced labor in each contractual agreement it or the EPC contractor enters into with a solar supplier (ESAP item). 

PS3: Resource Efficiency and Pollution Prevention   

Resource Efficiency: 

The main water requirement during construction is likely to be water for dust suppression, concrete production, minor concrete batching will be required for the substation, control and administration buildings, and domestic use.  

Water requirements during the operation phase will be largely focused on panel cleaning. However, a waterless cleaning solution must be preferred. If this is not the case, the PE will submit to MIGA’s approval a "best available technology" study comparing waterless and with- water solutions from a technico- economic and E&S perspective. Only renewable water sources should be envisaged (not fossil aquifers) and hydrogeological study and water mass balance should be included to confirm the absence of water use competition with local agricultural or community needs, taking into account climate change (ESAP item).  

The PE will develop and implement a Water Management Plan for construction and operation, which will include measures for efficient water use/water minimization as part of the cleaning needs for panels and for general use as well as monitoring procedures of water supply services. Water use will be a KPI, and the PE will keep track of water usage (ESAP item). 

GHG emissions during the construction and operations phase are expected to be predominantly associated with the use of fuels for vehicles and machinery. The total annual GHG emissions has not been estimated yet but is significantly less than 25,000 tons CO2e.  

Pollution prevention:    

It is anticipated that the Project will produce both non-hazardous wastes, such as paper, wood, plastic, scrap metals and glass, and a limited quantity of potentially hazardous materials such as transformer oils, paints, batteries, as well as some electronic waste, and used PV panels. Pollution of water resources may arise at construction sites due to accidental spillage or leakage of polluting materials (fuel, paints, chemicals, hazardous waste).   

The PE will also develop a waste management plan (including for broken and used solar panels) in line with good international industry practices (GIIP), national laws and MIGA’s PS 3 requirement, and include provisions to ensure hazardous waste contractors are licensed from the local relevant authority (ESAP item).  

The PE will require the EPC contractor to develop and implement Pollution Prevention and Control Plan including dust suppression measures, speed restriction, regular maintenance of machinery and equipment, implementation of erosion control measures, an oil spill prevention and management procedure, providing spill and leak cleanup material and equipment (ESAP item). The PE will also ban the use of herbicides or pesticides during the construction and operation period, in particular for vegetation control, and include this ban in the contractors’ contracts (ESAP item). 

PS4: Community Health, Safety and Security   

Community health and safety:    

During construction, potential community health and safety risks and issues include workers influx, dust emission, increased traffic, noise vibration and increased construction trucks in the area. During operations, potential risks include structural and site access issues, road traffic accidents, fire and safety issues, oil spillages, accidents, and electrical faults. Risks are minimized by restricting access to the sites and to equipment through 24-hour security. Sites are fitted with fire extinguishers and security guards are trained in their use.  Power lines, transformers and components are designed and installed according to GIIP, considering the potential frequency and magnitude of natural hazards.  

Any accommodation of workers by the company or its contractors will need to meet the requirements of IFC/EBRD’s guidance note Worker Accommodation: Process and Standards. The PE will require the EPC contractor to design and implement a Community Health and Safety Management Plan under its HSSE Management Program. This will include an assessment of worker influx and will include: (i) a communicable disease (including HIV/AIDS and sexually transmitted infections) awareness and prevention program for site workers as well as local communities; (ii) requirements for adequate on-site medical facilities; (; (iii) Prevention and control of tensions and conflict between the labour force and communities, including GBV and harassment ; (iv) provisions for periodical monitoring of social related effects of the influx of migrants; (v) provision of construction schedule and description of community risks to the governorates and communities; (vi) installation of fences and safety and danger warning signage at the construction sites and operational sites; (vii) emergency drills involving the communities (ESAP item).  

Security Personnel:   

A permanent fence will be erected around the perimeter of the site. Security and access control to the site will be provided on a 24-hour basis during both construction and operations.  

The PE will (i) conduct a Security Risk Assessment, (ii) develop and implement a Security Management Plan, including security personnel code of conduct, for the construction and operations phases (including site access control and register) in line with MIGA’s PS4 including IFC’s “Good Practice Handbook on the Use of Security Forces: Assessing and Managing Risks and Impacts”, and (iii) undertake regular audits of the established security provisions as part of the established monitoring and reporting requirements described in PS1 (ESAP item).  

PS5: Land acquisition and Involuntary resettlement 

General: 

The solar PV plant will be carried out on uncultivated and un-inhabited land. This land is under private ownership and covers an area of 305 hectares (13 land titles, ten landowners), of which only 180 hectares will be used for the project. The land is being leased to the landowners under a willing lease, willing lessor arrangement. A Promise to Lease Agreements were signed on April 2023 and July 2025 between the landowners and the PE. The Promise to Lease Agreement will be converted to Lease agreement after securing the Governor authorization.  

A 12 km 225 kV high-voltage overhead transmission line (OHTL) will be constructed and intersects mostly state-owned land over approximately 7 km, the remainder crossing approximately privately owned 19 plots.  

Potentially affected land users include sedentary farmers, cultivating seasonal or perennial crops, and seasonal livestock herders, using private or public land—sometimes informally—for grazing. 

Displacement: 

There will be no physical displacement because of this Project. However, as detailed above, there will potentially be limited economic displacement as result of the Project.  

The PV plant does not require any physical resettlement; however, access restriction and economic displacement may occur due to potential loss of occasional grazing areas, and potential loss of seasonal farming activities. The single herder identified as utilizing the PV plant site owns approximately 300 sheep and goats and employs two additional workers to support his herding activities. A grazing area of 1500 hectares called Hamila, is in the near vicinity and several families settle there for weeks with their herd for grazing. 

The PV plant area will be divided into three non-contiguous sections. Two main access roads will remain unfenced and fully accessible, ensuring continued access for nearby households. However, minor agricultural tracks will be closed off once the perimeter fencing is installed. 

The OHTL does not require any physical resettlement, but potential economic displacement may result from damage to trees and crops (e.g., almond, olive), temporary land use restrictions during construction, permanent access loss where pylons are located, long-term limitations within the 50 meters Right of Way (25 meters per side), prohibiting tall vegetation. The OHTL alignment was designed to avoid residential dwellings, only three homes are located near the route, the closest being over 105 meters from the line. Land use along the OHTL route includes open land (95.5%), olives and almond trees (2.3%), and vegetation planting (1.7%). The exact location of pylons is not yet known. The PE will ensure the EPC Contractor designs and implements a Pylon Routing Procedure, which shall prioritize avoidance and minimization of community and privately-owned land, including the location of the pylons at the edge of land parcels to minimize adverse impacts (ESAP item). 

The construction and operation of the Project may result in a loss of livelihood, and this will be confirmed during surveys conducted during the preparation of a future Land Acquisition and Livelihood Restoration Plan (LALRP). The PE will be required to develop and implement the LALRP in line with MIGA’s PS5 requirements (ESAP item). At the completion of land acquisition and compensation, the PE will audit the implemented LALRP and submit it to MIGA (ESAP item). 

Private Sector Responsibilities under Government-Managed Resettlement: 

Non applicable. The land acquisition process is totally led by the Project. 

PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources  

Both the PV solar plant site and the OHTL corridor occur within the Mediterranean woodlands and forests ecoregion. The project components are located in arid pre-Saharan steppe zones characterized by degraded vegetation, low plant cover (5–15%), and limited floristic diversity. Rapid biodiversity assessments were completed as part of lender E&SDD for both sites. Both PV solar plant site and the OHTL corridor are treated as a mix of modified habitat and degraded natural habitats that have been subjected to past agriculture and intensive grazing by livestock. The Project area does not qualify as Critical Habitat, as defined by MIGA PS6. There are no overlaps with legally protected areas or internationally recognized areas (e.g. Key Biodiversity Areas), though such sites do occur within a 2-5 kilometer radius: the Bouhedma National Park and Important Bird Areas (IBA) (~3.4 kilometer away), and the Sebkhet Ennaoual IBA & RAMSAR Site (~2.5 kilometer away). 

Potential impacts include habitat transformation, disturbance (e.g. lights and bats), accidental mortality of individual species (e.g. reptiles) during construction, and potential for bird collisions, where the OHTL passes between and nearby to the IBAs with nearest IBA.  

Based on a review of currently available information, exiting and known development projects in the delegation of Mezzouna include the STEG OHTL between Bouchema and Meknassy and the solar PV project (PV Plant Khobna – Qair, 198 MW) including 45 kilometer transmission line that runs parallel to the project’s 12 kilometer OHTL and lies at approximately 2 kilometer from it. Cumulative impacts are plausible and may exacerbate potential adverse impacts on avifauna including migratory birds, in addition to issues related with increased road traffic, habitat fragmentation, access restriction to certain grazing areas, and increased pressure on local water use. While the current transmission line route has been confirmed as the most sustainable and final option following the assessment of potential cumulative impacts by the LESA and engagement with STEG, the PE is  required to engage with a local BirdLife partner to consult on appropriate mitigations measures, and to allocate the necessary resources for the preparation and implementation of the Biodiversity Management Plan (BMP), including a section addressing the management of cumulative biodiversity impacts, taking into account the final routing of the planned OHTL in the Mezzouna area. The BMP will propose actions and timelines for mitigating risks to biodiversity aligned with the lenders E&SDD recommendations including i) mitigation of OHTL risks in the proximity of IBAs, including with Bird Flight Diverters, following industry standard designs and spacing; ii) completion of required surveys prior to construction; iii) collection and relocation of reptiles from the construction site prior to land clearing; iv) regular bird mortality monitoring at the operational phase especially during the nesting and migration seasons; v) compliance with national law with respect to risks related to nationally protected species; vi) proper site fencing that allows for reptile passage; vii) lighting management to avoid night habitat disturbance (ESAP item).  

PS8: Cultural Heritage 

There is no cultural heritage in the PV solar plant area. However, at three locations along the current OHTL route, antique pottery fragments and shards are found in fairly high density and variety, suggesting potential archaeological interest. During the LESA consultation with Khobna local community, the existence of an ancient cemetery located outside the boundary of the PV site (around 15 meter) was identified and not actively maintained or used for recent or ongoing cultural or religious practices. In line with the lenders E&SDD recommendations, the PE will (i) undertake a pre-construction archeology survey by the Tunisian National Heritage Institute (Institut National du Patrimoine)  at the pylon locations covering the area of ground physically disturbed (including any access routes) prior to the start of the works,  (ii) prepare a Chance Find Procedure before sites clearing; (iii) train workers on the nature of potential chance finds, and the way to manage them ; (iv) engage with local communities and relevant authorities to find the appropriate approach to protect the nearby cemetery from potential adverse impacts from the Project (ESAP item). 

The documentation listed below is available electronically as PDF attachments to this ESRS at www.miga.org.    

Project Contact Information: 

Contact: Maha Ben Hmidane 

Position: Director Scatec Tunisia 

E-mail: maha.ben.hmidane@scatec.com  
Address: 24 rue Lac Tanganyika, Les Berges du Lac 1, 1053 Tunis, Tunisia 

Broad Community Support is not applicable for this Project.  

----------------------------------------------  

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

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

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

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

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