Société de Production d’Energie Solaire de Ouagadougou SAS
Environmental and Social Review Summary
Nagréongo Solar Project, Burkina Faso
This Environmental and Social Review Summary (ESRS) is prepared by MIGA staff and disclosed prior to the date on which MIGA’s Board of Directors considers the proposed issuance of a Contract of Guarantee. Its purpose is to enhance the transparency of MIGA’s activities. This document should not be construed as presuming the outcome of the decision by MIGA’s Board of Directors. Board dates are estimates only.
Any documentation that is attached to this ESRS has been prepared by the project sponsor, and authorization has been given for public release. MIGA has reviewed the attached documentation as provided by the applicant, and considers it of adequate quality to be released to the public, but does not endorse the content.
MIGA has been asked to provide a guarantee for a period of up to twenty years to cover equity investments and shareholder loans provided by GreenYellow of France to Société de Production d’Energie Solaire de Ouagadougou SAS (the “Project Company”) for the development of the Nagréongo Solar Project (“the Project”).
The Project is developed by GreenYellow in cooperation with a local partner in Burkina Faso, Africa Energy Cooperation. GreenYellow is an Independent Power Producer and Energy Services Company based in France with current renewable energy assets in France, Brazil, Colombia, Thailand, Cambodia, Morocco, Senegal, Mauritius and Madagascar. A separate project company has been formed as special-purpose vehicle in Burkina Faso to develop and manage the Project.
The Project consists of the development, construction and operation of a greenfield photovoltaic (PV) solar power plant, including PV modules mounted on fixed tilt structures, inverters, step-up transformers, and supporting infrastructure such as maintenance buildings, control room and offices, and internal access roads. The installed capacity will be 30 Megawatt (MW) with an estimated yearly production of 49 Gigawatt hours (GWh).
The solar plant will be connected to the national power grid through an existing substation managed by the national utility SONABEL. A 21 kilometers (km) 33 kilovolt (kV) overhead transmission line will be constructed as part of the solar plant. Financing and construction of the transmission lines will be undertaken by the Project Company, and ownership transferred at commissioning to SONABEL which will then be responsible for operation and maintenance. The construction of the transmission line will be part of the Project, and once transferred to SONABEL for operation it will be considered an Associated Facility of the Project, as defined by the MIGA Performance Standards. In operations, the transmission line will be owned, operated and maintained by SONABEL, and the Project will have no control and only limited leverage over the management of its operation and maintenance.
The plant site is located approximately 3.5 km from the national road. As part of the Project, an access road will be built for the passage of construction vehicles and trucks.
Construction activities will include clearing of the site, the transport of equipment on site, the installation of photovoltaic solar modules and supporting inverters and transformers, electric meters, technical rooms, access roads, fences and a site security and surveillance system. During the operational phase, activities will be limited to daily monitoring, cleaning of modules as needed, maintenance of vegetation under and between modules, and maintenance of electrical components and the boundary fence.
GreenYellow will assume the role of EPC Contractor through one of its branches (GreenYellow SAS). GreenYellow will also assume the role of O&M Contractor. Construction is expected to start in 2020, and last around 12 months.
The Project is located on a 50 hectare (ha) plot in Nagréongo, 15 km south of the town of Ziniare, and around 30 km northeast of Ouagadougou. The area was previously partly used for cultivation, and collection of fruits and firewood.
MIGA has also been asked to provide guarantees covering investments for four other solar plants in Burkina Faso, disclosed under separate ESRS available on MIGAs website.
The Project is categorized as Category B according to MIGA’s Policy on Environmental and Social Sustainability (2013) because the potential adverse impacts are site-specific, largely reversible and readily addressed through mitigation measures. Key potential environmental and social (E&S) risks and impacts related to the Project are economic displacement and livelihood impacts; water management and use; contextual security risks; labor and community health and safety risks; and the implementation of environmental and social management system and procedures.
While all Performance Standards are applicable to this investment, based on our current information, the investment will have impacts which must be managed in a manner consistent with the following Performance Standards:
- PS1: Assessment and Management of Environmental and Social Risks and Impacts
- PS2: Labor and Working Conditions
- PS3: Resource Efficiency and Pollution Prevention
- PS4: Community Health, Safety and Security
- PS5: Land Acquisition and Involuntary Resettlement
The Project is located on heavily modified farmed and fallow land and there are no significant impacts related to biodiversity, thus PS6 Biodiversity Conservation and Sustainable Management of Living Natural Resources does not apply. There are no Indigenous Peoples within the Project area of influence, and therefore PS7 Indigenous Peoples does therefore not apply.
No sites of cultural / historical value were identified within the boundaries of the Project area, neither were any resources of heritage value identified. PS 8 Cultural Heritage does therefore not apply; however, a Chance Find Procedure will be developed and implemented under PS1.
In addition, the following World Bank Group Environmental, Health, and Safety (WBG EHS) Guidelines are applicable to the Project:
- General EHS Guidelines (2007)
- Sector specific guidelines for Electricity Transmission and Distribution (2007)
The following documents were reviewed by MIGA:
- Provisional Environmental Impact Assessment Study: Nagréongo Solar Plant. Engineering & Environment Services, March 2020.
- Environmental and Social Due Diligence: Nagréongo Solar. IBIS Consultants, March 2020.
- Draft Engineering, Procurement, and Construction Contract. November 2019.
- GreenYellow Health, Safety and Environment Policy and Standards. October 2019.
- GreenYellow Health, Safety and Environment Best Practises & Tools. November 2019.
- Compensation Principles and Social Responsibility Policy. OSIEC, February 2020.
- Security Management Plan, Nagréongo Solar. GreenYellow, April 2020.
- Draft Community Engagement Protocol, SPES and Nagreongo Commune (March 2020).
In addition to reviewing the above documents, MIGA conducted due diligence calls with the Project Company and its consultants. The lender’s E&S consultants carried out an E&S due diligence visit in February 2020 which included meetings with the Project Companies and consultants, E&S staff, and affected communities, as well as tours of the Project site.
MIGA’s due diligence review considered the environmental and social management planning process and documentation for the Project, and identified gaps (if any) between these and MIGA’s requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable 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 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
GreenYellow has a set of corporate Health, Safety and Environment (HSE) Policies in place, setting out the guiding principles and standards for HSE requirements, applicable to the Project and related infrastructure. The policy statement affirms the Company’s commitment to develop the Project in a safe and socially responsible manner, and is based on a set of standards including risk analysis, work site supervision, incident analysis, training, and management.
Identification of Risks and Impacts:
An Environmental and Social Impact Assessment study (ESIA) have been prepared for the Project, in accordance with local regulation and the requirements of the PSs. The ESIA is currently in draft stage and is conducted by EES and OSIEC, environmental consultancies based in Senegal, in cooperation with EDI, a local consulting firm.. The ESIA adequately identifies the potential risks and impacts of the proposed Project. The draft ESIA has been submitted to the local environmental authorities, and the final version will consider any comments resulting from the authorities’ review. The transmission line and access road are part of the scope for the ESIA study.
An Environmental and Social (E&S) Due Diligence of the Project and the ESIAs against the requirements of the PSs was commissioned by the lenders in February 2020 and conducted by IBIS, an international consulting firm. The main gaps identified by IBIS were related to establishment of management plans and compensation of project-affected persons without formal land titles. These gaps are being addressed by the Project Company, as further described below.
An assessment of security risks related to the Project has been completed by GreenYellow. The assessment concluded that security risks are fluid, but manageable, and regular re-assessment is required.
Potential cumulative impacts were considered in the ESIAs, which concluded that no material cumulative impacts are expected.
GreenYellow has a corporate wide Health, Safety and Environment Management System in place, certified according to ISO 14001, applicable to the Project.
The ESIA includes a framework for an Environmental and Social Management Plan (ESMP), which provide principles for preventing and mitigating environmental and social impacts, in both construction and operation phases. The Project Company has engaged a consultant to establish an Environmental and Social Management System (ESMS) for the Project (as per the ESAP), based on the findings of the ESIA, GreenYellow’s policies, applicable local regulation, and the PSs. The ESMS will include a policy and provisions for risk identification, organization and responsibilities, disclosure of information and reporting. The ESMS will also include a set of sub-management plans for inter alia occupational health & safety, emergency response, waste and recycling, water, biodiversity, stakeholder engagement, grievance management, and monitoring.
As required by the contract, the EPC Contractor will implement a Contractor’s Environmental and Social Management Plan (CESMP), in line with the ESMS and relevant management plans.
Security Management Procedures have been established for the Project, including roles and responsibilities, procedures for engagement and use of security forces, incident response and evacuation plans.
An ESMP for the operations phase will be developed prior to commencement of operations, as per the ESAP.
Organizational Capacity and Competency:
The Project Construction Director has the overall responsibility of the implementation of the ESMS and related coordination with authorities, contractors and other stakeholders. The Project Company will hire a HSE Manager for the Project, and OSIEC will act as E&S advisor throughout the development phase, including questions around implementation of the ESMS, monitoring of EHS aspects in construction, stakeholder engagement, the grievance mechanism, and provide capacity building. GreenYellow will also provide support to the Project through its corporate level E&S Manager based in Paris.
The EPC Contractor will appoint an HSE Officer responsible for overseeing the implementation of the ESMP, monitoring and inspections, training, and reporting to the Project Company and relevant authorities. The HSE Officer shall be suitably qualified and have prior experience from overseeing HSE management in construction projects. In addition, each sub-contractor will be required to appoint an HSE Coordinator. As per the ESAP, the Project Company will notify MIGA of the appointment and qualifications of the HSE Manager and EPC’s HSE Officer prior to the start of construction.
Emergency Preparedness and Response:
An Emergency Response Plan will be a part of the ESMS including inter alia procedures for responding to fire and explosion, spills, loss of containments of dangerous substances, traffic incidents, safety and security incidents, and malicious acts. The procedures and responsibilities for emergency response actions and communication will be clearly defined and available on-site.
The plan will include provisions for organization of emergency areas, roles and responsibilities, communication systems, resources, and training and updating. It will also include requirements for periodic tests and exercises to ensure that the necessary response measures are understood by the designated teams, staff and contractors.
Monitoring and Review:
As part of the ESMS, a monitoring and reporting system on HSE impacts related to construction will be established and implemented. Monitoring frequencies, methodology and indicators will be reflective of the risks and impacts identified in the ESIA. The EPC Contractor will report to the Project Company, which will report to authorities as required, disclose monitoring results and provide feedback to affected communities on at least an annual basis in relation to any impacts affecting them and associated mitigation measures. Annual monitoring reports will also be developed and submitted to MIGA.
In 2019, during the ESIA processes, several community consultation activities were completed with various groups of participants, including landowners, women, youth and local authorities. Stakeholder meetings were held to discuss the Project and to provide an opportunity for the affected communities to raise any concerns. Issues raised during the meetings primarily included employment opportunities, support for road maintenance and other community support measures.
A Stakeholder Engagement Plan (SEP) will be developed as part of the ESMS (as per the ESAP), building on the engagement undertaken as part of the ESIA. The SEP will include procedures for information sharing between the Project and affected parties, and the establishment of a monitoring committee with representatives from the Project, local communities and authorities, The SEP will cover both construction and operations phases.
A Community Engagement Protocol is also being negotiated between the Project and local Municipality, setting out the principles for communication between the Project and Municipality, and responsibilities regarding community involvement and development.
External Communication and Grievance Mechanisms:
A grievance mechanism will be established as part of the Stakeholder Engagement Plan, implemented by the Project Company, with the objective of providing a channel for people and communities affected by the Project to voice their concerns effectively and transparently. This includes recording any stakeholder comments or complaints and ensuring that they are passed on to the relevant party for response and resolution as soon as practicable.
PS2: Labor and Working Conditions
Construction works for each plant will generate about 150 jobs for up to one year, and operations will involve about 10-15 full-time workers. Construction staff will be housed in nearby towns, with transportation provided by the EPC Contractor, when required. Worker accommodation provided by the contractor will be in line with the IFC/EBRD Guidance Note on Worker’s Accommodation (as per the ESAP).
A local recruitment committee will be established (as per the ESAP) composed of representatives from the local authorities, affected communities, EPC, and the Project Company. The committee will handle job applications and pre-selection of local candidates and ensure fair distribution of labor requests between the local villages. The committee will also administer training programs and presentations of employment and business opportunities. Recruitment at the entrance of, or close to the project site, will not be permitted.
Working Conditions and Management of Worker Relationship:
The EPC contract will require the Contractor to observe applicable labor laws and comply with requirements related to working conditions in line with PS2. It will also require the Contractor to ensure that these requirements are passed on to sub-contractors. Relevant HR policies and procedures for the construction and operations phases will be established (as per the ESAP) to cover all workers, including direct workers and contracted workers. At a minimum, the HR Policies will include the following provisions: working relationship; working conditions; terms of employment; workers’ organizations; non-discrimination and equal opportunity; grievance mechanism; prohibition of child and forced labor; and occupational health and safety. The conditions of employment and worker’s rights will be communicated to all new employees during the induction process.
A staff representative will also be appointed, responsible for bringing employee’s concerns or requests to the management.
Protecting the Work Force:
In line with the GreenYellow’s policies, child and forced labor is prohibited in relation to the Project. The EPC Contractor will be contractually bound not to use any forms of forced labor, and to observe applicable laws and PS2 requirements related to child labor.
Occupational Health and Safety:
The ESIA includes a description of occupational health & safety (OHS) risks and impacts during construction, operations, and decommissioning, with a series of preventive measures. The main risks and impacts will include heat exposure, traffic safety, exposure to welding light and fumes and potential for fires and/or explosions resulting from ignition of flammable materials or gases. As referenced earlier under PS 1, the EPC Contractor will develop and implement the CESMP, including an OHS Management Plan. This will include organization, identification of risks and prevention measures, scheduling of meetings and trainings, permit-to-work procedure, and medical check-ups.
Workers Engaged by Third Parties:
As stated above, the Project Company will include EHS provisions in the EPC and O&M contracts and contracts with other sub-contractors providing services to that Project Company’s operations. These provisions will include as a minimum: compliance with labor legislation, terms of OHS management, and access to a workers’ grievance mechanism including review and response to anonymous complaints. The Project Company will monitor third-party compliance with approved EHS requirements.
PS3: Resource Efficiency and Pollution Prevention
During construction water will be primarily required for building foundations for the solar plant, as well as for sanitary purposes and dust control. A total of around 150 m3 of water will be required for construction purposes (for concrete preparation, equipment washing and sanitary use, etc.). During operations water will be used for sanitary purposes and to clean the panels. The frequency of cleaning depends on weather and climatic conditions, and the estimated water usage will be around 155 m3 per month.
The Project Company will undertake a water resource study prior to construction (ESAP item), to assess options for meetings water requirements during construction and operations, including connecting to the public water distribution network and whether water can be extracted from the ground aquifers to meet the water requirements for operations, whilst ensuring that extraction will not affect the local community’s resources. If sufficient water is not available, water will be supplied by trucks.
According to the ESIA, the Project will lead to greenhouse gas emissions reductions equivalent to approximately 30.000 tonnes of carbon dioxide per year.
During construction, a minor amount of air, noise and water emissions are anticipated, which will be mitigated through standard pollution prevention and control measures. During the operational phase, environmental pollution will be limited to wastewater and waste generation. The EPC Contractor will be required to implement pollution prevention measures in the CESMP to mitigate the risk of any pollution, with specific provisions for erosion and sediment control, effluent management, chemical management, and waste management.
The measures indicated in the ESMP of the ESIA include the use of proper equipment, vehicle and roads maintenance, timely dust suppression measures, speed restriction, etc.
According to the ESIA, during construction waste will primarily consist of wood residues, pallets and packaging material, metal scraps, and domestic waste. During operations, waste will be mostly generated at the offices, along with mineral oil from transformers, and sanitary effluents. A waste management procedure will be developed as part of the ESMS, including characterization of waste by type, quantities, and potential use; opportunities for source reduction, as well as reuse and recycling; procedures and operational controls for onsite storage; and final disposal.
Mineral insulating oils will be used to cool transformers in operations phase. These oils will be handled by trained personnel to ensure that manufacturers’ recommendations are strictly followed. Provision of secondary containment, drip trays or other overflow and spill containment measures will be implemented in designated areas. Vegetation control will be carried out manually without any pesticide use. Hazardous material will also include broken solar panels. The waste management system described above will include used hazardous materials and will address issues linked to waste minimization, generation, transport, disposal, and monitoring.
Apart from runoff water from cleaning the solar panels, only sanitary wastewater will be generated during operations. As there is no sewage collection network at the site, a septic system will be used, designed and installed in accordance with local regulations and the WBG EHS Guidelines to prevent any hazard to public health or contamination of land, surface or groundwater.
Decommissioning and rehabilitation plans will be developed prior to decommissioning the solar plants and associated infrastructure. Such plans will include, but will not be limited to, management of socio-economic aspects such as employment loss, removal, re-use and recycling of materials and vegetative rehabilitation to prevent erosion.
PS4: Community Health, Safety and Security
Community Health and Safety
The Project is located in a rural and sparsely populated area. It is surrounded by rural communities grouped in villages and hamlets, the closest of which is the village of Linoghin at around 6 km from the Project site, with an approximate population of 500.
Construction traffic is the primary potential adverse community health & safety impact associated with construction. A Traffic Management Plan will be developed and implemented as part of the ESMS, including training & certification, vehicle safety procedures, signage, and awareness campaigns in affected communities.
Community impacts related to in-migration are expected to be moderate and short-term due to the relatively short duration of the construction works. In-migration will be minimized and managed local recruitment committee, and the ESMS will include provisions prohibiting the use of day-laborers and recruitment at the site, and the communication of qualified job opportunities on a national level.
As discussed under Performance Standard 3, the quantities of hazardous materials are limited, and the materials are managed in a suitable manner to avoid community exposure to these materials.
The community exposure to disease around the plant is limited as the sites are located in sparsely populated areas. The Project will be implementing worker’s health programs to screen the health of workers, and a Communicable Diseases Awareness Campaign will be implemented in the communities surrounding the projects as part of the ESMP. A Code of Conduct for employees will be established, covering rules of interaction with local communities, addressing respect for local beliefs and customs and with special attention for risks related to sexual harassment, gender-based violence, and prostitution.
As indicated under Performance Standard 1, the Project will develop and implement an Emergency Preparedness and Response Plan which covers the procedures for informing stakeholders and responding to emergencies.
Site security will be managed by a private security firm. The Project is guided by the principles of good international practice in relation to hiring, rules of conduct, training, equipping, and monitoring of security workers, and by applicable law. The Project Company will ensure that the security contractor operates in a manner which meets the requirements of local regulation and Performance Standard 4, and update the Security Management Plan (as per the ESAP) to include commitment to the Voluntary Principles on Security and Human Rights, rules for use of force, and code of conduct.
The site will be fenced to prevent public access to the solar plant.
PS5: Land Acquisition and Involuntary Resettlement
The Project site is located on a 50 ha plot which was procured by SONABEL in 2018 from a single landowner. Prior to the purchase, parts of the plot (around 20%) was cultivated by community members from Linoghin and Tibin for subsistence farming, and these households where provided alternative areas to farm elsewhere on the property of the same landowner.
The land purchase was based on the principles of willing buyer – willing seller, but to align with local regulation separate compensation should be paid out for loss of trees. This amount is outstanding and will be paid by the Project Company to the landowner to finalize the land acquisition process (as per the ESAP).
Community members from Linoghin and Tibin, primarily women, also use the Project area to collect natural fruits and firewood. The Community Engagement Protocol will include livelihood support measures to address compensation for affected community members, as well community support programs identified based on consultations conducted as part of the ESIA studies, and may include agriculture productivity programs, livelihood diversification activities for women, tree planting and management, and a welfare program for vulnerable households. The final design and implementation of the support programs will be conducted in consultation with the PAPs and local authorities.
A 3.5 km access road from National Highway 4 (NH4) will also be constructed as part of the Project, on land that belongs to the same family that sold the land for the solar plant. The access road will not affect any agricultural activity, and the land acquisition is being negotiated with the owner.
The 21 km transmission line connecting the site to the existing Ziniare substation will be built along the access road and easement of an existing transmission line, additional land acquisition will therefore not be necessary. The construction of the new transmission line is expected to cause temporary closure of five shops located along NH4 and the existing transmission line. The Project will ensure that the shops are compensated for loss of income and any rehabilitation necessary, in line with local regulation and PS5 (as per the ESAP).
The Project has prepared a document setting out Compensation Principles and Social Responsibility Policy, which includes provisions for land acquisition and incorporates the issues described above. It also includes identification of vulnerable groups, community support programs in line with the Community Engagement Protocol, and a grievance mechanism. The grievance mechanism which will be implemented as part of the ESMS (see under PS1) and will be available for resolution of issues related to land acquisition.
The documentation listed below is available electronically as PDF attachments to this ESRS at www.miga.org.
- Environmental and Social Action Plan (May 2020)
- Provisional Environmental Impact Assessment Study: Nagréongo Solar Plant.
The final version of the Environmental Impact Assessment Study will be made available at the Nagréongo City Hall, the local environmental authorities (BUNEE), the Nagréongo Préfecture, the Haut-Commissariat de l’Oubritenga and the Gouvernorat du Plateau-Central.
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:
International Finance Corporation
2121 Pennsylvania Avenue NW
Washington, DC 20433 USA
Tel: 1 202 458 1973
Fax: 1 202 522 7400