Suez Wind Energy
Environmental and Social Review Summary
Suez Wind Energy
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 requested to provide guarantees covering equity/quasi-equity/shareholder loans investments and associated interests by ACWA Power Company (ACWA Power) and Meridiam Africa Investments 2 (Meridiam) and other investors yet to be identified (together referred to as the Guarantee Holders or GHs) into the Suez Wind Energy SAE (Project Enterprise or PE) for a period of up to 20 years (the Project). The Project involves the design, construction, operation and maintenance of a 1,100 megawatt (MW) wind farm, split between two plots located in Ras Gharib District, Egypt.
The Project consists of the construction of around 138 wind turbine generators (8MW each), connected by underground cables to substations, internal roads, warehouses and offices. The Project will connect to the national grid through a 47km overhead transmission line (both 500 and 220 kV) which is under the responsibility of the Egyptian Electricity Transmission Company (EETC). The OHTL is an associated facility to the Project, over which the PE has no control and only limited leverage. The OHTL route is being confirmed, and the E&S impact assessment (ESIA) is in the process of being developed by the Regional Center for Renewable Energy and Energy Efficiency (RCREEE).
The Project sites (Plot 1: Northern plot and Plot 2: Southern plot) have been allocated for wind power development by the New and Renewable Energy Authority (NREA). The sites are in the Gharib plain and parallel to the Gulf of Suez, near other existing and planned wind farm projects, as well as petroleum industries. The sites are under the customary ownership (“ghafra system”) of Bedouin groups, who are custodians of the area; however, they do not have physical or economic activities within the sites. Plot 1 is distant from residential areas, while Plot 2 is adjacent to a small village, Wadi Dara.
Plot 2 and some portions of the OHTL are located within the Gebel El Zeit Key Biodiversity Area (KBA), designated for globally significant concentrations of migratory birds. KBAs include the set of sites previously recognized as Important Bird Areas (IBAs). The KBA covers a large area and has been zoned by NREA to guide siting of wind power development based on differing levels of risk. Plot 2 is the first development site proposed in the medium risk zone of the KBA, where bird monitoring and verification are required prior to permitting.
The Project has selected an international company to be the engineering, procurement and construction (EPC) contractor, and ACWA’s subsidiary to be the operation and maintenance (O&M) contractor. The PE and the EPC contractor started the mobilization of workers and pre-construction activities in mid-January 2025.
The Project is categorized as Category A according to MIGA’s Policy on Environmental and Social Sustainability (2013) because it includes activities with potentially significant adverse environmental or social risks and/or impacts that are diverse, irreversible, or unprecedented. The key risks and impacts associated with the construction and operation of the Project include the development and implementation of an effective environmental and social management system at the PE level, labor and working conditions (including occupational health and safety, contractor management, and influx of workers); water consumption and management, community health and safety, and biodiversity impacts on natural and critical habitat.
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
- PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resource
PS 5 does not apply since the PE is leasing bare land that was allocated by NREA for wind power development, and there was no physical or economic displacement. The Project site is not home to any Indigenous People and does not contain known cultural heritage. Therefore, PS 7 and 8 are not directly applicable.
In addition, the following World Bank Group Environmental, Health, and Safety (WBG EHS) Guidelines are applicable to the Project:
- General EHS Guidelines (2007)
- EHS Guidelines for Wind Energy (2015)
- EHS Guidelines for Electric Power Transmission and Distribution (2007)
The following documents were reviewed by MIGA:
- SUEZ Wind Energy Environmental and Social Impact Assessment (Plots 1 & 2). Prepared by EcoConServ & EcoConsult on behalf of RCREEE. Dated August 2024.
- Camina, A., Ceballos, P., and Vicente, N. 2024. Migration of Soaring Birds at Gebel El Zeit (IBA) in relation to wind energy developments. Prepared for EcoConsult on behalf of RCREEE. Dated 25 Sep 2024.
- The Biodiversity Consultancy. 2024. Draft Biodiversity Action Plan for SUEZ Wind Energy BOO Wind Power Plant 1.1. GW – SWE South (PLOT 2). Prepared for ACWA. Dated 9 Dec 2024. Disclosed by EBRD.
- The Biodiversity Consultancy. 2024. Appendix 1: Interim Offset feasibility study. Prepared for ACWA. Dated 10 Dec 2024. Disclosed by EBRD.
- IBIS. 2024. Lenders’ Environmental and Social Advisory Services for 1.1 GW Wind Power Plant (WPP) in Egypt – DRAFT Report. Prepared for Lender’s Group. Dated 25 Oct 2024. Shared by IBIS.
- ACWA Power. E&S plans and procedures
- EPC contractor. Draft E&S plans and procedures (for approval)
In addition to reviewing the above documents, MIGA carried out an E&S due diligence visit in March 2025 to the Project which included meetings with key E&S staff and management, regulatory authorities, municipal government, international and national biodiversity conservation organizations and experts, and local communities, as well as visiting the Project sites. In addition, an Independent E&S Consultant (IESC) has been engaged by the Project lenders to undertake E&S due diligence and review the E&S aspects of the Project against the Performance Standards.
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 Performance Standards objectives.
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
Environmental and Social Assessment and Management System:
ACWA Power, has a corporate Health, Safety, Security and Environment (& social) (HSSE) Management System, aligned with PS1 requirements and applied to all its projects. An E&S Management System (ESMS) framework was prepared as part of the Project’s Environmental and Social Impact Assessment (ESIA), which is aligned with the ACWA HSSE Management System.
The PE will develop a Project-specific ESMS, which will specify compliance with applicable E&S laws and PSs. 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, (viii) contractor management, (ix) adaptive management (ESAP 1). The EPC and O&M contractors will adopt the Project’s ESMS or will develop their own Project-specific ESMS that are aligned with the Project’s ESMS (ESAP 2).
Policy:
ACWA Power’s E&S Policy will be adopted by the PE as part of the Project-specific ESMS (ESAP 1) and communicated to all Project workers.
Identification of Risks and Impacts:
The Project’s ESIA was developed in line with national and lenders’ requirements by an independent consultant. The ESIA included an assessment of the potential cumulative impacts on biodiversity, air quality, noise and vibration, socioeconomics (job creation) and community health and safety. The ESIA also considers the potential climate change risks, such as warming temperatures and increased flooding. Findings indicate minimal potential impacts because the Project is in an area with low flood risks and the Project is designed to tolerate extreme weather events, including extreme rain, and wind.
ESIA approval was obtained from the Egyptian Environmental Affairs Agency (EEAA) in July 2024. The ESIA approval includes 42 actions that the PE is required to implement (e.g. design specifications, biodiversity conservation, rehabilitation, pollution prevention).
An archaeological baseline survey has been carried for the Project sites which concluded the absence of records of any sites of interests or significance within the Project area. The EPC Contractor is responsible for the preparing and implementing a Chance Finds Procedure during construction (ESAP 28).
Management Programs:
The ESMS framework in the ESIA establishes structures and programs for the management of E&S risks and impacts during construction and operation. The EPC contractor has drafted the Construction E&S Management Plan (CESMP), which will be finalized and implemented after MIGA’s review (ESAP 2). The O&M contractor will develop an Operations E&S Management Plan (OESMP) before operations in line with Project Specific ESMS (ESAP 2).
In addition, the Project will obtain the required licenses, consents and permits (e.g. construction permits; water use permits), prior to commencing any activities for which the permits are required (ESAP 3).
Organizational Capacity and Competency:
The Project engaged an E&S Manager and an HSSE Manager, who report directly to the Project CEO and coordinate closely with the EPC Contractors’ HSSE/E&S team. The EPC Contractor has engaged E&S resources, including an Environmental Manager, Social Manager, two Community Liaison Officers (CLOs), and an HSSE/E&S Translator.
Emergency Preparedness and Response:
The Project Emergency Preparedness and Response Plan (EPRP) covers community health and safety, environmental spill prevention, emergency situations, and off-site mitigation measures. The EPC and O&M contractors will prepare EPRPs as part of the CESMP, and OESMP, which will be aligned with PS 1 requirements (ESAP 2). The PE will assess local emergency services and establish supplementary site-based emergency response capabilities as part of the ESMP (ESAP 4).
Monitoring and Review:
The PE, EPC & O&M contractor will monitor implementation of E&S plans and procedures to ensure compliance with applicable E&S requirements. An Environmental Monitoring Plan will be part of the CESMP and OESMP, including baseline information; parameters; locations; methods and frequency of monitoring; and compliance criteria (ESAP 2)
The PE and the EPC contractor will be responsible for day-to-day monitoring during construction, and the PE will compile quarterly monitoring reports to be shared with MIGA. In addition, independent monitoring of environment, health and safety, labor and social aspects of construction activities will be undertaken quarterly during construction (refer to PS 2). During operation, the PE will be required to submit the annual E&S monitoring reports to MIGA.
A Lender’s E&S Advisor will also review the E&S performance of the Project on a quarterly basis during construction and semi-annually for the first two years of operation.
Stakeholder Engagement:
Stakeholder engagement activities were conducted as part of the ESIA process through targeted consultations, public meetings, disclosure of E&S documents online and in government offices, and newspaper announcements. Key issues discussed included employment opportunities, community development, and disturbance during construction.
The Project’s Stakeholder Engagement Plan (SEP) describes key stakeholders, past and planned engagement activities, grievance mechanism, roles and responsibilities, monitoring, and reporting. The SEP covers both construction and operation phases. The two CLOs will implement the SEP, including engagement activities with the Bedouin families, Wadi Dara and Ras Ghareb communities. The EPC and O&M contractors will update the SEP in the CESMP and OESMP to provide updated information regarding stakeholder activities and contacts during construction and operation (ESAP 5).
External Communication and Grievance Mechanisms:
The PE has disclosed key E&S documents, on the company website in English and Arabic. The PE also communicates updates and announcements to the public and local communities through the CLOs, social media, and local government representatives.
A Grievance Redress Mechanism (GRM) is part of the SEP and has been communicated to local communities during consultation meetings and through Project disclosures. It allows the public to send comments and/or complaints in person or via the ACWA website, e-mail, telephone, etc. The GRM will be updated to include the EPC and O&M contractors’ contact details (ESAP 5).
PS2: Labor and Working Conditions
The project is expected to employ up to 1,400 workers at the peak of construction. Workers have already been mobilized to start setting up temporary facilities on site. The PE will implement the Local Recruitment Management Plan, which will include a commitment to hiring local residents. The PE is working closely with local authorities to determine local labor availability.
Working Conditions and Management of Worker Relationship:
The PE’s HR policies and procedures are consistent with PS2 requirements and cover the following: (i) managing contractors and supply chain; (ii) human rights; (iii) working conditions and terms of employment; (iv) freedom of association / collective bargaining; (v) child labor and forced labor; (vi) equal opportunities and non-discrimination; (vii) prevention of and adequate response to gender based violence & harassment; (viii) oversight provided of contractor policies/procedures; (ix) effective worker grievance mechanism, including channel to report grievances anonymously; and (x) code of conduct. The EPC and O&M contractors, will develop and implement an Human Resources (HR) policy and procedures consistent with national laws and PS 2 requirements, and these will be made available to all workers (ESAP 6)
The PE conducts mandatory workers inductions, including training on HR policies and procedures, including GRM, code of conduct, and health and safety. The PE shall require all employees, including contractor and sub-contractor employees to be provided with a written contract of employment specifying working hours (including provisions for overtime); salary; annual leave; dismissal process; responsibilities of the employee (including responsibilities related to environment, health and safety); responsibilities of the employer and right to join trade unions (ESAP 7). The EPC Contractor includes the code of conduct in workers’ contracts so the workers are aware of their responsibilities.
The PE will conduct weekly monitoring of labor and working conditions and will engage an independent labor expert to conduct quarterly labor audits during construction (ESAP 8). The PE will submit the quarterly labor audit reports to MIGA.
The PE and EPC contractor will construct workers’ camps in line with the IFC/EBRD Guidance Note for Workers Accommodation: Process and Standards (ESAP 9). In other cases, the PE and the EPC contractor will provide accommodation through rented apartments or hotels. The PE will undertake an audit of the facilities prior to occupancy, and quarterly audits by the third-party external provider (ESAP 9)
The PE has a draft workers GRM to record, track and address grievances. The GRM can be accessed by all Project workers and includes various channels for filing a complaint (e.g. verbally, grievance box, telephone number, e-mail, WhatsApp). The Project prohibits retaliation against complainants or participants of an investigation.
The PE will undertake a gender-based violence and harassment (GBVH) risk assessment for construction and operations, including mapping of GBVH services and response providers to GBVH survivors. Based on the findings of the GBVH risk assessment, the PE will develop and implement a time-bound GBV prevention and response action plan designed to manage identified GBV risks linked to the Project. The PE will also develop GBVH policy and procedures supported by training and awareness campaign and assign and train a focal point staff to respond to GBVH related incidents (ESAP 10).
Protecting the Work Force:
The PE prohibits forced labor or human trafficking in any part of its business or supply chain as per its Code of Conduct and Ethics Policy. The PE also prohibits child labor and restricts individuals below 18 years from working in the Project (Labor Management Plan). The PE and the EPC contactor record workers’ names and birthdates and conducts age verification through official government IDs.
Occupational Health and Safety (OHS):
The PE will provide a safe work environment for all employees by complying with applicable environmental laws and regulations that govern workplace health and safety. Employees must immediately report to their immediate line supervisor on all unsafe conditions or work-related injuries, illnesses, and accidents. The EPC and O&M contractors will develop an Occupational Health & Safety (OHS) Management plan to address risks during construction and operation (ESAP 11) and to comply with regulatory and PS 2 requirements.
The EPC Contractor has drafted a Health and Safety Management Plan, which defines the OHS management system, including HSE policy, rules, roles and responsibilities; awareness and training; hazard identification and risk assessment and management; incident management, emergency response; monitoring and reporting. This Plan will be updated to provide more information on implementation (e.g. applicable risks, implementable actions, actual responsibilities, monitoring and evaluation, reporting) within the Project context (ESAP 11).
During the site visit, HSSE leads were observed to be proactive in promoting H&S in the workplace. Workers were provided with PPEs, safety signages across the sites were set-up and ambulances were on standby in case of an emergency. To that date, no incident has been reported since the initial works have started.
The PE will establish a medical clinic and ambulance managed by a physician and a nurse (ESAP 11), and the EPC and O&M contractors will have basic first aid clinics.
Workers Engaged by Third Parties:
The PE will develop a Contractor Management Plan, which will describe measures and procedures to oversee and manage contractors’ E&S performance. This Plan will stipulate contractors’ E&S requirements and have provisions on remedial actions if the contractors underperform (ESAP 12). The EPC Contractor has developed a Sub-Contractor Management Plan to check that all sub-contractors adhere to both national laws and the PSs. This Plan establishes a structured approach for selecting, monitoring, and managing sub-contractors to ensure compliance with E&S requirements. The Plan includes clauses on maximum working hours, overtime policies, and provisions for rest periods, and workers grievance mechanism, and incident reporting.
Supply Chain:
ACWA Power is committed to conduct business only with suppliers that follow the same ethical and human rights standards. The PE assessed labor and working conditions of the supplier. The supplier is required to implement a corrective action plan.
The Project Supply Chain Management Plan prohibits forced labor and child labor for suppliers and other parties involved in the Project. It also describes appropriate actions to identify and assess the risk of child and forced labor practices in the supply chain. The PE will update the Supply Chain Management Plan to include monitoring of the corrective action plan implementation and provisions related to remedial actions if risks and/or incidents have been identified (ESAP 13).
PS3: Resource Efficiency and Pollution Prevention
Resource Efficiency
During construction, the Project will generate greenhouse gas emissions from vehicles and heavy machinery. During operations, it is anticipated that the Project will result in GHG emissions savings of around 2.5 million tons of carbon dioxide equivalent (tCO2e) per year.
Water will be required for domestic use, dust control, and concrete works at the batch plant during construction. There is no existing or planned water connection to the Project sites. The PE will engage contractors to deliver water via water tankers from Ras Ghareb to the site while bottled water will be purchased for drinking. The Project is expected to require 47,000 cubic meters (m3) for construction activities and 22,000 m3 for drinking and domestic use during construction. Water consumption during operation will be minimal.
Given the water scarcity in the Project area, the PE will undertake a water supply assessment to assess water availability for the Project and impacts on local users in Ras Ghareb (ESAP 14). This assessment will also consider cumulative impacts of existing and planned development projects in the area and the potential impacts of climate change.
The EPC and O&M contractors will coordinate with the Ras Ghareb Water Company to secure the water requirements for the Project, obtain the necessary permits, and engage an authorized company to deliver the water (ESAP 3). The EPC and O&M contractors will develop a Water Management Plan to minimize water use during construction and operation (ESAP 14).
Pollution Prevention:
Potential pollution to air, water, and soil during construction is expected to be temporary, site-specific, and can be addressed through implementation of standard pollution prevention and control measures, defined in the ESIA.
Air emissions: Per the ESIA, air quality impacts are expected to be limited and result from operation of machinery and earthworks during construction. Standard mitigation practices will be followed during construction such as dust abatement measures as stipulated in the ESIA. The PE will require the EPC contractor to develop and implement an Environmental Monitoring Plan which will include among others, air quality monitoring (ESAP 2).
Noise: Although the Project site is in a remote location, there are noise sensitive receptors such as the workers and residents in Wadi Dara, adjacent to the Southern plot, who may be impacted. Noise modelling was undertaken as part of the ESIA, which included modelling of cumulative impacts from nearby windfarms. The noise modelling indicated that during operations, noise levels will not exceed standards in the WBG EHS Guidelines. The PE will conduct noise monitoring at sensitive receptors during construction and operation and include the results in the environmental monitoring report (ESAP 15).
Wastes: Construction activities will generate various waste streams including solid waste, wastewater, hazardous waste, liquids, soil, packaging wastes, metal scraps and other construction material waste. Waste management plans will be developed as part of the CESMP and OESMP (ESAP 16), and will include waste segregation and recycling, disposal facilities for the different waste streams, training, and management of wastewater and hazardous wastes. Domestic wastewater generated onsite will be collected in temporary holding tanks and removed by authorized contractors for disposal in a licensed wastewater treatment plant. The PE will assess potential waste and wastewater disposal and/or treatment facilities to identify their capacity to handle and treat the Project’s wastes (ESAP 16). Only facilities that are appropriately licensed by government regulatory body and operated to acceptable standards of safely for human health and the environment will be considered.
Hazardous Materials Management: Hazardous materials described in ESIA include fuel, paints, solvents, oils, machinery lubricants among others. A hazardous materials management plan will be developed as part of the CESMP and OESMP respectively (ESAP 17) including storage requirements, handling procedures and record keeping/ chain of custody and training.
PS4: Community Health, Safety and Security
The Project is located in a remote desert area. The potential impacts on community health and safety are expected to be more significant for Wadi Dara village, which is adjacent to the Project’s Southern plot. The village uses the access road that runs through the Southern plot. There is no residential structure within the minimum safety/setback distance from a wind turbine (300m for the Project).
Community Health and Safety
At the peak of construction, it is anticipated that approximately 1,400 workers will be working at the Project sites. The influx of workers may lead to impacts on local community infrastructure, community conflict, misconduct of workers, anti-social activities, GBVH and spread of communicable diseases (e.g. sexually transmitted illnesses). The EPC Contractor will update the Project’ Influx Management Plan to include: (i) an awareness and prevention program for site workers and local communities; (ii) GBV awareness sessions; and (iii) provisions for periodical monitoring of social related effects of workers’ influx (ESAP 19). If construction works overlap with other major construction projects in the area, the Project will assess potential cumulative impacts of worker influx to the area and implement mitigation measures if necessary (ESAP18).
The EPC will conduct a transportation route survey of the roads that will be utilized to transport turbine components (abnormal load) in accordance with the requirements of the Institute of Environmental Management and Assessment Guidelines prior to the start of construction (ESAP 19). Based on the survey results, the EPC and O&M contractors will develop and implement a traffic and transport management plan (TTMP), which will be part of the CESMP and OESMP and apply to all sub-contractors (ESAP 19). The TTMP will specify measures to minimize road traffic accidents through driver training, speed limits, regular maintenance of vehicles, and coordination with relevant stakeholders (e.g. traffic police) particularly ahead of and during convoys.
The EPC Contractor’s Health and Safety Management Plan and Operational Control Procedures include measures to avoid or mitigate adverse community health, safety and security impacts. The Plan also include arrangements for managing site access during construction and operation, including fencing / physical barriers, access controls, warning signage and monitoring of security (patrols, etc.). This Plan will be updated to provide more information on implementation (e.g. who will implement what, where, when, and how) within the Project context (ESAP 2, 12, 19).
Shadow Flicker: The ESIA identifies potentially significant shadow flicker effects at 3 sensitive receptors in Wadi Dara, where exceedances of 30 hours per year limits are predicted. The PE will ensure that stakeholder engagement will include explanation of shadow flicker and its potential impacts to the members of Wadi Dara village prior to the start of operation, as well as the grievance mechanism.
Security Personnel
A fence will be erected around the perimeter of the sites. Security and access control to the site will be provided by a third-party security company during construction and operation. The EPC Contractor will develop a security management plan in accordance with the Voluntary Principles of Security and Human Rights, and the IFC Good Practice Handbook – Use of Security Forces, (ESAP 22). The Plan will specify requirements for screening, training, managing and monitoring security and a code of conduct for security personnel, including Bedouins (responsible for the security of the Project sites through the Ghufrah system). The O&M contractor will conduct a Security Risk Assessment and incorporate the findings into the O&M Security Management Plan prior to operation (ESAP 20).
PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resource
The Project occurs within the Red Sea Coastal Desert Terrestrial Ecoregion. The landscape is a hyper-arid and very sparsely vegetated coastal plain bound by the Gulf of Suez coast (eastern edge) and the Red Sea Mountain escarpment (western edge). Some wadis occur with relatively more abundant vegetation associated with water. The landscape contains several existing wind farms, transmission lines, small oil fields and small agricultural operations (e.g. poultry, date palms, other crops). The landscape occurs within a recognized bottleneck for the Red Sea/Rift Valley flyway, with the southern parts of the landscape being recognized as a Key Biodiversity Area (Gebel El Zeit KBA) by BirdLife International for globally significant concentrations of migratory birds, including some threatened species.
The Project occurs within Natural Habitat supporting priority biodiversity features (e.g. Egyptian Spiny-tailed Lizard, IUCN Vulnerable/VU). Plot 2 occurs entirely within the Gebel El Zeit KBA and is Critical Habitat for globally significant concentrations of migratory soaring birds associated with the KBA. Project studies confirmed 3 risk zones (yellow: important, orange: very important, and red: extremely important), with risk increasing from north to south based on frequency and quantity of migrating soaring birds. Plot 2 occurs in the southernmost limit of the orange zone and meets red zone thresholds for some periods of the year (e.g. Spring migration).
Risks include temporary construction impacts (e.g. noise), and bird collisions. No significant residual impacts to Natural Habitat are expected. Significant residual impacts are possible for migratory birds, including Critical Habitat values at Plot 2 and the OHTL. Offsets will be required to achieve Net Gains for Critical Habitat. Cumulative impacts of multiple developments in the landscape, and specifically inside the KBA, are a concern. The Government of Egypt is leading a Strategic Environmental and Social Assessment (SESA) process to assess and manage cumulative effects in the landscape. This SESA is not related to the Project but findings will be relevant to the Project.
The Project has completed ESIAs, including Critical Habitat Assessments (CHAs), Biodiversity Management Plans (BMPs), Cumulative Effects Assessments (CEAs), and supplementary bat studies for Plot 1 and 2. An assessment of existing data, including that of neighboring projects, was completed to assess cumulative effects of multiple developments in the landscape around Gebel El Zeit KBA and to clarify relative risk of Plot 2 with regards the KBA. A draft Biodiversity Action Plan (BAP) and interim Offset Feasibility Study (OFS) have been developed for Plot 2. The Project has also engaged with local BirdLife partners (Nature Conservation Egypt).
Based on the BAP, BMPs and ESIAs, proposed mitigation includes avoidance (e.g. avoiding lizard burrows during construction), minimization (e.g. radar and observer-based shut-down-on-demand, use of bird flight diverters), and rehabilitation (e.g. re-instatement of areas disturbed areas post construction). The PE will establish lender agreed mitigation plans for the life of the Project and implement all measures to fully mitigate bird collision risks during Project operations (ESAP 21). The PE will update the post-construction fatality monitoring (PCFM) protocol for the life of the Project and OHTL, according to IFC/EBRD good practice handbook (ESAP 22). Residual impacts are not expected to be significant if proposed mitigations are implemented adequately at Plot 1.
Regarding Plot 2, given the sensitivity of the site, additional mitigation measures and offsets are required to effectively address the potential impacts. The draft BAP includes recommendations to improve the existing BMP for Plot 2 (e.g. additional vantage points for monitoring wind turbines) but the final implementation plan, which will indicate how these recommendations will be implemented, is still pending. The interim OFS provides a qualitative assessment of feasibility of a number of suggested sites; however, the final site or sites have yet to be selected. As a result, estimated gains have not yet been calculated. Once the final site or sites are selected, the OFS will need to be updated to present a final selection and the expected gains from these options. Proposed offset options rely on some actions within the broader flyway that are outside of Egypt and beyond the control of the PE and the Government of Egypt. The current drafts indicate that an updated BAP including implementation plan, Biodiversity Monitoring & Evaluation Plan (BMEP), and a final OFS will be prepared. While the existing documents indicate that effective implementation of proposed mitigation and offset measures may be sufficient to meet lender requirements, the final BAP and OFS are required to confirm the likelihood of effective implementation. Given overlap with the Gebel El Zeit KBA, the Project will have to implement additional conservation actions that contribute to the conservation objectives of the KBA.
The PE will update the draft BAP for Plot 2, including BMEP and proposals for contributing to the conservation objectives of Gebel El Zeit KBA (ESAP 23). The PE will update the interim OFS based on final offset selections and confirm required gains are feasible (ESAP 24). The PE will establish a panel of independent experts on migratory soaring bird monitoring and mitigation to advise the project, including consideration of cumulative effects (ESAP 25).
The ESIAs for Plot 1 and 2 include an initial assessment of the OHTL based on expected right of way (ROW) and proposed mitigation actions. The OHTL ROW, as presented in the ESIAs, is in Critical Habitat due to extensive overlap with the Gebel El Zeit KBA. For the portion in the KBA, 53% follows an existing OHTL while the remainder was re-routed to pass on the western outside edge of an existing wind power plant. An ESIA for the OHTL has been finalized for EETC, with support from ACWA, which will confirm associated mitigation plans (ESAP 26). Once available, MIGA will review the ESIA to confirm the adequacy of proposed mitigation. The PE will integrate additional biodiversity mitigation and offset measures into the updated BAP (ESAP 23) and OFS (ESAP 24) for Plot 2 to address the residual impacts not addressed through OHTL mitigation measures. The Project will develop a plan to install, monitor and maintain bird flight diverters (BFDs) for the life of the Project, with guidance from Nature Conservation Egypt on approaches appropriate for the landscape (ESAP 27).
Risks associated with introduction or spread of invasive alien species have been assessed and will be managed as part of the BMP. No impacts to priority ecosystem services were identified during assessment.
The documentation listed below is available electronically as PDF attachments to this ESRS at www.miga.org.
Northern Plot documents
Southern Plot documents
Additional documents
The above documentation is also available for viewing at the following locations:
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