Symbion Power Lake Kivu Limited

MIGA has been approached by Symbion Power Mauritius Ltd. to cover its equity investment to Symbion Power Lake Kivu Limited (SPLK), which is a special purpose vehicle established to develop the Kivu 56 Power Plant (Kivu 56 or the Project). The Project involves the design, construction, operation and maintenance of four off-shore gas extraction facilities (GEF) on Lake Kivu, an on-shore gas processing facility, pipelines connecting the GEFs to the on-shore facility (together, the Gas Plant), a 56 MW gas power plant, and ancillary infrastructure including a transmission line and a 600 m access road. The Project is located on the Rwandan side of Lake Kivu in Rubavu District on a peninsula near Busoro, approximately 10 km south of Rubavu and 150 km from Kigali. The GEFs will be constructed as floating platforms tethered to the bottom and located approximately 2 km from the nearest shore, and 5 km from the Project’s on-shore facilities.

Symbion Power is an independent power producer based in New York and develops and operates power projects in generation, transmission and distribution in Africa, Asia and the Middle East. 

Lake Kivu contains high concentrations of naturally occurring methane and carbon dioxide, which remain sequestered in the deep layers of the lake because the water is stratified along stable density layers. The lake is estimated to contain 300 billion cubic meters of carbon dioxide and 60 billion cubic meters of methane. Without intervention, the gas concentrations are expected to reach saturation levels and produce an uncontrolled gas outburst, or so called limnic eruption, within a range of 50 to 200 years, whereby large amounts of gases would be rapidly released to the atmosphere.

While Lake Kivu is located between Rwanda and the Democratic Republic of Congo, the Project’s concession is entirely within the territory of Rwanda. There is a Memorandum of Understanding in place, signed by the two countries, which stipulates the approach for selection and negotiation of concessions on the lake. In 2008, a panel of experts was engaged jointly by the two countries to establish guidelines for the safe development and operation of gas extraction plants on the lake. Based on the work of the panel, the Management Prescriptions for the Development of Lake Kivu Gas Resources were released in 2009 (the Management Prescription). The Management Prescriptions apply to all projects on the lake, and the implementation is under the auspices of the Lake Kivu Monitoring Program (LKMP), set up with the objectives of ensuring public safety, preserving the ecosystem, and maximizing the socio-economic benefits of gas extraction projects on Lake Kivu.

There are currently two gas-to-power plants on Lake Kivu utilizing a similar process as the proposed Project, Kibuye Power 1, a pilot project of 3.6 MW which was operational between 2006 and 2014, and KivuWatt of 26 MW capacity and in operation since 2015. Both plants are located in Rwanda. The distances from the Kivu56 GEFs are approximately 6 km (KP1) and 32 km (KivuWatt)..

The Project will require the construction of a 4.5 km 220 kV transmission line to connect the Project with the national grid, which will be considered an associated facility of the Project. The transmission line will run from the Project site and eastwards, connecting to the existing transmission line between Karongi and Rubavo. The transmission line will be developed by the Energy Development Corporation Limited (EDCL), a subsidiary of the Rwanda Energy Group owned by the Government of Rwanda. A 600 m access road to the Project site is also required, which has already been constructed and is also considered an associated facility to the Project.

There is a community residential area adjacent the Project site, which belongs to the village of Kabushongo. The area is primarily used for agriculture, and there is a hotel located on the Lake Kivu shore approximately 500 m to the northeast of the site.

During construction, a workforce of 250-300 persons is expected, for which housing will be arranged in rented accommodations nearby the site. There will be no on-site worker’s camp as part of the project. The Project is currently in the process of engaging an Owner’s Engineer, as well as construction contractors, with separate contracts for the GEFs, gas plant, power plant, and earthworks. The Project is currently in feasibility study stage, construction is currently expected to commence in June 2019 and last for a period of approximately 3 years.

The Project is a Category A under MIGA’s Policy on Environmental and Social Sustainability (2013) because it has potentially significant adverse environmental and social (E&S) risks and impacts. The most significant E&S risks include: lake stability and the potential risk of a limnic eruption, impacts on aquatic ecology, land acquisition, air and noise emissions, and occupational and community health and safety. Additional E&S impacts include the potential cumulative impacts associated with other existing and planned power projects on Lake Kivu.

While all Performance Standards are applicable to this investment, current information indicates that the investment will have impacts which must be managed in a manner consistent with the following Performance Standards (PS):

• PS1:  Assessment and Management of Environmental and Social Risks and Impacts
• PS2:  Labor and Working Conditions
• PS3:  Resource Efficiency and Pollution Prevention
• PS4:  Community Health, Safety and Security
• PS5:  Land Acquisition and Involuntary Resettlement
• PS6:  Biodiversity Conservation and Sustainable Management of Living Natural Resource

There is no indication or evidence of indigenous people residing in or having cultural ties to the Project area, thus PS7 Indigenous Peoples do not apply.

There are no indications of cultural or archeological sites in the Project area, and PS8 Cultural Heritage does therefore not apply. A ‘Chance Find Procedure’ will be prepared for the Project and implemented during construction activities.

World Bank Group (WBG) Environmental, Health and Safety (EHS) General Guidelines, Guidelines for Offshore Oil and Gas Development, and Guidelines for Electricity Transmission and Distribution will also apply to this Project.

The following documents were reviewed by MIGA:

• Symbion Power Lake Kivu, Environmental and Social Impact Assessment, Concession Area 2. Eco Design & Protection LTD. February 2017.
• Addendum to the ESIA, Symbion Power Lake Kivu. Nemai Consulting. October 2018.
• Abbreviated Resettlement Action Plan and Livelihoods Restoration Plan. Nemai Consulting. October 2018.
• Environmental and Social Management Plan. Nemai Consulting. October 2018.
• Symbion Power – Health, Safety, Social and Environmental Requirements for Contractors. Symbion Power.
• Gap Analysis Review against IFC Performance Standards and AfDB Operational Safeguards for the Symbion Power Lake Kivu Project. Royal Haskoning DHV. April 2018.
• Community Health, Safety & Security Baseline and Response Plan. Symbion Power. October 2018.
• Biodiversity Action Plan, Symbion Power Lake Kivu. October 2018.
• Traffic Management Philosophy, Symbion Power Lake Kivu. October 2018.
• Symbion Power Rwanda, Human Resources Policy Manual. May 2018.
• Management Prescriptions for the Development of Lake Kivu Gas Resources. Expert Working Group on Lake Kivu Gas Extraction. June 2009.
• Biological Baseline of Lake Kivu, University de Namur & Carrtel. December 2014.
• Fishes in Lake Kivu: Diversity and Fisheries, National University of Rwanda, 2012.

MIGA’s review also included a site visit in November 2018. During the visit, the team visited the proposed location for on-shore facilities and had meetings with SPLK, representatives of local communities, LKMP, EDCL, and the Rwanda Environmental Management Authority.

MIGA’s due diligence review considered the environmental and social management planning process and documentation for the Project and identified gaps between these and MIGA’s E&S requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable period, are summarized in the paragraphs that follow and in the Environmental and Social Action Plan (ESAP) attached to this Environmental and Social Review Summary (ESRS). Through the implementation of these measures, the Project is expected to be designed and operated in accordance with MIGA’s Performance Standards.

PS1:  Assessment and Management of Environmental and Social Risks and Impacts

Symbion Power has a corporate Health, Safety, Environment and Social (HSES) policy which describes the company’s commitment to conduct all activities in a manner that ensures the health, safety, and well-being of those engaged in the Project, benefiting the communities in the area of operations and minimizing pollution or harm to the local environment. The policy requires compliance with applicable laws and relevant health, safety and environmental standards and applies to all aspects of operations.

Environmental and Social Assessment:

An Environmental and Social Impact Assessment (ESIA) report was prepared by an independent consultant, in line with local requirements. The ESIA was submitted to the relevant authorities in Rwanda and approved with conditions related to E&S management and monitoring in May 2017. An independent consultant undertook a gap analysis review of the ESIA against the IFC Performance Standards, and a number of gaps as well as recommendations to address them were identified. Identified gaps included, for example, the need for further ecological baseline studies, review of associated facilities and cumulative impacts, biodiversity assessment, and compensation related to land acquisition. 

SPLK contracted another consultant to prepare an amendment to the ESIA as well as supportive studies and management plans (further described under the respective PS below), to address the recommendations identified in the external review. The ESIA addendum was undertaken consistent with the requirements of PS1.

Cumulative impacts resulting from the operation of both existing and potential future plants on the lake were reviewed as part of the ESIA addendum, including gas extraction projects, tourism development, and a potential expansion of port facilities. Concessions for future gas projects have been established in order to protect the lake and limiting potential impacts on both gas resources and other aspects such as impacts on fisheries (see PS5).  

A separate ESIA has been prepared for the construction of the transmission line, commissioned by EDCL. The transmission line is considered an associated facility to the Project (as defined by PS1). The Project has no control and very little influence over the construction of the transmission line, and will support the implementation of mitigation measures in a manner commensurate with their control and influence over the transmission line.  

Management Programs and Monitoring:

SPLK has established an Environmental and Social Management Plan (ESMP) for the Project, based on the requirements of the Rwanda’s regulation and ESIA approval, as well as PS1. The ESMP provides the E&S regulatory framework for the Project, describes the roles, resources and responsibilities for E&S management, as well as training and organizational capacity.

The ESMP also includes an implementation schedule and budget for the mitigation measures identified in the ESIA studies, and a monitoring program for the construction and operational phases of the Project. The requirements of the ESMP will be applicable to all contractors and this will be included in each contract. SPLK has also established a set of Employers Requirements for Health, Safety, Security and Environment (HSSE) which specifies requirements for contractors, including adherence to Rwandan regulation and the PSs, contractor staff training and competencies, as well as reporting and monitoring. The construction contractors will be required to implement a HSSE Management System, to be compliant with ISO 14001 and OHSAS 18001 (ESAP item #2).     

SPLK has also established a Project Execution Plan (PEP) to ensure that all contractors, employees, vendors and consultants involved in the Project adhere to the principles set out by SPLK regarding inter alia quality management, communication, reporting, certification, and HSSE management. The PEP also specifies performance criteria including occupational health and safety, environmental management, and responding to any community complaints. 

An independent Environmental and Social Monitoring Consultant will also be engaged by SPLK, to review the Project’s compliance with Rwandan regulations and the Performance Standards.

SPLK will update the ESMP for operations before commissioning of the Project (ESAP item #1).

Organizational Capacity and Training:

The SPLK management team is responsible for the overall Project, including E&S performance. Implementation of the ESMP and related requirements are delegated to the Project Director. SPLK has engaged an Environmental Officer to oversee the implementation of the ESMP. The Environmental Officer has previous experience from managing E&S issues at similar construction sites. An HSE Manager has also been appointed for the Project.

A Project Steering Committee will be established to promote the E&S policy and ESMP across the Project, which will be accountable for assuring effective E&S management at the site. A Community and Government Relations Officer will also be engaged, whose duties include managing relations with the communities and institutional stakeholders and overseeing the implementation of activities related to land acquisitions, livelihood restoration, and grievance management. Each construction contractors will also appoint a HSSE Representative.

Reporting:

Reporting commitments are specified in the ESMP and PEP. During construction, E&S reporting to SPLK management and the Steering Committee will be at least monthly and will include: summary of activities; number of contractors employed; number of environment, health and safety incidents; description of environment, health and safety incidents (if any), summary of community engagement activities and grievance register. Regular internal audits will also be undertaken by the Environmental Officer, HSE Manager, and the Owner’s Engineer. The Project will also be required to provide MIGA and Rwandan authorities with an Annual Environmental and Social Monitoring Report.

Emergency Preparedness and Response:

An Emergency Preparedness and Response Plan (EPRP”) will be prepared by SPLK as part of the ESMP (ESAP item 3). The plan will include procedures for incident and emergency management, call out and mobilization, line of responsibilities and roles, interfaces with external organizations and institutions, contingency plans for specific scenarios and a communications directory. The EPRP will include consideration of worker and public injuries, property damage, fire, environmental damage and natural disasters. In addition, the EPRP will include coordination with the LKMP and communication to communities in the case of a gas release event. Contractors will be required to have their own EPRP, which is based on the SPLK EPRP.

Stakeholder Engagement:

Stakeholder engagement was initially carried out as part of the ESIA process and included consultation with government officials, EDCL, the private sector, and representatives from farming, fishing and Lake Kivu transport cooperatives.      

Engagement with the potentially affected communities started with baseline socio-economic surveys and a series of consultation meetings starting from February 2016. Key topics included Project activities, potential construction impacts and risks, stakeholder engagement process and the proposed grievance redress mechanism.   Ahead of each meeting, a non-technical summary of the Project was made available to attendants. The results of the consultation indicate that the community is generally supportive of the Project. The primary benefits expected include jobs, business opportunities and electricity. Concerns from the stakeholders included issues related to land acquisition and compensation, safety of gas extraction activities, cumulative impacts, and potential impacts on fish and fishing.  

A framework for a Stakeholder Engagement Plan was established as part of the ESIA. The Project will finalize and implement the engagement plan as per the requirements of the PS1 (ESAP item #4)

PS2:  Labor and Working Conditions

It is estimated that the proposed Project will engage approximately 300 staff during peak construction period. The operations phase will require approximately 50 employees. SPLK currently has 11 staff engaged for the development and design phase.

As indicated above, there will be no worker’s camp at the site and construction staff will be housed in nearby rented accommodation. Contractors are required to follow the EBRD/IFC Guidance Note on Worker’s Accommodation, as per the SPLK ‘’Employers Requirements.  

Human Resource Policy and Procedures:

SPLK has established Human Resources (HR) policies and procedures consistent with Rwanda regulation and the requirements of PS2. This includes description of employment practices and recruitment procedures, code of conduct, training and development, policies for non-discrimination and against sexual harassment, and conflict resolution.  Contractors will be contractually obligated to apply the SPLK HR policies and procedures.

Working Conditions and Terms of Employment:

The Project will avoid discrimination and ensure equality of opportunity during the recruitment processes of its own employees and workers engaged by third parties, and such provisions are included in the HR Policies described above. The Project, including contractors, will preferentially hire local people for unskilled jobs, particularly from the families of project affected persons.  Local residents with the appropriate skills will also be given priority for skilled jobs and contractors are required to assess the opportunities to train the local workforce to fulfil the employment needs.

Employee Grievance Mechanism:

As part of the HR procedures, an employee grievance mechanism has been established. It allows for workplace concerns to be raised by workers and addressed, and has a described procedure for managing and resolving complaints.  In its current version, the grievance mechanism does not allow for anonymous filing of complaints and can only be filed within 10 days of the event or conflict. SPLKL will update the procedures for grievance management as per the requirements of PS 2 (ESAP item #5).

A staff grievance mechanism for the construction phase of the Project will be established by the construction contractors, as defined by the SPLK Employer’s Requirements. The mechanism will include an anonymous communication channel and contractors will report to SPLK on reported grievances and progress in terms of resolutions.

Occupational Health and Safety (OHS):

SPLK’s policies and procedures related to OHS are set out in the Project Execution Plan (PEP) and the Employer’s Requirements for contractors. The PEP includes targets and success criteria for OHS, organizational capacity, procedures for reporting, investigation of incidents and security.

Construction contractors will establish and implement a HSSE Management System compliant with the requirements of OHS 18001. The Employer’s Requirements lists provisions for the management systems, including policy statements, organizational structure, competence assurance system, risk assessment, audits and inspections, incident investigation, and subcontractor management. The HSSE Management System will include provisions for emergency response to events such as unplanned gas releases, explosions, or fire on the Project facilities.

In addition to the management system, contractors will prepare Health & Safety Management Plans, including site specific procedures for site design and operation, risk register, use of personal protective equipment, induction training, competency requirements, etc. to ensure that the work is carried out in line with the Employer’s Requirements and the applicable Performance Standards and EHS Guidelines.

Supply Chain:

HR Policies and procedures prohibit the employment of workers under 18 years of age. The potential for child and forced labor in the primary supply chain will also be monitored and contracts with sub-contractors and suppliers will include provisions consistent with PS2 requirements to address labor issues including child and forced labor.

PS3:  Resource Efficiency and Pollution Prevention

Potential pollution issues during the Project’s construction phase will be those typically associated with construction sites such as dust, noise, oil spills and traffic. These impacts are limited and temporary and will be mitigated with standard mitigations measures which are included in the ESMP and in accordance with the PSs.

Resource Efficiency and greenhouse gases:

The Project will be fueled by methane extracted from the Lake Kivu, and utilize high efficiency combustion engines. With respect to emissions of greenhouse gases (GHG), the project is expected to emit 900,000 ton CO2-equivalent per year. By extracting and burning the gas in a controlled manner, the Project mitigates the risk of a limnic eruption which would result in the release of large amounts of GHGs (methane and carbon dioxide) to the atmosphere. The Project aims to reduce consumption of primary resources and emissions of pollutants, and the ESMP includes application of adequate control measures for this purpose. The power plant will monitor GHG emission continuously and ensure annual reporting of the emissions.

Water resources:

The gas extraction process utilizes two water cycles. Water from the lake’s gas resource zone at approximately 350 m. depth is drawn up through a riser and gas is separated from the water under hydrostatic pressure in a separator. The degassed water is reinjected at 270 m depth through a second riser. The second water cycle takes place on shore, where the gas is concentrated in a wash water tower through the reabsorption of carbon dioxide and hydrogen sulfide. The wash water is drawn from 40 m depth and reinjected at 80 m (below the biozone). The extraction of gas alters the density of the water, and the depths for reinjection of water has been chosen to match the density or the ambient water, as per the Management Prescriptions. Other water quality impacts are not expected. The volumes of water in the gas extraction cycle will be approximately 1.5 Mm3/day, and for the wash water cycle 0.2 Mm3/day, all of which is reinjected to the lake.     

Pollution Prevention:

During the construction phase, air emissions from the project will primarily include dust/particulates from land clearing and earth works as well as nitrogen oxides (NOx), carbon monoxide (CO) and sulfur dioxide (SO2) from the combustion of fuels and operation of construction vehicles. Measures to minimize these impacts have been identified in the draft ESMP. These measures include the use of adequate equipment, vehicle and roads maintenance, timely dust suppression measures, and speed restrictions.

Air dispersion modelling for the operations phase is currently being carried out for the Project, and will guide the final design, including stack height in line with the WBG EHS Guidelines. Noise impacts are expected to be associated with construction activities, as well as the operation of turbines and generators for power production. Noise emissions modelling for the operational phase has been conducted and confirmed that noise levels are expected to be within the limits of local regulation and the WGB EHS Guidelines.

Solid waste Management:

Construction waste such as domestic waste, inert waste (i.e. rubble, spoil), recyclables (i.e. plastics, paper, metals.) will be sorted on site and collected by a licensed waste collector for recycling and disposal as required by local regulation. General waste generation during operations is not expected to be significant, the waste will be disposed of by a licensed waste contractor similar to in the constructions phase. A Waste Management Plan will be developed and implemented by the Project, as part of the EMP.

Hazardous Materials Management:

Chemicals to be used during construction and operation of the Project will primarily include paints, fuels and lubricating oils. These chemicals will be stored in small quantities on site, in designated storage cabinets with secondary containment. Petrol/diesel for generators will be stored in above-ground storage tanks fitted with containment bunds.

PS4:  Community Health, Safety and Security

Potential community health and safety impacts are principally associated with the risk of lake

eruption, gas release, explosion and fire related to operation of the GEFs, gas pipeline and the

power plant. During construction, communities in the Project area are also exposed to impacts associated with increased traffic and in-migration of the project workforce.

SPLK has established a Community Health, Safety & Security Response Plan (CHSSRP) which includes a risk analysis, mitigation measures, provisions for community emergency preparedness and a monitoring program for community health and safety. Related to construction traffic, a Traffic Philosophy has been developed for the Project which acts as a management plan, and includes provisions for traffic planning between contractors and SPLK as well as measures to minimize disruption to local communities, use of signage and dedicated passageways, coordination with local authorities, and road safety information campaigns.

The CHSSRP also includes prescriptions for management of impacts related to in-migration of the project workforce, such as use of Worker’s Code of Conduct, health campaigns and monitoring of sexually transmitted infections, partnering with the local health clinic, monitoring of community grievances and partnerships with relevant organizations to reduce potential incidents of gender violence in both communities and among the SPLK workforce.

The potential for a limnic eruption of Lake Kivu is a safety and health risk for the surrounding communities, as hazardous amounts of methane, carbon dioxide and other gases would be released and render the air surrounding the lake unbreathable. The risk of an eruption is primarily mitigated through the Management Prescriptions, which details requirements for the safe operation of gas extraction projects, as well as provisions for monitoring of the chemical and physical conditions in the lake. The Management Prescriptions are enforced by LKMP, which will conduct a review of the Project’s technical design and its compliance with the Managements Prescriptions. LKMP will also conduct on-site inspections of the Project in both construction and operation phases.

Security Arrangements:

Site security will be managed by a private security firm who will provide trained unarmed security personnel. The site will be fenced and public access to the plant will be controlled. The Project will be 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.

For construction and operations activities, SPLK will establish site security procedures as part of the Health and Safety Plan in line with the requirements of PSs 4 (ESAP item 8).

PS5:  Land Acquisition and Involuntary Resettlement

The on-shore site will occupy an area of 5.5 hectares, of which approximately 1 hectare was under government control as part of the Lake Kivu buffer zone, and the remainder was made up of 34 plots owned by 17 different land owners. The land acquisition process was managed by EDCL through expropriation on behalf of the Government of Rwanda and initiated in 2017. The Project will be leasing the land from the Government.

The expropriation process included a survey of the 34 plots, valuation of properties by a certified third party, the availability of a grievance resolution process for negotiation of compensation amounts, and sign-off by the land owner, EDCL, and local authorities. Land-owners are given the choice of monetary (cash) or in-kind compensation of land and buildings (or a combination).  Following the payment of agreed amounts, land is transferred to state ownership. In addition to the agreed amount for compensation, an allowance is added corresponding to 5% of the amount for transitioning costs for the affected households. All affected households had official title deeds for the respective plots and opted for the option of cash compensation.

The expropriation process has been completed for 27 out of the 34 plots. For the remaining plots, negotiations around the compensations rates and amounts are still ongoing between EDCL and the land-owners.

Out of the 34 plots, 30 was used for agricultural purpose only, primarily banana, cassava and bamboo. Four affected households required physical resettlement; each of these households opted to receive monetary compensation for building a new house of equivalent standard while at the same time retaining the right to re-use any material from the old house. At the time of the site visit, each of the four households had relocated to new sites at distances of approximately 1 km from the previous location, remaining in the village of Kabushongo.

Grievances raised by affected households during the expropriation process included access to land title documentation, disagreements related to details in the land title registry, a case of collective land title, and complaints regarding the compensation amounts. All grievances were resolved by EDCL, except for one case where the complainant has opted to escalate the case to the court system to settle the amount. 

The approximately 600 m site access road connecting the existing road to the site is considered an associated facility to the Project. Expropriation for the road was conducted by the Rwanda Transport Development Agency (RTDA) in 2016 and involved 11 affected households out of which 7 required physical resettlement and 4 economic displacement.

For the second associated facility, the transmission line connecting the Project to the national grid, the approximate route has been identified but the land expropriation process has not yet begun. Based on the current design, 8 households will require physical resettlement. The expropriation process will be carried out by EDCL. The Project has no control and very little influence over the construction of the transmission line and will support the implementation of mitigation measures in a manner commensurate with their control and influence over the transmission line.

The Project has prepared an Abbreviated Resettlement Action Plan (ARAP) with the purpose of addressing any gaps between the land acquisition carried out by EDCL and the requirements of PS 5. This includes the identification and assessment of vulnerable households among the affected population, establishing a grievance mechanism operated by the Project, and the implementation of a Livelihood Restoration Program. SPLK will also conduct a survey of the households affected by expropriation to date, including for the associated facilities, and liaise with EDCL for the land acquisition necessary for the construction of the transmission line.  

Although the Project is not expected to have any effect on the fish stock in the lake, fishermen will be affected by the Project since an exclusion zone will be established around each GEF and along the pipeline. Boats will be allowed to cross the pipeline, but not while using fishing equipment such as nets. Kivu56 will establish a Fisheries Management Plan, including a survey of current fishing activities in the Project area, potential ways to limit the extend and impact of the exclusion zones, monitoring of impacts resulting from limited access to fishing areas, and the implementation of support programs to fishermen and fishery cooperatives (ESAP item #10).

Following the completion of the land acquisition process, the Project will conduct a completion study of affected households to assess the outcomes of compensation and livelihood restoration activities (ESAP item 8).  

PS6:  Biodiversity Conservation and Sustainable Management of Living Natural Resource

The biodiversity assessment carried out as part of the ESIA studies concluded that there are no protected areas (e.g. national parks, reserves or wildlife sanctuaries) affected by the Project and significant impacts on terrestrial or aquatic biodiversity are not expected.

The on-shore project site is located in modified habitat, currently used primarily for farming of banana, cassava and bamboo. The vegetation on areas which is not farmed is made up of shrubs, herbaceous plants and a variety of grass species.

There are 29 species of fish in the lake, out of which 5 are introduced. The most abundant species, and widely fished, is the Izambaza (Limnothrissa miodon) or so called ‘Tanganyika Sardine’, which was introduced in the 1960’s. There are no threatened or endangered species in the lake. Significant impacts on aquatic biodiversity, including fish, are not expected. The Project will be designed and operated in line with the Management Prescriptions which include mandatory requirements for control and monitoring of potential impacts on aquatic biodiversity.

The lake’s biozone is defined as the top layer (0 – 60 m) where fish and other aquatic species are present. During gas extraction and processing operations, impacts resulting in changes to the chemistry of the biozone could have a potential effect on fisheries, either because of impacts to primary food sources (phyto and zooplankton) or directly to the fish species themselves. In addition, the accidental release or ingress of deep waters from the resource zone into the biozone would be expected to result in nutrient enhancement from ammonia, iron and phosphates, causing eutrophication. The design of the Project in terms of the process for extraction and return of water minimizes such risks as any processed water is re-injected to the lake at depths below 80 m, as required by the Management Prescriptions.

Both the Project and LKMP will be conducting monitoring of biochemical parameters in the Project’s potential area of influence. Based on the results of the monitoring program conducted so far for the operational KivuWatt project, the Project is expected to operate without significant impacts on water quality and aquatic biodiversity.

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

• Symbion Power Lake Kivu, Environmental and Social Impact Assessment Report, Eco Design & Protection LTD.
• Addendum to the Environmental and Social Impact Assessment, Symbion Power Lake Kivu. Nemai Consulting.
• Abbreviated Resettlement Action Plan and Livelihoods Restoration Plan. Nemai Consulting.

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