Jbel-Sendouq Khalladi Wind Farm and 225kV Power Line Project Tangier, Morocco. Environmental and Social Action Plan

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1 OFFICIAL USE Jbel-Sendouq Khalladi Wind Farm 225kV Power Line Project Tangier, Morocco Environmental Social Action Plan August 2015 ESAP August

2 Official!Use!!!! Environmental,,Social,Action,Plan,, Khalladi,Wind,Farm,Project,, Note:&The&personnel&hired&(or&to&be&hired)&by&&&mentioned&in&&ESAP&includes&hired&personnel&(or&to&be&hired)&by& ACWA&Power&Morocco.& No.! Action! Environmen tal,&,social, Risks, (Liability/Be nefits)! Requirement, (Legislative,, EBRD,PR,, International, Best, Practice)! EP1! Assessment,,Management,of,Environmental,,Social,Impacts,,Issues! 1.1 Environmental Social Monitoring Report Submit to EBRD a progress report: Implementation status of ESAP Environmental social performance report in relation project activities/status Environmen tal social monitoring Loan Agreement requirement 1.2 Environmental Social Management during construction phase assign within team following three (3) responsibilities (one to three personnel, providing necessary resources), under direct authority of Project Manager: Implement ation of regulatory requiremen ts ESAP Resources,, Investment, Needs,, Responsibility! The format of annual report will be provided by EBRD. Personnel engaged by (se three responsibilities Timetable! Constructi on: every six months Operation: end of first quarter of each year during credit period. Upon entry into force of ESAP for duration of Target,, Evaluation, Criteria,for, Successful, Implement ation! Reports submitted approved by EBRD. The three leaders are recruited retained in ESAP August

3 "Environment" responsibility in charge of compliance with environmental (including environmental recommendations of EIA specifications) ation of ESAP (EP1, EP3 EP6) "Social" responsibility in charge of compliance with labor, social recommendations of EIA specifications, ation of ESAP (EP2, EP5, EP10 EP8) "Health Safety" responsibility in charge of compliance with health safety (including recommendations of EIA specifications) ation of ESAP (EP4) 1.3a Prepare an Environmental Social Management Monitoring Plan that is based on Frame ESMMP 1.3b Implementation of Environmental Social Management Monitoring Plan (ESMMP English) by Environmental, Social Health Safety Coordinator(s) during construction phase, including notification to EPC contractors of ir obligations in EBRD EP1 can not be outsourced) resources must be allocated with support of a Specialist Consultant Organized by coordinator(s), with support from external service constructio n period. By end of consultatio n period for additional ESIA document s After 1.3.a as soon as coordinato rs are hired office until end of constructi on phase The ESMMP is by Renewabl es approved by EBRD The ESMMP is ed ESAP August

4 relation to ESMMP. 1.4 Environmental Social Management during operation phase designate within team coordinator(s) "Environmental, Social, Health Safety" in charge of compliance with (including environmental recommendations of EIA specifications) ation of ESAP for operation phase. 1.5 Update of Environmental Social Management Monitoring Plan for operation ation phase. 1.6 Implementation of an Environmental Social Management System (ESMS) Integrating ISO 9001, ISO OHSAS covering all project activities for operational phase Implement ation of regulatory requiremen ts ESAP Quality Assurance Continuous Improveme providers when needed personnel engaged by (se three responsibilities can not be outsourced) Organized by coordinator(s) "Environmenta l, Social, Health Safety", with support from external service providers when needed with possible assistance of during constructio n phase 6 months before end of constructio n phase ESMMP updated before start of operationa l phase ESMMP ed during operationa l phase Prepared system: during first year of operation Coordinat or(s) appointed held in position throughou t operating phase ESMMP updated submitted for no objection to EBRD The ESMMP is n ed Integrated certified. ESAP August

5 1.7 Quality, Performance control of environmental, social health / safety of or service providers: During construction operational phases, for contracts for services or more than one million Euros, providers are required to: - Appoint a HSE (Health Safety Environment Health) - Include in ir offers HSE risk management specific plan that comply with E&S EBRD policy: (i) review of risks HSE organization, (ii) personal protective equipment, (iii) management of solid liquid waste, (iv) public protection safety of neighboring communities to construction, (v) road traffic management (vi) or specific measures that would like to see clarified. 1.8 External audit in case of complaint or significant non-compliance On request of EBRD, hire an independent consultant (chosen by agreement between nt Quality assurance a specialized firm to prepare ESMS. Certification audits by a certified firm. Request by Action to be ed by provider. Certificatio n: in second year of operation Upon entry into force of ESAP for duration of funding agreemen t On request of EBRD, in case of Certificati on renewed regularly Request systematic ally made to service provider. HSE Manager appointed HSE Plan by provider ed after approval by renewabl e. Audit conducte d ESAP August

6 EBRD) for an E & S audit recommendations for dealing with complaints or non-compliances. complaint or significant noncomplianc e. (Max 2 audits per year) EP 2 Labour Working Conditions 2.1 Complaint management: Prepare a complaints hling mechanism available to employees employees of EPC contractors ir subcontractors 2.2 Human Resources Policy Prepare make available permanently to all employees a Human Resources policy, in line with H&S policy of EBRD including: equitable treatment, non-discrimination equal opportunities for all ers; right to membership in trade unions; No child forced labour. 2.3 Human Resources of EPC contractor: Require EPC contractors ing in Morocco: to manage human resources in accordance with with EP2 of H & S policy of EBRD Conflict prevention Transparen cy Human Resources Complianc e Managem ent Preventing internal risks related to presence of a large number of EBRD PR2 EBRD PR2 EBRD PR2.. Requirement made by. Action to be ed by EPC Before start of From first year after entry into force of ESAP. Each EPC contractor managem ent plan must be submitted to Mechanis m ed effective policy paper "Human Resources Policy" freely accessible Requirem ent transmitte d to each EPC contractor ESAP August

7 To prepare a human resource management plan for construction phase including: o The conditions of employment of local residents, o o Working conditions, The conditions of accommodation catering. 2.4 Personal safety security: Prior to engagement (direct or via a service provider) of security staff, conduct a study of risks (health, safety, ing conditions) on this basis prepare a management plan to apply to this activity. EP 3 ers contractors. renewable s before begins Anticipatio n prevention of risks that security personnel will be exposed. Resource Efficiency Pollution Prevention Control EBRD PR2 EPC contractor for construction phase. for operational phase Risk assessment managem ent plan before start of constructio n phase Updated plan for operationa l phase Human Resources Managem ent Plan for each EPC contractor approved by renewabl es social responsibili ty coordinat or. Risk Managem ent Plan ed (directly or via a service provider) ESAP August

8 3.1 Water supply: Include in contract documents obligation of EPC contractors to supply ir construction site installations with water purchased from an authorized source (prohibition to pump from underground or surface sources) 3.2 Prevention control of pollution during construction phase: Require preparation ation (after approval by ) of following: waste management plan (all of waste: solid or liquid, domestic or construction waste, etc..) soil conservation plan: l management, erosion control, revegetation of temporary sites, access roads circulation, borrow or disposal areas. The uncontrolled disposal of spoils along roads/tracks is prohibited. 3.3 Prohibition of use of pesticides The nature of project does not justify use of pesticides (insecticides herbicides) during construction or operation phase. Their use is prohibited. Preventing risks of conflicting use of water resources Prevention Control of Pollution Prevention Control of Pollution EBRD PR3 EBRD PR3 EBRD PR3 Internationa l best practices Notification of EPC contractors by Requirement by Action to be ed by EPC contractors. Requirement by Action to be ed by EPC contractors for Before start of constructio n Prior to start of From start of for duration of financial agreemen Obligation / restriction included in contract document s of EPC contractor s. Plan, approved ed Prohibition formulate d applied ESAP August

9 3.4 Flicker effect Implementation of recommendation of Flicker impact study EP 4 Health Safety 4.1 Fire prevention emergency plan Prepare a plan for prevention of fire hazards management of emergency situations. The plan must include safety of ers public; will be presented to civil security authorities. 4.2 HSE Plan for major s: The measure in 1.7 of ESAP (Quality, Performance control of environmental, social health / safety of or service providers) applies to EPC contractors Prevention of Flicker effect The risk of fire in hills adjacent to Project is a major risk to safety of personnel Risk prevention for personnel exposed to EBRD PR3 Internationa l best practices EBRD PR4 EBRD PR4 construction phase for operational phase Requirement by Action to be ed by each EPC contractor. Requirement by Action to be t During operationa l phase Before start of HSE Plan each EPC contractor to prepare before Recomme ndations ed Plan approved by renewabl es, subject to civil protection authorities ed. HSE Plan by each EPC contractor ESAP August

10 ir subcontractors. activities EP 5 L Acquisition, Involuntary Resettlement Economic Displacement 5.1 Restoring Livelihoods: Preparation ation of a plan to restore livelihoods, based on Frame LALRPs Social Impact Assessment, with particular attention to gender aspects. Risk prevention, livelihood losses. EBRD PR5 Internationa l best practices ed by EPC contractors. Plan approved by EBRD before start of s that may affect livelihoods. Implement ation immediate ly after approval ed after approval by renewabl es. Prepared ed Plan EP 6 Biodiversity Living Natural Resources management of living natural resources 6.1 Biodiversity Protection Plan Implementation of biodiversity protection plan Prevention of damage to biodiversity Site EBRD PR5 As soon as Environme nt Manager is engaged during Plan ed ESAP August

11 EP 8 Cultural Heritage 8.1 Unforeseen encounters: Develop chance find procedure. Train/advise ers of types of cultural heritage that could be discovered what to do in case of unexpected discovery. EP Information Disclosure Stakeholder Engagement Stakeholders Engagement Plan (SEP): Implement SEP for Project. The ation of SEP should ensure access to information of all parties involved in project, including vulnerable groups (illiterate women heads of household, etc.). The plan will be reviewed adapted when Social Manger deems it is necessary at least at start of operational phase. Implement Stakeholder Engagement Plan (SEP), including grievance mechanism for external stakeholders, a second round of public consultations which will specifically target women. Protection of cultural heritage Public information, complaint managem ent EBRD PR8 0.. entire funding period Before start of constructio n. As soon as Social Manager is engaged during entire funding period. The public consultatio n following disclosure of environme ntal social document s should be undertake Procedure before. Inform ers. The stakehold er participati on plan is ed by renewabl es updated in due course. ESAP August

12 10.2 Public information on environmental social performance of project Publish on line up date at least annually, a comprehensive set of information selected by demonstrating good environmental social performance of Project. Demonstrati on of environment al & social performanc e of Project 0. n before begins. From first year after entry into force of ESAP. Existing web page updated annually. ESAP August