CERTIFICATE OF ENVIRONMENTAL CLEARANCE RULES, 2001

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1 CERTIFICATE OF ENVIRONMENTAL CLEARANCE RULES, 2001 Final Terms of Reference for the Environmental Impact Assessment in respect of: CEC1468/2006 Application for a Certificate of Environmental Clearance (CEC) by Alcoa Trinidad Unlimited for the establishment of an Aluminium Complex at the proposed Cap-de-Ville Industrial Estate in Chatham. 1.0 Introduction The Environmental Management Authority (EMA) received an application for a Certificate of Environmental Clearance (CEC) from Alcoa Trinidad Unlimited on May 15, It is with regard to the proposed establishment of an aluminium complex (aluminium smelter, anode production facilities, and intermediate/downstream fabricating facility) to produce 341,000 metric tonnes per annum (approximate) of aluminium at the proposed Cap-de-Ville industrial estate at Chatham. This application was made in accordance with the CEC Rules, 2001 and Activity 21 [Establishment of a facility for the production and reforming of metals or related products] of the CEC (Designated Activities) Order, The EMA has determined that there could be significant environmental impacts arising from these activities, and that the application requires a CEC and an Environmental Impact Assessment (EIA) in compliance with a Terms of Reference (TOR). The TOR will serve as a guide for the conduct of the EIA and the preparation of an Environmental Impact Report in an effort to understand the scope of the project, the potential impacts and the measures that should be taken to mitigate these impacts. While every attempt has been made to ensure that this TOR addresses all of the major issues associated with this proposal, they are not necessarily exhaustive and should not be interpreted as excluding matters deemed to be significant but not incorporated in them, or matters (currently unforeseen) that emerge as important or significant from environmental studies, or otherwise, during the course of preparation of the EIA. It should be noted that the preparation of terms of reference for this Environmental Impact Assessment does not indicate approval or support in any way, nor does it indicate approval in principle. 1.1 Background Information The proponent has indicated in the application for CEC 1468/2006 that the proposed aluminium smelter is expected to utilise state-of-the-art air emission control systems, institute processes to reduce or eliminate process wastewater discharges, and implement programmes to reduce/recycle solid and hazardous waste generation and disposal. 1

2 The facility is proposed to produce 341,000 metric tonnes of aluminium annually. Aluminium will be produced using the Hall-Heroult electrolysis process for the reduction of alumina. The production of aluminium using this process requires a number of material handling and sub-production facilities to supply and prepare the raw materials and consumables for the reduction process. Downstream facilities are also required to refine, alloy, and freeze the metal product at a quality and shape specified by customers. Aluminium reduction will occur in multiple cells or pots arranged in two parallel buildings each of approximately 1100m in length. Emissions from the pots will be captured at the top of the pots and forwarded to the gas treatment centre where the gases are injected into an alumina bed which adsorbs the gaseous fluorides, passed through bag filters to remove particulates and finally released to the atmosphere. The anode production facilities will comprise three sections: the green carbon plant, the anode baking plant and the anode rodding plant (for rodding and storage). Molten aluminium is converted to different products at the casthouse including extrusion ingots, T-bars, standard ingots etc. The raw materials required for the process will be imported by ship via a proposed port for the Capde-Ville estate. The port facilities will include alumina, aluminium tri-fluoride and coke receiving and handling, general materials receiving and handling, pitch receiving/storage and handling, product shipping, warehouse and laydown areas. The power requirements for the smelting process will be provided by a new a natural gas-fired power facility with the capacity to continuously supply approximately580mw power to the smelting facility. Additional facilities proposed for the site, that is, the power facility, port facility and other related facilities, would be covered under separate applications. However, these facilities must be considered within this TOR with regards to cumulative impacts. 1.2 Objectives The scope of the EIA will be to determine the type and extent of environmental and social impacts arising from each of the proposed facilities, at the same time examining the cumulative impacts of the complex with other proposed activities for the industrial estate and existing activities in the surrounding areas. It will also include the management or mitigation of the significant negative impacts, monitoring of the mitigation measures used, and provide an assessment of the risks and hazards associated with all aspects of the proposed project. In addition, the scope of the EIA will include an examination of the socio-economic benefits of this project to the affected community/ies as well as the national community. The EIA will address the general ability of the site to sustain and benefit from the proposed development. A critical part of the assessment will be the consideration of potential cumulative interactions of the subject project with other existing approved and ancillary projects and activities. 2

3 The applicant will ensure that it has sufficient details on the design, layout and operations of the ancillary and other facilities being assessed for cumulative impact to allow for a rigorous assessment of these impacts. The assessment will also address potential future project modifications where these can be reasonably predicted. These must be addressed to the satisfaction of the EMA. It is envisaged that the EIA Report will be based on the results of available research, studies and data as appropriate, with further studies being conducted where necessary and practicable. The extent to which the limitations, if any, of available information may influence the conclusions of the environmental assessment should be discussed. This assessment is being done to: Allow the community and the wider public to understand the project and its impacts on them and their socio-economic and physical environment, and to have their views and concerns addressed in the determination of the CEC application, and any subsequent design, development and construction; Provide the developer with information that allows them to maximize the benefits of the project to themselves, the environment and the community and wider public; Allow regulators to ensure that the positive impacts of the project are maximized and the negative impacts eliminated or minimized to acceptable levels. 1.3 Legal Framework The CEC Rules, 2001 were made under Section 26(h) of the Environmental Management (EM) Act, 2000 and came into effect on July 7, The CEC (Designated Activities) Order, 2001 outlines a list of activities that require a CEC from the EMA before such activities can commence. The establishment of the proposed aluminium complex is consistent with activity 21 of the CEC Order, the establishment of a facility for the production or reforming of metals or related products. The CEC Rules describe the process to apply for and obtain a CEC. Rule 5(1) of the CEC Rules describes the process for preparation of the TOR for an EIA, while Rule 10 outlines the standards of preparation of the EIA. This environmental assessment is requested in accordance with the relevant sections and rules of the EM Act and CEC Rules, respectively. In order to be environmentally acceptable, the establishment of the proposed complex must be in compliance with international standards or guidelines (as indicated in the National Environmental Policy, 2006) and pertinent local standards or guidelines. Local environmental standards or guidelines, which are applicable to CEC application CEC1468/2006, include the following: TTS 417:1993 (Specification for the Liquid Effluent from Domestic Wastewater Treatment Plants into the Environment) 3

4 TTS 547:1998 (Specification for the Effluent from Industrial Processes Discharged into the Environment) Environmentally Sensitive Species Rules, 2001 Noise Pollution Control Rules, 2001 National Environmental Policy Occupational Health and Safety Act (Amended) 2006 Town and Country Planning Act The Forest Act Chapter 66:01 and Amendments Act 24 of 1999 Conservation Wildlife Act Chapter 67:03 National Biodiversity Strategy and Action Plan for Trinidad and Tobago National Physical Development Plan, 1984 International Conventions to which Trinidad and Tobago are signatory e.g. Basel Convention, United Nations Framework Convention on Climate change (UNFCCC), Convention on Environmental Impact Assessment in a Transboundary Context (Espoo, 1991), the Convention on Biological Diversity, and any other relevant agreements and treaties. International standards or guidelines can be sourced from the most stringent of the following: United States Environmental Protection Agency (USEPA), World Bank, World Health Organization (WHO), Multilateral Environmental Agreements or other appropriately referenced and available material. 2.0 Requirements for Environmental Impact Assessment and EIA Report 2.1 Study Area The study area should be determined by the extent of direct and indirect impacts of the construction and operation activities of the aluminium complex and the physical, biological and social environments. This should include the area of proposed works, other facilities within the general area, and the associated areas such as the predicted impact zone for air and other emissions. Surrounding communities that can be affected by noise, air emissions, emergencies or upset conditions also need to be considered in defining the study area. In order to obtain this information, the proponent should liaise with the Meteorological Division to establish wind-monitoring equipment over a period of time (to be determined in conjunction with the EMA), which would allow for a more accurate record of the wind activity in the area. The study area should also include lands that will be directly disturbed by the facilities or by its associated infrastructure such as off-site facilities, access and utility corridors. Definition of the study area should also illustrate any other existing infrastructure with respect to industrial activity in the concerned area. The proponent is advised to consult with the EMA in defining of the study area after each scoping phase of the EIA is completed. The study area(s) should be properly delineated and referenced in relation to the Universal Transverse Mercator (UTM) coordinate system and/or the World Geodetic System (WGS84). 4

5 In addition, the study area(s) should be described with accompanying photographs, aerial photos, land-use, topographical and geological maps, and any other diagrams at easily understood scales to illustrate the spatial extent of the project, and the potentially impacted areas and sensitive receptors. Labelling of maps and diagrams must be at a font size that is easily read. The various study areas should not only be listed, but the rationale used to select the EIA study areas should also be explicitly described. 2.2 Mapping Mapping, as referred to in this TOR, shall be considered to be spatial data to scale as represented in digital and printed format. Because of the nature of this intended project and the study area, the use of GIS to represent spatial data shall be required. Submitted data should be presented in a working GIS project compatible with ArcView and be organised into discrete themes (i.e. shape files point, raster and vector data). Data themes should illustrate, but not necessarily be limited to, the following features/attributes: Roads (all classes) Built development (e.g. residential, institutions schools, hospitals etc.) Demographics of the study area Water resources rivers/streams, standing water bodies, aquifers/groundwater resources, municipal wells, watershed, etc. Location of existing industries and their associated infrastructure (i.e. existing/abandoned oil wells, pipelines, etc) Topography (contour lines at appropriate intervals, preferably in metres) including derived digital elevation models (DEMs) and triangulated irregular networks (TINs) Sampling points for baseline data Proposed monitoring stations/points Intended effluent points Proposed building footprints and buffer zones Property holdings and land tenure Flora, including endemic species, and faunal habitats Forest reserves, wetlands Fishing areas Agriculture Recreation Land ownership, areas to be acquired Administrative areas (e.g. regional corporation) Conceptual Emergency operations (e.g. evacuation routes, shelters, contamination zones, fire zones, explosion zones, etc) Soil and geology Permanent geodetic markers Known archaeological sites and sites of historical interest. 5

6 For features in themes to which particular emphasis is to be placed, they shall be linked to photographs. Themes should be clearly labelled/annotated. Map units and distance should be set in metres and kilometres respectively, and either the UTM or WGS84 coordinate system should be utilised. The use of GIS would not otherwise exclude the use of photographs, map sheets and diagrams at easily understood and appropriate scales to illustrate the spatial extent of the project and the impact area. Such photographs should be indexed with the map sheet to aid in the illustration process. High resolution aerial and satellite imagery should be used as reference data and must align with digital data themes. Printed maps of the site area should indicate the layout of the proposed facilities in the context of the immediate site as well as with respect to other existing and proposed activities within the wider study area. Each printed map should be at appropriate scales for the overview being illustrated (e.g. 1: 5,000 minimum for site plans). All maps and other figures should be clearly legible and include proper legends; use of scanned documents, texts or graphics is not acceptable and should be avoided. 2.3 Description of the Project The description of the project will include a justification statement and detailed descriptions of the project s phases and activities. A site plan at a scale of 1:5,000 (or other appropriate level) should be provided to indicate the general layout of the proposed facilities as well as its relationship with the study area. The site plan is to be based on the subdivision plan approved by the Town and Country Planning Division (TCPD). Where necessary, appropriate plans should be included at relevant scales to facilitate easy comprehension of location, design, construction or operational processes. Provide sufficient scope and detail in the project description information to allow quantitative assessment of the environmental consequences where practicable. If the scope of information varies among components, processes or phases of the project, provide rationale demonstrating that the information is sufficient for assessment purposes. Detailed information on the project should be provided and must include the following: A description of the overall positioning of the aluminium smelter, anode-making facilities, intermediate/downstream fabricating facilities, and their associated components (e.g. process equipment, storage areas, drainage areas, pipelinesconveyor systems, product loading areas, location of stacks and other points of emissions etc.) in relation to one another and the surrounding areas. This should show shapes, boundaries and coastlines, rivers, streams, outfalls and community settlements; Process Description Describe all stages (e.g. feed system, aluminium reduction process, gas scrubbing/treatment, pot lining, casting and dross treatment, anode forming process and storage, etc) of the aluminium production process. Flow diagrams shall be utilized as far as possible to illustrate the process. 6

7 The process description shall include (but not be limited to) the following details: - Design basis, design capacity and normal operational capacity; - Process equipment and machinery; - Source and description of all major feed and raw materials, intermediates and subsidiary inputs used in the process as they relate to normal operations and maintenance. This should also include estimates of quantities in stock, quantities to be consumed per metric tonne of aluminium produced and on-site storage arrangements such as containment and location; MSDS for each chemical should be provided in an appendix; - Details on the physical characteristics of the major raw materials (alumina, calcined petroleum coke and coal tar pitch) such as particle size distribution, particle density, bulk density and moisture content; also data on the chemical composition of alumina such as % Al 2 O 3 and any other trace constituents such as heavy metals (e.g. lead, cadmium, mercury, nickel etc.) should also be included; - An identification and description of the final product(s) derived including rate of production, chemicals/material storage arrangements and intended destination and shipping arrangements. - A description of utilities (e.g. water, natural gas, electricity) in terms of requirements and areas to be utilised, availability, sources and plans for obtaining such and infrastructure that will be required; - The water requirements (both potable and process) for construction, start-up, normal, worst-case conditions and emergency; - Details of any hazardous materials to be stored/handled or used in the process including the maximum quantity to be stored and/or used in the process at any one time; a plan showing the location of the material on the site and the MSDS should also be provided; - An identification of the source, quantity and composition of all sources of all potential liquid wastes (e.g. process water, sewage, stormwater, chemical) that will be generated and describe how they will be managed (i.e. containment, treatment and disposal) and what special risks (if any) they pose. The treatment and collection of all liquid effluent generated may best be depicted on a flow diagram. The layout of the wastewater drainage system should be clearly depicted on a site plan that includes all discharge points (if any) and the pipeline routing; 7

8 - An identification of the source and quantity of all hazardous and non-hazardous solid waste (e.g. spent pot lining, anode butts, dross, solids from dust-collection equipment, construction waste etc.) that are expected to be generated, and describe how they will be managed (i.e. containment, treatment and disposal) and what special risks (if any) they pose. For disposal of hazardous wastes, full details must be provided including the location of the proposed receiving facility, evidence that the facility is able to handle the type of waste, evidence that they are willing to handle the waste, and details of compliance with all legislative, regulative and other related criteria for the collection, transport, receipt and processing of the waste. The treatment and collection of solid wastes may best be depicted on a flow diagram; - An identification of the source, and estimate of the quantity and quality of air emissions and noise levels generated from this type of facility; identify locations of these emission sources including sources of gaseous fluoride, particulate fluoride and any other significant atmospheric pollutant on a map; the average volumetric flow rate and velocity for emissions from the potroom should also be included; emissions to be considered include alumina dust, coke dust, tar vapour, carbon particulates, volatile organic compounds (VOCs), gaseous fluorides, particulate fluorides etc.; a clear identification of all sources of noise emissions, as well as an estimate of the noise levels generated from this type of facility at the property boundary, as well as in the respective communities; - Electromagnetic fields resulting from smelter operations - Show zone of impact with changes in levels as they radiate out of the potrooms; - A list of Alcoa plants in other countries utilising similar technology should be provided along with details on pollutant emissions and operating efficiencies of the various pollution-control equipment/processes being utilised; any differences from the proposed project in the process and infrastructure should be highlighted. Description of all other associated works and infrastructure required for the establishment and operation of the facilities. Include: - Description of activities that would occur during site preparation, construction/ engineering operations and start-up of operations; - Description of the proposed Port, Power Plant and ancillary facilities in sufficient detail to allow for assessment of cumulative impact; - Description of transportation requirements - equipment utilised and access routes, pipelines/conveyor systems, transmission lines or access roads; discuss the suitability of available transport resources and information regarding the design and upgrade of new or 8

9 existing transportation resources; describe how the raw materials and products will be transported to and from the complex and port facilities; - Description of proposed buildings, equipment and other facilities including site access and exits, services access, buffer areas, staff and visitor car parks, landscaping and beautification proposals, distances to boundaries include detailed concept and layout plans; - A breakdown of the labour force, types and levels of employment, and number of employees anticipated to be required during the construction and operational phases of the project; the length of time positions will be available for, and from where they are expected to be sourced, needs to be specifically stated; also provide details on the amount of foreign expertise that will be brought in for the project; - A breakdown of individuals with the skill sets available in the south-west area who are likely to gain employment in the construction and operation phases of the plant; Detailed analysis of the soil structure and the types of sewage treatment facility that will suit this type of soil; description of the proposed process and expected composition of wastewater discharges where applicable; comparison studies of the suitable systems identified based on this analysis, and justification for the final choice. Description of the activities relating to plant site preparation and construction of the smelter, anode-making facilities, and intermediate/downstream fabricating facilities; this is to include proposals to reduce runoff from the site onto roadways, riverine and marine environments including natural measures such as riparian borders; Description of the activities relating to operations and maintenance of the smelter, anodemaking facilities, and intermediate/downstream fabricating facilities, including the proposed manner of disposal of hazardous waste generated, or materials used by the plant; Description of proposals for the decommissioning of the smelter, anode-making facilities and intermediate/downstream fabricating facilities; include replacement by alternative proposals and details of disposal of all hazardous materials; Proposed scheduling of the project, including construction sequence for the smelter, anode plant and intermediate/downstream fabricating facilities. Construction and commissioning schedule for associated power plant, port facilities and infrastructural elements of the proposed estate should also be indicated; Description of other existing, approved and ancillary projects in sufficient detail to allow for assessment of cumulative impact. 2.4 Description of the Environment 9

10 Conduct a review of recent studies undertaken to determine the current status of data and information on the study area as they relate to the current physical, biological and socio-economic environments. These studies are to be listed in the Bibliography, and any data derived from these studies is to be referenced. Information for applications for proposed development in the area may be accessed from the Public Registers of the Town and Country Planning Division by visiting the relevant office (in this instance the South Regional Office) and requesting to see the map and book of registers. If Alcoa should undertake additional site-specific field studies so that a comprehensive description of the human and natural environment could be provided (see Appendix 1), such studies must cover the study area as defined in section 2.1 above. Include changes that may occur before your project commences in light of previous, ongoing or future activities that could reasonably be determined to have a combined effect. Sufficient detail is needed to allow a clear understanding of the likely negative impacts of the proposal, and to assess the effectiveness of any proposed mitigation measures. An examination of any positive impacts should also be included to ensure a comprehensive assessment as possible. Adequate spatial and temporal samples shall be taken to ensure a proper assessment of baseline conditions. Details of the study area should include the following: Physical environment Climate, Air Quality, Noise and Light A description, (representative of meteorological data for the area) of the wind regime of the area, including wind speed and direction; prevailing wind conditions, seasonal variations and storm conditions. Rainfall in the area, including seasonal variations; Air Temperature and Relative Humidity; Air Quality - describe, assess and discuss appropriate ambient air quality parameters associated with expected emissions of this type of facility, including but not limited to the ambient concentration of nitrogen oxides (NO x ), sulphur dioxide (SO 2 ), total particulate matter (PM), particles less than 10µm (PM 10 ), particles less than 2.5µm (PM 2.5 ), heavy metals in the PM, carbon monoxide (CO), hydrogen sulphide (H 2 S), hydrogen fluoride (HF), VOCs, ozone (O 3 ); Noise assess and discuss baseline noise level conditions; 10

11 Light assess and discuss baseline light conditions at the site. Geology and Soils Geology and soil characteristics of the site including, but not limited to; - Describe and map the soil types and their distribution in the study area; - Assess the soil capability classes for the relevant land use (discuss in context of the ability of the site to support the level of infrastructure and development); - Describe baseline soil quality analyse for ph, total organic and total inorganic carbon, fluorides, perfluorocarbons, petroleum hydrocarbons, polycyclic aromatic hydrocarbons, dioxins, furans, and metals and other parameters that will be expected to be used, produced or discharged by the facility; - Assess the suitability of the substrata of the study area for load bearing, particularly in the context of the site s ability to support proposed structures and operational activity; - Describe past and potential tectonic activity; - A detailed geological investigation, involving the mapping of the water-bearing strata on the northern limb of the Erin Syncline should be undertaken, and a correlation analysis conducted with data obtained from the geological investigation and historic data (available from the Ministry of Energy and Energy Industries, the Water Resources Agency and other sources). This correlation would establish whether there is hydraulic connectivity between the water-bearing strata on either side of the Erin Syncline; Topography; a topographical map that clearly shows the elevation patterns at the site and zone of impact, in order to determine the amount of cutting and filling which will be required to develop the site. Aquatic Environment Surface Hydrology and Drainage map and discuss the existing drainage patterns/characteristics of the site and wider study area, including the identification of outfall points and the dry season and wetflow rates of the watercourses; Groundwater including, but not limited to, such aspects as: - A discussion of the characteristics of the major aquifers and other ground waters in the study area, including area and volume capacity, and specifically whether they 11

12 are confined or unconfined. Map recharge areas of aquifers, where these occur in the study area. Assess extraction and recharge rates; - An inventory of groundwater uses and users in the study area; identify any groundwater use conflicts; - Assessment of groundwater quality in the area of the proposed project site; - Analyse ph, conductivity, dissolved oxygen, total suspended solids, chemical oxygen demand, biological oxygen demand, total petroleum hydrocarbons, dissolved fluorides, cyanide and metals, faecal coliform and other parameters that will be expected to be used, produced or discharged by the facility; Analysis should include assessment of seasonal variations, and comparison of findings with acceptable water quality standards; Surface Water Quality including, but not limited to, such aspects as: - Assessment of surface water quality at the proposed project site and the proposed discharge and main site outfall points (if any) of the plant(s) to the inland surface waters and receiving coastal environment; - Analyse temperature, ph, conductivity, dissolved oxygen, total suspended solids, chemical oxygen demand, biological oxygen demand, nutrients (ammonia, nitrates, nitrites, and phosphates), total petroleum hydrocarbons, dissolved fluorides, cyanide, metals, salinity, free chlorine and faecal coliform and other parameters that will be expected to be used, produced or discharged by the facility; - Analysis should include assessment of seasonal variations, and comparison of findings with acceptable water quality standards; Coastal and Nearshore Water Quality including, but not limited to, such aspects as: - Assessment of marine water quality in close proximity to the proposed project site and the proposed discharge and main site outfall points (if any) of the plant(s) to the receiving coastal environment; - Analyse temperature, ph, conductivity, dissolved oxygen, total suspended solids, biological oxygen demand, chemical oxygen demand, nutrients (ammonia, nitrates, nitrites, and phosphates), total petroleum hydrocarbons, dissolved fluorides, cyanide, metals, salinity and faecal coliform; 12

13 - Analysis should include assessment of seasonal variations, and comparison of findings with acceptable water quality standards; Marine processes modelling of coastal and offshore currents, as well as tides and other oceanographic processes that may affect the dispersion of liquid discharges to the sea Biological environment Use site-specific field surveys to assess the terrestrial, aquatic, intertidal and nearshore environments for impact prediction, and development of mitigation and monitoring programs. The sampling regime must be scientifically rigorous and statistically significant to allow for future comparisons. The use of participatory research techniques including Rapid Rural Appraisal should be employed in gathering some of this information, especially where it is relevant to community and individual use of the resources on the site. Life cycles, seasonality and migration of species should also be captured; Flora - map and describe the existing terrestrial, intertidal and aquatic (freshwater and marine) vegetation; provide information on plant species and communities that are present within the study area, including information on any rare or endangered plant species, and information on any specialised or unique plant communities that may be present. Plant communities should be mapped, and the area of any community type that may be lost due to project activities should be estimated; Fauna of the site and their use of the surrounding environments document and describe any species of wildlife including, but not limited to, amphibians, reptiles, birds, mammals and insects of economic importance, that are present within the study area; particular attention should be paid to bees and beekeeping and the spatial use of the site for this activity; Provide a detailed habitat assessment, including identification of resident species of all watercourses on site, especially those which will be altered by the project; Provide information on any aquatic habitat (including springs, streams, rivers, estuaries, ponds, lakes, wetlands, and the sea) that are present within the study area, as well as information on the characteristics and quantity of any aquatic habitat that may be affected or altered as a result of the project; Describe any freshwater and marine fisheries (whether commercial, subsistence, or recreational), including the species fished, landed weight or numbers, and estimated value, in the study area; 13

14 Identify and describe environmentally sensitive species in the study area; Identify and describe the species of commercial importance in the study area; Identify rare, threatened, endangered and endemic species; Itemize and describe the extent and benefits of the ecosystem services provided by the biodiversity on the site, in terms of provisioning, regulating and cultural services Socio-economic environment The EIA should trace a chain of cause and effect from a proposed decision on a project through anticipated economic or social changes, both positive and negative, resulting from the project, to physical changes caused in turn by economic or social changes. The intermediate economic or social changes need not be analysed in any detail greater than necessary to trace the chain of cause and effect. The focus of the analysis shall be on the physical changes. The requirement to link social and economic impacts to a physical impact will apply to the EMA's decision-making process. However, such a requirement may not apply to findings of significance, or decisions on the project that are to be made by other relevant regulatory bodies. The socio-economic environment shall be characterized by the collection, reporting and analysis of appropriate and sufficient information from relevant sources (including Census data, information from village councils, local government, community-based organizations, and community knowledge/asset information) and primary research. A socio-economic profile of the project area should be developed as part of the analysis including: employment and income, population and demography, housing, socio-economic well-being, and community assets including formal and informal social institutions and structures, and community capacity. The analysis should identify and describe aspects that have direct or indirect relationships to the natural environment. Identify the project s probable area of influence in terms of its potential positive and negative social, economic and cultural impacts. Map overlays (depicting existing settlements and landuse patterns as well as proposed project footprints including associated facilities such as roads etc.) should be used to provide a spatial portrayal of socio-economic data. Field studies should be undertaken to fully establish an appropriate social baseline, and to update information that may no longer be current. Appropriate data gathering methods shall be used commensurate with the level of detail required and/or risk to socio-economic components. The socioeconomic baseline shall include, but not be limited to, the following information: Data on household assets, formal and informal income strains, income streams and livelihood survival strategies, household composition and demography, health and 14

15 educational characteristics, skills of the labour force, vulnerable groups and the economic dependency on land and local resources; Information on the economic effects of the project including, but not limited to, the following: - The number and distribution of people who may be affected by the project; - Information on the economic status of the area; - Employment and labour market indicate opportunities for employment generation and the availability of such employment both locally and within the nearby communities; the availability of employment should be quantified and defined in terms of temporary vs. permanent, skilled vs. unskilled and availability during the different phases of the project (site preparation, construction, operational); also the number that will include foreign expertise needs to be specified; also assess the capability of the local population to participate in any employment opportunities afforded by the project; - The economic benefits of the projects to project affected communities as well as the wider national community. Information about the traditional, existing and proposed land use in the project s area of influence identified above, and the nature, size, location and duration of their potential interactions with the environment; land use should be described both for amenity and aesthetics, and in terms of its importance to cultural activities; Details of any proposals for the relocation of communities out of area affected by the proposed industrial activity; Customs, aspiration and attitudes indicate (by providing documentation) the acceptability of the proposed project to nearby communities and users of the area; Archaeological, cultural and historic value of the area. Special attention should be paid to settlement patterns and past, present and/or future programmes to relocate residents or communities from the site area Existing levels of contamination in the field 15

16 Point and non-point sources of pollution should be assessed to determine the type and extent of contamination in the concerned area. This includes identification of the location of any operating or abandoned oil or gas wells, dumping or other activity within the project location that may be a source of pollution. Samples shall be taken where appropriate to determine pollution levels for air, water (surface and ground) and soil. This data shall be mapped Health Baseline Assess the baseline health characteristics of the communities that are located in the zone of impact for the proposed project. Focus should be placed on the incidence of illnesses/ diseases among different groups within the community that may increase vulnerability to emissions from an aluminium smelter. 2.5 Legislative and Regulatory Considerations Describe all relevant local and international regulations, standards and guidelines that would apply to the proposed project including those governing environmental quality, health and safety, land use and other relevant regulations that require approvals. Some of these are identified in Section 1.3 above and should be expanded as appropriate. 2.6 Institutional and Financial Mechanisms Examine innovative mechanisms or Arrangements which may be utilised in the event of the following: Closure of the project before its scheduled life; Site remediation from contamination of soil or ground water during the life of the project. Unexpected health consequences arising out of upset conditions or any other unforeseen circumstances; Restoration of the site after decommissioning; Restoration of roads and other infrastructure after all stages of the project. Mechanisms for addressing the complexity of compliance monitoring by regulatory agencies must also be identified and evaluated. 2.7 Determination of the Potential Impacts of the Proposed Project Identify all impacts that could arise during the plant site preparation, construction and operation and decommissioning of the complex as a whole. Distinguish (where applicable) between negative and positive impacts, direct and indirect impacts, immediate, short-term, long-term impacts and 16

17 synergistic and cumulative impacts. To illustrate the significance, direct comparisons should be made between estimates of the potential impacts with the baseline conditions for given parameters. In those cases where negative impacts are known or expected to be significant, it is to the proponent s benefit to follow the impact hierarchy of avoidance, minimization, and mitigation in project planning. Avoidance of impacts (e.g. to sensitive areas such as wetlands) should be the first choice and is most beneficial to the proponent in economic terms. If significant impacts can be avoided, the costs and delays associated with mitigation planning and permitting are also avoided. If impacts cannot be entirely avoided, it is to the proponent's benefit to minimize impacts for the same reasons. Mitigation is the least desirable course of action because of the costs and delays related to mitigation planning, design, permitting and implementation, as well as potential for some measure of degradation to or loss of natural resources. Assess the cumulative environmental effects (i.e. considering existing, approved and ancillary projects) that are likely to result from the proposed facilities in combination with other existing, approved and proposed projects in the region that could reasonably be considered to have a combined effect (e.g. port facilities, power plant and other facilities that have been proposed for the area). The cumulative assessment must be based on an adequate understanding of the design and operation of ancillary facilities. Cumulative effects should be well defined and include a description of the study boundaries and other existing and proposed industrial projects, as well as activities associated with land use and infrastructure. Cumulative effects should either be described within a specific section of the EIA report on cumulative effects, or be well defined within each of the report s subsections on potential effects, as relevant. Potential impacts should also be described quantitatively as far as possible. The potential environmental effects from project accidents, malfunctions and upset conditions should also be explicitly assessed. Impacts should be categorised and illustrated using an appropriate format e.g. matrices. The proponent should also provide data from other existing facilities using the same technology to compare with, or assist in the prediction of, impacts for this proposed facility. A method of determination of impact significance should be clearly outlined including specific significance criteria that will allow the reader to understand the level of impact of the project on key ecological and socio-economic components. Areas of impact/hazards should be illustrated in map form, and those that are unavoidable or irreversible must be specifically identified. Significant changes to baseline conditions should also be quantified. Proposed mitigation measures to reduce adverse effects and measures to enhance benefits should be clearly described. A determination of impact significance should be provided for each key environmental or socio-economic component (by major phase or activity) considering the application of proposed mitigative measures (i.e. residual effect). A list of all proponent commitments for 17

18 mitigation, monitoring and follow-up measures should be clearly recorded and included in the Environmental Management Plan (refer to section 2.8 below). The potential impacts to be determined include, but are not limited to: Human beings including, but not limited to, such aspects as: - A Social Impact Assessment (SIA) should be conducted The SIA is a method of analysing what impacts a proposed project or action may have on the social aspects of the environment and how these social impacts may result in changes to public health and the physical environment. These aspects include, but are not limited to: The ways people cope with life through their economy, social systems, and cultural values; The ways people use the natural environment for subsistence, recreation, spiritual activities, cultural activities etc.; The ways people use the built environment for shelter, making livelihoods, industry, worship, recreation, gathering together, etc.; The ways communities are organised and held together by their social and cultural institutions and beliefs; Ways of life that communities value as expressions of their identity; Art, music, dance, language arts, crafts, and other expressive aspects of culture; A group s values and beliefs about appropriate ways of life, family and extra-family relationships, status relationships, means of expression, and other expressions of community; The aesthetic and cultural character of a community or neighbourhood it s ambience; The SIA would involve characterizing the existing state of such aspects of the environment, forecasting how they may change if a given project or alternative is implemented, and developing means of mitigating changes that are likely to be adverse from the point of view of an affected population. The analysis should present an understanding of how any proposed land use change/s as a direct or indirect result of the project may affect the area s environment and socio-economic dynamics. The SIA also represents an important basis for other elements of the EIA. It provides important information for the health risk assessment, the iterative design of effective public participation processes over the life course of the project, and for efforts at sustainable development and mitigation monitoring. 18

19 It is important that the SIA examine and predict, where feasible, impacts throughout the major phases of the project, including 1) site preparation 2) construction/implementation, 3) operation/maintenance and 4) decommissioning/abandonment or other forms of closure or shut down - partial or complete. It should also examine impacts of any potential future expansion of the facility or site or material changes. If not addressed in this EIA, it should be clearly stated that any such eventuality would trigger another environmental review. The SIA should also directly examine direct or indirect impacts on the social cohesion of the potentially impacted community/ies. Information from the early stages of the public participation process described in Section 2.10, and as specified above, should be employed to determine the appropriate indicators and geographic scales for measuring the social well-being and economic health baselines of the potentially impacted communities and their direct and indirect relationships to environmental quality. Information should also be collected for characterization of any recreation, small-scale agriculture, hunting, tourism, and fishing/angling as they relate to environmental quality, social well-being and economic health of the community. The analysis will present responses to questions such as: Would the project disrupt or adversely affect property/areas of cultural significance to the community or any given social group? Would the project induce substantial growth or concentration of population? Would the project cause an increase in traffic that is substantial in relation to the existing traffic load and capacity of the street system? Would the project displace a large number of people relative to the size of the population in the project area and its environs? Would the project disrupt or divide the physical arrangement of an established community? Would the project conflict with established recreational, educational, religious, or scientific uses of the area? Would the project convert prime agricultural land to a non-agricultural use or create a brownfield (polluted site) out of a greenfield (previously unpolluted) site? Would the project interfere with emergency response plans or emergency evacuation plans? - Social impact as it relates to: local employment and training, local procurement, vulnerable groups (youth and elderly, handicapped, squatters etc.), transport, health services, security, lifestyle and culture; the potential for unplanned settlements, overloading of municipal infrastructure, and social conflict between workers and communities; 19

20 - Impact of the project on the road conditions in the area discuss proposed mitigation measures to maintain roads during the construction period, and restorative and maintenance works on roads after completion; - The potential loss of earnings to traditional users of the area e.g. hunters, farmers, tour operators; - Changes in emergency response time and capability as a result of increase in demand on the available resources (fire services, police, EHS, etc.); - Changes in domestic supply of services as a result of increase in demand on existing utilities (water and electricity) in the area; - The temporary or permanent dislocation/relocation of residents, public facilities, community centres and other facilities regularly used by the community; - The impact of the project on foreign exchange earnings; - The documentation of health, safety and environmental concerns raised by stakeholders during the consultation on the project; Flora and fauna including, but not limited to, such aspects as: - Impacts on terrestrial and aquatic habitat use, and ecology; - Impacts on sensitive species including endangered and commercially exploited; - Expected changes in health of flora and fauna with the introduction of the activity; - Any expected changes in the quantity and type of species existing in the study area; - Impacts on biodiversity / ecosystem services; Water (surface and ground) quality including, but not limited to, such aspects as: - The impact of discharges (sewage and any possible process) on the ambient water quality; the cumulative impacts of continuous/long-term discharge at the proposed site outfall point(s) of the project site; - Impact on the water requirements during worst-case conditions and emergency operating conditions; discuss the availability and source of water in the event of these occurrences; - Effect of site runoff on surface water quality; the potential for contamination of groundwater from any aspect of the proposed processes; and potential for this 20

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