ENHANCING SIERRA LEONE ENERGY ACCESS PROJECT - ESCP Republic of Sierra Leone Ministry of Energy & Energy Distribution and Supply Authority Enhancing Sierra Leone Energy Access Project (P171059) Draft ENVIRONMENTAL and SOCIAL COMMITMENT PLAN (ESCP) November 14, 2020 2|Page ENHANCING SIERRA LEONE ENERGY ACCESS PROJECT - ESCP ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN 1. The Republic of Sierra Leone (the Recipient) will implement the Enhancing Sierra Leone Energy Access Project (the Project), with the involvement of the Ministry of Energy (MOE) and the Electricity Distribution and Supply Authority (EDSA). The International Development Association (the Association) has agreed to provide financing for the Project. 2. The Recipient will implement material measures and actions so that the Project is implemented in accordance with the Environmental and Social Standards (ESSs). This Environmental and Social Commitment Plan (ESCP) sets out material measures and actions, any specific documents or plans, as well as the timing for each of these. 3. The Recipient will also comply with the provisions of any other E&S documents required under the ESF and referred to in this ESCP, such as Environmental and Social Management Plans (ESMP), Resettlement Action Plans (RAP), and Stakeholder Engagement Plans (SEP), and the timelines specified in those E&S documents. 4. The Recipient is responsible for compliance with all requirements of the ESCP even when implementation of specific measures and actions is conducted by the Ministry, agency or unit referenced in 1. above. 5. Implementation of the material measures and actions set out in this ESCP will be monitored and reported to the Association by the Recipient as required by the ESCP and the conditions of the legal agreement, and the Association will monitor and assess progress and completion of the material measures and actions throughout implementation of the Project. 6. As agreed by the Association and the Recipient, this ESCP may be revised from time to time during Project implementation, to reflect adaptive management of Project changes and unforeseen circumstances or in response to assessment of Project performance conducted under the ESCP itself. In such circumstances, the Recipient or MOE will agree to the changes with the Association and will update the ESCP to reflect such changes. Agreement on changes to the ESCP will be documented through an exchange of letters signed between the Association and the Recipient or MOE. The Recipient or MOE will promptly disclose the updated ESCP. 7. Where Project changes, unforeseen circumstances, or Project performance result in changes to the risks and impacts during Project implementation, the Recipient shall provide additional funds, if needed, to implement actions and measures to address such risks and impacts, which may include risks and impacts that are relevant to the Project, such as environmental, health, and safety impacts, labor influx, gender- based violence. 2|Page ENHANCING SIERRA LEONE ENERGY ACCESS PROJECT - ESCP MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY/AUTHORITY MONITORING AND REPORTING A REGULAR REPORTING Prepare and submit to the Association regular monitoring reports on the Quarterly after effectiveness and Component 1: EDSA environmental, social, health and safety (ESHS) performance of the throughout Project implementation Component 2: MoE Project, including but not limited to the implementation of the ESCP, Component 3 (a): MoE status of preparation and implementation of E&S documents required Component 3 (b): EDSA under the ESCP, corrective and preventive measures taken or required to be taken to address such conditions, stakeholder engagement activities, functioning of the grievance mechanism.. B INCIDENTS AND ACCIDENTS Promptly notify the Association of any incident or accident related to the Notification to the Association within 48 Component 1: EDSA Project which has, or is likely to have, a significant adverse effect on the hours after learning of the incident or Component 2: MoE environment, the affected communities, the public or workers, including accident. Component 3 (a): MoE but not limited to incidents involving fatalities or serious bodily harm and Component 3 (b): EDSA incidents such as fire injuries, physical violence, Sexual Exploitation and Subsequent incident report submitted Abuse and Sexual Harassment (SEA/SH), construction accident, within a timeframe acceptable to the communicable diseases and infections. The notification will include as Association. much detail as is available at the time of notification concerning the incident or accident, indicating immediate measures taken to address it, and including information provided by any contractor and supervising entity, as appropriate. Subsequently, as per the Association’s request, prepare a report on the incident or accident and propose any measures to prevent its recurrence. C CONTRACTORS MONTHLY REPORTS Require contractors to provide monthly monitoring reports, including on Monthly reports to the MOE/EDSA. Component 1: EDSA ESHS issues, to MOE/EDSA. Submit those reports to the Association upon Submission to the Association upon request. Component 2: MoE request. Component 3 (a): MoE Component 3 (b): EDSA ESS 1: ASSESSMENT AND MANAGEMENT OF ENVIRONMENTAL AND SOCIAL RISKS AND IMPACTS 3|Page ENHANCING SIERRA LEONE ENERGY ACCESS PROJECT - ESCP 1.1 ORGANIZATIONAL STRUCTURE Establish and maintain project Management unit (PMU) at MOE and Unless otherwise agreed in writing with the MOE & EDSA Health, Safety, Social and Environment unit (HSSE) at EDSA with qualified Association, fully functional PIUs (with full staff and resources to support management of E&S risks at each complement of staff) must be established implementing agency in accordance with the following terms. not later than three (3) months from the Effective Date or any later date as may be For Project Components 2 and 3(a): agreed with the Association. The existing Project Management Unit (PMU) for the Energy Sector Utility Reform Project (ESURP), which is also financed by the World Bank, may be used. MOE shall build on the ESURP PMU by maintaining an organizational structure with the following specialists: (i) a procurement specialist; (ii) a contract management specialist; (iii) a financial management specialist; (iv) engineer(s) specialized in renewable energy; (v) an environmental and safeguard specialist (with expertise in SEA/SH risks and impacts); (vii) a monitoring and evaluation specialist; and (viii) a communications specialist (with expertise in stakeholder engagement), For Project Components 1 and 3(b): EDSA currently has a Project Management Team (PMT) that is implementing the investment component of ESURP. EDSA shall build on the ESURP PMT by maintaining an organization structure with the following specialists: (i) a procurement specialist; (ii) a contract management specialist; (iii) a financial management specialist; (iv) engineer specialized in renewable energy; (v) an environmental safeguard specialist; (vi) a social and gender specialist (with expertise in SEA/SH risks and impacts; (vii) a monitoring and evaluation specialist; and (viii) a communications specialist (with expertise in stakeholder engagement), The PIUs shall be supported by experienced consultants to assist in project implementation and in building the capacity of the regular EDSA staff. 3|Page ENHANCING SIERRA LEONE ENERGY ACCESS PROJECT - ESCP MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY/AUTHORITY 1.2 ENVIRONMENTAL AND SOCIAL ASSESSMENT Project activities will be screened and assessed for environmental Throughout Project implementation Component 1: EDSA and social (E&S) risks and impacts in accordance with the ESSs and Component 2: MoE the Environmental and Social Management Framework (ESMF) Component 3 (a): MoE and Resettlement Framework (RF) prepared for this Project, in a Component 3 (b): EDSA manner acceptable to the Association. Based on the screening and assessment results, detailed environmental and social assessments shall be conducted, as required based on the nature and scale of the activity and its potential environmental and social risks and impacts. ESMPs, RAPs and such other E&S instruments as this ESCP requires shall be developed and implemented to address any risks identified during the process. This screening, assessment, and mitigation process shall be comprehensive to address waste management and pollution, labor, SEA/SH risks, social diversity and gender, and impacts on vulnerable and disadvantaged groups or individuals, among other relevant risks and impacts. 3|Page ENHANCING SIERRA LEONE ENERGY ACCESS PROJECT - ESCP 1.3 MANAGEMENT TOOLS AND INSTRUMENTS a. Prepare, adopt, disclose, and implement a Stakeholder a. ESMF, SEP, RF will be approved Component 1: EDSA Engagement Plan (SEP), Environmental and Social by the Association prior to Component 2: MoE appraisal. Component 3 (a): MoE Management Framework (ESMF) and a Resettlement Component 3 (b): EDSA Framework (RF) in a manner acceptable to the Association. The ESMF shall include Screening Forms to be b. Throughout Project used to screen all sub-projects to determine whether implementation. No ESIAs, ESMPs, RAPs, and other E&S instruments must be construction or rehabilitation prepared and implemented prior to sub-project may begin before required implementation. permits are obtained. b. Secure environmental permits for all new construction and rehabilitation under the Project. c. Throughout Project implementation. No works may begin before ESMPs, RAPs and c. Prepare, disclose, adopt, and implement an ESMP, RAP other E&S instruments are in and/or any other E&S instruments required for the place. respective subproject activities, based on the assessment process, in accordance with the ESSs, the ESMF, the EHSGs, and other relevant Good International Industry d. Manual to be completed by Practice (GIIP) in a manner acceptable to the Association. Project effectiveness and implemented throughout Project implementation. d. Project Implementation Manual: Include the E&S requirements into the Project Implementation Manual. At the minimum, the Manual will describe: • The roles of Environment and Social (E&S) officers • The minimum E&S clauses to be included in the Terms of Reference and tender documents • Incorporation of E&S indicators into Monitoring and Evaluation system • Completion timeline 3|Page ENHANCING SIERRA LEONE ENERGY ACCESS PROJECT - ESCP MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY/AUTHORITY 1.4 MANAGEMENT OF CONTRACTORS Manage contractors and subcontractors to ensure that they Integration of E&S provisions prior to Component 1: EDSA comply with the ESSs and this ESCP. Incorporate the relevant issuing of procurement documents Component 2: MoE aspects of this ESCP, including, inter alia, any environmental and Component 3 (a): MoE social management plans or other instruments, ESS2 Component 3 (b): EDSA Supervision of contractors and requirements, and any other required ESHS measures, into the subcontractors throughout Project ESHS specifications of the procurement documents and contracts implementation. with contractors and supervising firms. Thereafter ensure that the contractors, subcontractors, and supervising firms comply with the ESHS specifications of their respective contracts. Ensure in particular that: • Codes of conduct are required of contractors and subcontractors and their workers to prohibit sexual harassment and exploitation and training of workers on their obligations under the Code of conduct • Contractor ESMP (C-ESMP) is costed, with sufficient budget to mitigate E&S risks • Contractor and subcontractor commitment and compliance with the ESSs and this ESCP is monitored • Contractors provide details on contractor’s oversight on environmental, social, health and safety (ESHS) performance • Contractor develops a grievance redress mechanism to handle concerns of their personnel, consistent with ESS2. 3|Page ENHANCING SIERRA LEONE ENERGY ACCESS PROJECT - ESCP MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY/AUTHORITY 1.5 THIRD PARTY MONITORING Independent third-party monitoring agent(s) shall be appointed At least semi-annually throughout Component 1: EDSA prior to construction commencement under the Project. The PIUs Project implementation Component 2: MoE (EDSA and MOE) shall share Project monitoring reports with the Component 3 (a): MoE third-party monitoring agents for validation. These reports will Component 3 (b): EDSA outline safeguard compliance using site-specific ESMPs/ESIAs and RAPs if prepared. The independent third-party monitors shall check: (i) whether the ESMF is being correctly adhered to; (ii) whether appropriate mitigation measures have been identified and implemented effectively in accordance with this ESCP and whether these need to be adjusted to reflect changing circumstances and; (iii) the extent to which all stakeholder groups are involved in sub-project implementation. The third-party monitoring reports shall be submitted to the Association as part of the Recipient’s reporting under Section A of this ESCP . ESS 2: LABOR AND WORKING CONDITIONS 3|Page ENHANCING SIERRA LEONE ENERGY ACCESS PROJECT - ESCP MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY/AUTHORITY 2.1 LABOR MANAGEMENT PROCEDURES Develop, adopt, and disclose Labor Management Procedures Labor Management Procedures will be MOE & EDSA (LMP) for the Project as part of the ESMF, consistent with ESS 2 part of ESMF that will be prepared and and national law. submitted to the Association for approval before appraisal. The LMP shall set out the way in which Project workers will be managed, in accordance with the requirements of Sierra Leone Apply these Procedures throughout national laws and ESS 2. The LMP shall address the way in which Project implementation. ESS 2 will apply to different categories of Project workers including, inter alia, implementing adequate occupational health and safety measures, setting out grievance arrangements for project workers, and requirements for contractors to manage their workers. The LMP shall be referenced in the ESHS specifications of the procurement documents with obligations for contractors to comply with its requirement. 2.2 GRIEVANCE MECHANISM FOR PROJECT WORKERS Grievance mechanism to be operational MOE & EDSA Establish, maintain, and operate a Project GRM which shall be prior to recruitment of workers and available to Project workers, including PMU and HSSE staff, as implemented throughout Project described in the LMP and consistent with ESS2. This shall be implementation. approved by the PIUs and the Association. 2.3 OCCUPATIONAL HEALTH AND SAFETY (OHS) MEASURES Prepare, adopt, and implement occupational, health and safety Prior to implementation of the ESMPs MOE & EDSA (OHS) measures specified in the ESMPs. and C-ESMPs. Ensure that contractors also prepare OHS plans, as part of Maintained throughout Project Contractor ESMPs (C-ESMPs), before their mobilization for implementation approval by PIU. 3|Page ENHANCING SIERRA LEONE ENERGY ACCESS PROJECT - ESCP MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY/AUTHORITY 2.4 EMERGENCY PREPAREDNESS AND RESPONSE a. Prepare, adopt and implement Project emergency preparedness a. Before construction commencment a. MOE and EDSA and response plan. The Project emergency preparedness and and maintained throughout Project response plan shall be approved by the Association. implementation b. Require contractors to adopt, implement, and update as b. Prior to contractor mobilizing to site b. Component 1: EDSA necessary emergency preparedness and response protocols and maintained throughout Project Component 2: MoE consistent with the MOE/EDSA Project emergency plan. These implementation Component 3 (a): MoE contractor plans shall be approved by the PMU and HSSE and the Component 3 (b): EDSA Association. c. Require contractors to regularly complete safety drills for c. Throughout Project implementation c. MOE, EDSA, Contractors workers, and emergency preparedness training in accordance with the governing emergency preparedness and response plan. ESS 3: RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT 3.1 WASTE MANAGEMENT PLAN: a. Assess potential solid, hazardous, non-hazardous and electronic a. Before construction commencemnt a. MOE, EDSA waste that will be generated from this Project. Subsequently, and subject to review and approval by prepare, adopt, and implement a comprehensive Waste the Association. Management Plan consistent with ESS3. b. Each sub-project ESMP shall assess and incorporate a sub- b. Contractors project Waste Management Plan based on the comprehensive b. Plan to be adopted before sub-project Waste Management Plan. works begins and implemented throughout sub-project implementation. 3.2 RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT: Resource efficiency and pollution prevention and management Throughout Project implementation MOE and EDSA measures to be adopted under the ESMP to be prepared under action 1.3 above. 3|Page ENHANCING SIERRA LEONE ENERGY ACCESS PROJECT - ESCP ESS 4: COMMUNITY HEALTH AND SAFETY 4.1 TRAFFIC AND ROAD SAFETY: Require Project contractors to develop and implement measures Throughout Project implementation MOE and EDSA and actions to assess and manage traffic and road safety risks as required in the ESMPs to be developed under action 1.3 above. 4.2 COMMUNITY HEALTH AND SAFETY: a. The Project ESMF shall require the contractors to develop and a. Same timeframe for the preparation a. MOE, EDSA and Contractors include in the sub-project ESMPs adequate measures and actions and implementation of ESMPs and to assess and manage risks and impacts specific to the community maintained throughout Project and beneficiary arising from Project activities. These will include, implementation inter alia, measures to minimize the potential for community exposure to the COVID-19 disease, accidents and pollution, abuse by Project workers, risks of labor influx, accidents and other emergencies (e.g., a fire response or natural disaster), sexual exploitation and abuse, sexual harassment. These measures will include mechanisms to protect individuals or groups who, because of their particular circumstances, may be disadvantaged or vulnerable, and ensure access to the development benefits resulting from the Project. b. Ensure that contractor measures, and work methods are b. Prior to start of works b. MOE, EDSA, Contractors and Local validated by the local authorities and approved by the PMU and Authorities HSSE. 3|Page ENHANCING SIERRA LEONE ENERGY ACCESS PROJECT - ESCP 4.3 GBV AND SEA RISKS: a. Project to hire a local NGO to assist in GBV risk prevention and a. Submit the GBV Action Plan for the a. EDSA and MOE response. Through a Project GBV Action Plan, develop and Association’s approval before the implement measures and actions to assess and manage the risks preparation of the procurement of gender-based violence (GBV) and sexual exploitation and abuse documents. Once approved, implement (SEA) related to the Project. The GBV Action Plan shall be made Plan throughout Project available to the public, including to make community members implementation aware of Project risks and reporting mechanisms. b. Prior to start of works and throughout b. Workers and communities shall be sensitized through frequent Project implementation b. EDSA, MOE and contractors toolbox talks and community consultations. 4.4 GBV AND SEA RISKS DURING PROJECT IMPLEMENTATION : a. Each sub-project ESMP shall include a GBV Action Plan for a. GBV Action Plan to be in place by a. EDSA, MOE and Contractors addressing GBV and SEA risks based on the Project GBV Action Plan contractor mobilization to site and prepared under 4.3 above. This Plan shall include worker-related maintained throughout Project codes of conduct to be integrated in the LMPs. Additional implementation measures shall be developed as necessary during Project implementation. b. Ensure that contractors require workers to strictly abide by the measures and workers code of conducted. b. Throughout Project implementation b. EDSA, MOE and Contractors 4.5 SECURITY PERSONNEL: No security personnel may be employed on the Project without the prior written consent of the Association. ESS 5: LAND ACQUISITION, RESTRICTIONS ON LAND USE AND INVOLUNTARY RESETTLEMENT 3|Page ENHANCING SIERRA LEONE ENERGY ACCESS PROJECT - ESCP 5.1 RESETTLEMENT PLANS: Prepare, adopt, and implement resettlement plans (RAPs) in Resettlement Action Plans to be EDSA, MOE and Contractors accordance with ESS 5 and consistent with the requirements of submitted for the Association’s the Resettlement Policy Framework (RPF) that has been prepared approval, and once approved, for the Project, and thereafter adopt and implement the implemented before Project activities respective RAPs before carrying out the associated activities, in a involving land acquisition and manner acceptable to the Association. resettlement may commence. 5.2 MONITORING AND REPORTING ON RESETTLEMENT IMPLEMENTATION Submit Quarterly reports no later than MOE and EDSA Prepare and submit to the Association regular monitoring reports the last day of each quarter. on the implementation of resettlement activities, including status of preparation and implementation of resettlement documents Throughout Project implementation required under the ESCP, PAP engagement activities, functioning of resettlement related grievance mechanisms. ESS 6: BIODIVERSITY CONSERVATION AND SUSTAINABLE MANAGEMENT OF LIVING NATURAL RESOURCES 6.1 BIODIVERSITY RISKS AND IMPACTS: a. Include in the ESMF procedures for screening project activities a. Throughout Project implementation a. MOE and EDSA that may pose risks to biodiversity, in accordance with ESS6. b. If required, prepare, adopt, and implement as part of ESMPs b. Submit for the Bank’s prior approval b. MOE and EDSA biodiversity protection measures, including as appropriate a prior to initiation of activity that may stand-alone Biodiversity Management Plan, in accordance with affect biodiversity. Once approved, the ESS6 and the ESMF, and in a manner acceptable to the Association. plan shall be implemented throughout Project implementation. ESS 7: INDIGENOUS PEOPLES/SUB-SAHARAN AFRICAN HISTORICALLY UNDERSERVED TRADITIONAL LOCAL COMMUNITIES 7.1 INDIGENOUS PEOPLES PLAN: Not relevant. There are no distinct Not relevant Not relevant social and cultural groups in the Project area who exhibit characteristics meeting the criteria for indigenous or traditionally under-served communities as spelled out in the ESS7. 3|Page ENHANCING SIERRA LEONE ENERGY ACCESS PROJECT - ESCP ESS 8: CULTURAL HERITAGE 8.1 CHANCE FINDS: Identify cultural heritage sites prior to Throughout Project implementation MOE, EDSA and Contractors construction. Prepare and implement a Chance Find Procedure to guide treatment of impacted cultural heritage resources. Relevant aspects of this standard shall be integrated, as needed, under action 1.3 above. A Chance Find procedure will be part of the ESMF. ESS 9: FINANCIAL INTERMEDIARIES 9.1 ESMS: Not relevant Not relevant Not relevant ESS 10: STAKEHOLDER ENGAGEMENT AND INFORMATION DISCLOSURE 10.1 STAKEHOLDER ENGAGEMENT PLAN PREPARATION AND Draft SEP to be finalized prior to MOE and EDSA IMPLEMENTATION appraisal and implemented throughout Project implementation. Prepare, disclose, adopt, and implement the Stakeholder Engagement Plan (SEP) prepared for the Project. 10.2 PROJECT GRIEVANCE MECHANISM: Grievance Mechanism to be MOE and EDSA operationalized by Project effectiveness Develop, maintain, and operate a Project level grievance and maintained throughout Project mechanism (GM) to receive and address complaints related to the implementation Project, including but not limited to those related to resettlement, consistent with ESS10. The GM shall be described in the RPF, RAPs and SEP. The GM will incorporate digital platforms and existing GRM systems in place at the MOE/EDSA and the local level. CAPACITY SUPPORT (TRAINING) 3|Page ENHANCING SIERRA LEONE ENERGY ACCESS PROJECT - ESCP CS1 Based on E&S Capacity Assessment, the following types of training Annual training plan shall be submitted MOE, EDSA and External Consultant(s) will be provided to the relevant target groups, such as PIU staff, to the Association for approval to guide stakeholder community, project workers, consultants, training and capacity building. All staff contractors, sub-contractors: must complete the trainings and refreshers on the timeframes specified • Orientation training to staff of EDSA, PIU and MOE on the in the annual plan. World Bank ESF and its implementation modality (screening, scoping etc.) • Training to EDSA and MOE PIU staff on ▪ Issues of Land acquisition and involuntary resettlement, ▪ Issues of vulnerable and disadvantaged people and about Free Prior Inform Consent (FPIC), ▪ ESIA and RAP ▪ Occupational health and safety, community health and safety, (including emergency prevention, preparedness and response arrangements), ▪ GBV/SH/SEA awareness, prevention, reporting and management protocols ▪ Waste management, ▪ Labor Management Plan and related procedures, ▪ Cultural heritage management ▪ Traffic and road safety, ▪ Consultant Procurement and Contract Management, ▪ Management of Construction Impacts ▪ Additional training will be identified during Project implementation 3|Page