The World Bank ECOWAS - Battery Energy Storage Systems and Synchronization (BE3S) Project (P167569) Concept Environmental and Social Review Summary Concept Stage (ESRS Concept Stage) Public Disclosure Date Prepared/Updated: 10/21/2019 | Report No: ESRSC00534 Oct 21, 2019 Page 1 of 10 The World Bank ECOWAS - Battery Energy Storage Systems and Synchronization (BE3S) Project (P167569) BASIC INFORMATION A. Basic Project Data Country Region Project ID Parent Project ID (if any) Western Africa AFRICA P167569 Project Name ECOWAS - Battery Energy Storage Systems and Synchronization (BE3S) Project Practice Area (Lead) Financing Instrument Estimated Appraisal Date Estimated Board Date Energy & Extractives Investment Project 2/20/2020 6/9/2020 Financing Borrower(s) Implementing Agency(ies) Ministry of Finance, Ministry of Energy, Ministry Federal Republic of of Energy Nigeria, Republic Of Ghana, Republic of Cote d'Ivoire Public Disclosure Proposed Development Objective(s) The PDO of the project is to increase ECOWAS power system capability to secure synchronous operation and enable renewable energy penetration. Financing (in USD Million) Amount Total Project Cost 259.80 B. Is the project being prepared in a Situation of Urgent Need of Assistance or Capacity Constraints, as per Bank IPF Policy, para. 12? No C. Summary Description of Proposed Project [including overview of Country, Sectoral & Institutional Contexts and Relationship to CPF] The proposed project will provide support to finance equipment and to develop the soft components required for the operation of the regional power pool in West Africa. The proposed project aims to provide equipment (voltage control, frequency control, communications, SCADA) required to operate the power system in a synchronous manner. In addition, the project will finance the technical assistance for the key entities in charge of the operation of the system, namely, the regional regulator ERERA and the system operator, ICC. Oct 21, 2019 Page 2 of 10 The World Bank ECOWAS - Battery Energy Storage Systems and Synchronization (BE3S) Project (P167569) D. Environmental and Social Overview D.1. Project location(s) and salient characteristics relevant to the ES assessment [geographic, environmental, social] The proposed project will provide support to finance equipment and to develop the soft components required for the operation of the regional power pool in West Africa. The proposed project aims to provide equipment (voltage control, frequency control, communications, SCADA) required to operate the power system in a synchronous manner. In addition, the project will finance the technical assistance for the key entities in charge of the operation of the system, namely, the regional regulator ERERA and the system operator, ICC. The project aims at financing the equipment to ensure synchronization of the systems, and building regional institutions for power trade under ECOWAS (Regional regulator-ERERA and information coordination Center-ICC). The key activity of the project involves battery installation within existing substations. It is reported that no project activities will be carried out outside the fence line of existing substations. The project does not include civil works, except for the unloading and connection of the batteries to the networks. This will be replicated in Nigeria, Ghana and Cote ’d Ivoire sites. The potential areas for the project are in Kaduna in Nigeria, Ferkessedougou and Bouaken in Cote d’Ivoire and Dunkwa and Kumasi in Ghana, but the specific locations for the implementation of the project activities is not yet decided. The project will be prepared in close collaboration with national Governments and ECOWAS. The ECOWAS Regional Electricity Regulatory Authority (ERERA) is the regulator of regional cross-border trade of electricity and the regional regulator of cross border electricity interconnections in West Africa. The Member States of ECOWAS in January 2008 Public Disclosure established the ECOWAS Regional Electricity Regulatory Authority (ERERA) as a specialized institution of ECOWAS. The project will be implemented by the Regional Coordination Unit (PCU) under the ECOWAS Directorate of Energy, created for the ECOWAS Electricity Access Project, which has a qualified team. The role of the ECOWAS-RCU in the project implementation will be to provide a convening platform for coordination among regional entities and national participants, to provide relevant technical assistance to regional and country teams as deemed necessary, and support for procurement, monitoring, knowledge management, and communication. Each country will be supported by a national project implementation unit (PIU). Experienced national entities will be selected using criteria such as existing Bank funded PIUs showing proven adequate fiduciary capacities, which will be re-assessed. Each PIU will be responsible for the (i) planning of the works, (ii) supervision and monitoring/control of the project activities, (iii) administrative and financial management. The capacity to assess and manage the E&S risks will be further assessed during appraisal. ECOWAS is the main implementation unit for this project that will receive funding from the World Bank. ECOWAS through its PCU will implement the project in each of the countries along with the national units. D. 2. Borrower’s Institutional Capacity As mentioned, ECOWAS PCU will provide the overall guidance and oversight for the individual projects. The PCU will establish the coordination framework for the project and will enable a sustained communication with and among Program stakeholders through stakeholder consultations at the national and regional levels to support all components. Oct 21, 2019 Page 3 of 10 The World Bank ECOWAS - Battery Energy Storage Systems and Synchronization (BE3S) Project (P167569) ECOWAS has implemented other projects with other donors like AFDB and have received funding from the World Bank before and are familiar with World Bank OP standards. The PCU of ECOWAS has dedicated environmental and social specialists from previous projects. However the requirements of the ESF like stakeholder engagement, management of labor risks/contractors, focus on prevention of Gender based Violence (GBV) are new aspects which the agency does not have the experience. Therefore the PCU will require capacity building on ESF requirements. II. SCREENING OF POTENTIAL ENVIRONMENTAL AND SOCIAL (ES) RISKS AND IMPACTS A. Environmental and Social Risk Classification (ESRC) Moderate Environmental Risk Rating Moderate The environmental risk classification for the Project is moderate under the World Bank ESF, based on the nature and scale of the project activities, however the specific information on subprojects such as location and number of subprojects remain uncertain. The risk rating will be revisited when more details are known on the subprojects. The main work will be installation of battery within current boundaries of electrical installations. The environmental risks anticipated are mainly: (i) fire and explosion risks during project operation, (ii) environmental hazards related to the disposal of used batteries containing hazardous waste, (iii) disposal and management of generic waste during the construction and exploitation phase, (iv) occupational health and safety of workers, (v) nuisances related to air and Public Disclosure noise emissions, and (vi) community health and safety. However, majority of the impacts likely to be generated from the project activities are site-limited and can be mitigated with measures that are readily identifiable. Social Risk Rating Moderate The key activities proposed under the project include installation of batteries within the fence line of existing sub stations in Nigeria, Ghana and Cote d’Ivoire. The potential areas for the project are in Kaduna in Nigeria, Ferkessedougou/Bouaken in Cote d’Ivoire and Dunkwa/Kumasi in Ghana. It is reported that there are no large communities in the immediate vicinity of the potential sub stations being considered by the project developer. Overall the potential impacts are likely to be site specific and mitigation measures are available for the same. There is no civil works or expansion of substations expected which may lead to land acquisition that could adversely affect peoples assets, community properties and resources and pose other risks to communities. There will be limited number of contractors required for the installation of batteries with a small number of skilled workforce brought into the project areas. However since this is a regional project which spans three countries, contextual country related risks may arise during project implementation such as risks to contractor labor working in conflict areas/low security zones. Similarly the introduction of the skilled contractor workforce however small may heighten risks of GBV/sexual exploitation and the spread of communicable diseases to and from local communities. Currently the total number of substations and contractors/workers per country is not known and if installation work takes place in a number of substations simultaneously then the cumulative impacts of the project are heightened. Oct 21, 2019 Page 4 of 10 The World Bank ECOWAS - Battery Energy Storage Systems and Synchronization (BE3S) Project (P167569) Further, ECOWAS lacks adequate experience in implementing the ESF in totality and are new to certain requirements like labor risks, GBV and stakeholder engagement. Thus the social risk for the project is currently rated moderate B. Environment and Social Standards (ESSs) that Apply to the Activities Being Considered B.1. General Assessment ESS1 Assessment and Management of Environmental and Social Risks and Impacts Overview of the relevance of the Standard for the Project: The review considered the anticipated environmental, social and health risks presented by the project, the risks management requirements and the capacity of the implementing agency to manage the risks in compliance with the Bank’s ESF. The specific locations at the level of the selected countries for the implementation of the project activities is not yet known. The scope and scale of the anticipated risks are expected to be site-specific, limited, localized and largely manageable. The main environmental and social risks of this project relate to the ability of project developer to properly identify and manage the E&S risks and impacts as required by the ESF. In addition, since this is a regional project which spans three countries, contextual country related risks may arise during project implementation such as risks to contractor labor working in conflict areas/low security zones. Similarly, the introduction of skilled workforce however small may heighten risks of GBV/sexual exploitation, cultural conflicts and spread of communicable diseases to and from local communities. Public Disclosure From the preliminary review carried out at this concept stage, it can be concluded that the implementing agencies’ (IA) procedures need to be enhanced to comply with ESS1 requirements. Ahead of the project appraisal, and consistent with ESS1, the borrower/IA is required to prepare Environmental & Social Impact Assessment (ESIAs) and Environmental and Social Management Plans (ESMPs) to identify and manage notable E&S risks on each substation. A GBV Action plan including an Accountability and Response Framework needs to be developed as part of project ESMP. The ESIAs should provide an overview of key risks and impacts per potential sub stations/per country and provide inputs into the project design and analysis of alternatives. Each ESIA/ESMP with clearly defined mitigation measures for construction and operational phases, roles and responsibilities, time plans, costs and implementation procedures for each mitigation measures recommended. Contractors will be required, as a condition of their contracts with the Project, to implement and comply with the ESMPs, including Labor Management Procedures and Occupational Health and Safety measures outlined in the ESMPs. Contractors and their workers will also be subject to and trained on codes of conduct which includes GBV/prevention of sexual exploitation, interacting with local communities and security provisions. The impacts will be revisited when there’s greater details on the subprojects and the ESIA will identify any potential resettlement/economic displacement impacts to any communities or groups. If the ESIA should identify such impacts, then required instruments like RAP/ARAPs will be prepared by the borrower. Oct 21, 2019 Page 5 of 10 The World Bank ECOWAS - Battery Energy Storage Systems and Synchronization (BE3S) Project (P167569) The findings of the ESIAs will be integrated into relevant plans and processes (SEP, ESMP, GRM, etc.). The Bank team will review the TOR for the ESIAs. Areas where “Use of Borrower Framework” is being considered: The operation will not use the Borrower’s E&S Framework in the assessment, development and implementation of subprojects. The project will comply with relevant national legal requirements ESS10 Stakeholder Engagement and Information Disclosure The borrower will prepare a Stakeholder Engagement Plan (SEP) which will detail how to identify, meaningfully consult and include stakeholder issues in the project lifecycle. The IA will also design an appropriate grievance mechanism through which concerns, issues and complaints of the stakeholders will be recorded and resolved. The borrower will disclose the SEP prior to project appraisal. The SEP will focus on consultation, engagement, and information disclosure in relation to the project and its associated risks and impacts especially at the country levels. The SEP will incorporate a comprehensive project-wide GRM which will enable a broad range of stakeholders to channel concerns, questions, and complaints to the implementation agencies. If major changes occur in the scope of activities during implementation, a revised SEP is required and should be publicly disclosed. Throughout the project, the IA will engage in meaningful consultations with all stakeholders. B.2. Specific Risks and Impacts Public Disclosure A brief description of the potential environmental and social risks and impacts relevant to the Project. ESS2 Labor and Working Conditions The project footprint is envisaged to be relatively localized and limited to installation of batteries in substations within the existing fence lines. For each substation it is estimated that there will be a single contractor that will bring in at least 10 skilled workers. These workers would be on site for at least three months. No separate labor camps are being planned for the workers and its not known whether workers will be housed in the nearby communities or bussed in every day. It is currently estimated that no large trucks are required to bring in the equipment and batteries. Even though large trucks are not required, nevertheless a fleet of small trucks to bring in batteries and other equipment would bring in additional truck drivers/other workers into the areas of construction. Overall labor risks under ESS 2 is rated moderate. Risk of child/ forced labor is limited, however, ESIA to be conducted during preparation will assess potential risks and mitigation measures will be included in ESMPs, if found necessary. Risk related to labor will be mitigated by the establishment and close adherence to i) a labor management procedure to be prepared by the PCU; (ii) labor management plan(s) to be prepared by the Contractor(s) as part of the Contractors ESMPs; and iii) a worker’s code of conduct acceptable to the Bank. The ESMP and ESIAs will include sections on OHS and Community Safety as well as Labor Management Procedures (LMP). ESMPs and Bidding Documents prepared for the project will include a Health, Safety and Environmental (HSE) plan in line with World Bank Group Environment, Health and Safety (EHS) Guidelines. A Worker Health and Safety Plan will also be developed to cover site-specific job hazards, provision of preventive and protective measures for all hazards; information about safe working methods; and road safety measures. The plan will also include procedures on Oct 21, 2019 Page 6 of 10 The World Bank ECOWAS - Battery Energy Storage Systems and Synchronization (BE3S) Project (P167569) incident investigation and reporting, recording and reporting of non-conformances, emergency preparedness and response procedures and continuous training and awareness to workers. Locally based GRMs specifically for direct and contracted workers, respectively, will be provided. Civil works contracts will incorporate E&S mitigation measures from the ESMP; LMP, EHS guidelines and OHS Plan. All civil works contracts will include Codes of Conduct and other measures specified in the GBV action plan to prevent GBV/SEA. ESS3 Resource Efficiency and Pollution Prevention and Management The ESIAs/ESMPs will include sections on resource efficiency and Pollution Prevention and Management. Assessment of risks and impacts and proposed mitigation measures related to relevant requirements of ESS3 will be included within scope of the ESIAs and ESMPs as relevant. In particular used batteries that are identified as hazardous waste with damage to humans and environment if without proper disposal. During preparation, relevant domestic regulations and their enforcement will be reviewed against the requirements of ESS3 and the World Bank’s applicable Environmental, Health and Safety Guidelines, and the initial Due Diligence (DD) will be conducted to review the logistical arrangements to transport the batteries and viability of battery disposal sites to support the assessment and mitigation measures proposed in the ESMS/ESCP. ESS4 Community Health and Safety Public Disclosure The Project is required to include assessments of risks and impacts of project activities to health and safety in project affected communities in all phases of the project cycle. Risks and impacts could relate to traffic and road safety (particularly during construction), or community exposure to nuisance and public health issues. There will be a limited number of workers (at least 10) brought in per site. However, the workers are expected to be on site for at least three months continuously. Due to the incoming workers, there could be cases of sexual exploitation/GBV and spread of communicable diseases like Hepatitis A, Ebola, HIV/STDs etc. from workers to the host communities and vice versa. Even though large trucks are not required, nevertheless a fleet of small trucks that bring in batteries and other equipment could create traffic hazards and road safety risks for local communities. The potential impacts on the local communities will be will be further assessed by the ESIA during project preparation. The ESIAs / ESMPs will include procedures for assessing and mitigating these risks. ESS5 Land Acquisition, Restrictions on Land Use and Involuntary Resettlement There is no anticipated civil works or expansions planned in the sub stations that may require the acquisition of land. There is no resettlement or economic displacement currently identified. Oct 21, 2019 Page 7 of 10 The World Bank ECOWAS - Battery Energy Storage Systems and Synchronization (BE3S) Project (P167569) The ESIA will identify any potential resettlement/economic displacement impacts to any communities or groups. If the ESIA should identify such impacts, then required instruments like RAP/ARAPs will be prepared by the borrower. The relevance of ESS 5 will be further assessed prior to appraisal. ESS6 Biodiversity Conservation and Sustainable Management of Living Natural Resources The project will be located in modified landscapes, within existing electrical installations. ESS6 is not currently relevant. This will be further assessed during appraisal in the ESIAs. ESS7 Indigenous Peoples/Sub-Saharan African Historically Underserved Traditional Local Communities Currently the locations of the sub stations is not known and the exact sites have not been selected. The information available indicates that the project will not undertake activities in any location that is likely to impact any group of people with distinct characterization that meet the criteria provided in ESS 7. However, during the ESIA, communities in and around the potential sub stations should be screened to identify if any of them meet the characteristics defined in ESS7. ESS8 Cultural Heritage The proposed activities will not involve construction works or excavations or any other activities that may have Public Disclosure impacts on the cultural sensitivities of communities. The project is focused inside the fence line of the sub stations and therefore unlikely to have impacts on archaeological or cultural heritage. The relevance and applicability of ESS 8 will be further assessed prior to appraisal. ESS9 Financial Intermediaries Not relevant as the project does not proposed to lend to FIs C. Legal Operational Policies that Apply OP 7.50 Projects on International Waterways No OP 7.60 Projects in Disputed Areas No III. WORLD BANK ENVIRONMENTAL AND SOCIAL DUE DILIGENCE A. Is a common approach being considered? No Financing Partners Oct 21, 2019 Page 8 of 10 The World Bank ECOWAS - Battery Energy Storage Systems and Synchronization (BE3S) Project (P167569) NA B. Proposed Measures, Actions and Timing (Borrower’s commitments) Actions to be completed prior to Bank Board Approval: Prior to appraisal, the client will prepare a Environment and Social Impact Assessments (ESIA) and draft Environmental and Social Management Plans (ESMP) acceptable to the Bank Labor Management Procedure as a part of ESMP GBV Action Plan as a part of the ESMP The ESIA will be consulted on with stakeholders prior to finalization, reviewed and approved by the Bank, and publicly disclosed Preparation and disclosure of Stakeholder Engagement Plan (SEP) Preparation of the ESCP Preparation of Waste Management Plan as part of ESMP Possible issues to be addressed in the Borrower Environmental and Social Commitment Plan (ESCP): Implementation of ESMPs and schedule for monitoring implementation of ESMPs. The ESMPs will incorporate Labor Management Procedures (LMP) & GBV Action Plan Development and implementation of a proportional Health, Safety and Environmental (HSE) plan in line with World Bank Group Environment, Health and Safety (EHS) Guidelines (for construction activities); Details about the elements and timing of activities for delivery and implementation of the SEP Establishment and implementation of GRM Public Disclosure Implementation of SEP C. Timing Tentative target date for preparing the Appraisal Stage ESRS 31-Dec-2020 IV. CONTACT POINTS World Bank Contact: Massan Elise Akitani Title: Senior Energy Specialist Telephone No: 5220+31059 Email: makitani@worldbank.org Contact: Pedro E. Sanchez Title: Lead Energy Specialist Telephone No: 458-5711 Email: psanchez2@worldbank.org Borrower/Client/Recipient Borrower: Ministry of Finance Oct 21, 2019 Page 9 of 10 The World Bank ECOWAS - Battery Energy Storage Systems and Synchronization (BE3S) Project (P167569) Borrower: Federal Republic of Nigeria Borrower: Republic Of Ghana Borrower: Republic of Cote d'Ivoire Implementing Agency(ies) Implementing Agency: Ministry of Energy Implementing Agency: Ministry of Energy V. FOR MORE INFORMATION CONTACT The World Bank 1818 H Street, NW Washington, D.C. 20433 Telephone: (202) 473-1000 Web: http://www.worldbank.org/projects VI. APPROVAL Task Team Leader(s): Massan Elise Akitani, Pedro E. Sanchez Public Disclosure Practice Manager (ENR/Social) Maria Sarraf Recommended on 03-Jun-2019 at 21:31:6 EDT Safeguards Advisor ESSA Hanneke Van Tilburg (SAESSA) Cleared on 21-Oct-2019 at 00:22:51 EDT Oct 21, 2019 Page 10 of 10