REPORT Central Térmica de Temane Project - Construction Environmental and Social Management Plan (c-ESMP) Moz Power Invest, SA. and Sasol New Energy Holding (Pty) Ltd. Submitted to: World Bank Group Submitted by: Golder Associados Moçambique Limitada 6th Floor, Millenium Park Building, Vlademir Lenine Avenue No 174 Maputo, Moçambique +258 21 301 292 18103533 March 2019 March 2019 18103533 Distribution List 1 x electronic copy World Bank Group 1 x electronic copy SNE, EDM and TEC 1 x electronic copy e-projects library projectreports@golder.co.za 1 x electronic copy Golder project folder i March 2019 18103533 Table of Contents 1.0 INTRODUCTION ......................................................................................................................................... 7 1.1 Details of the Proponent .................................................................................................................. 10 1.2 Scope and Objectives of c-ESMP ................................................................................................... 10 1.2.1 What is included .......................................................................................................................... 10 1.2.2 What is Excluded? ...................................................................................................................... 11 1.2.3 Report Structure .......................................................................................................................... 11 2.0 CTT ENVIRONMENTAL POLICIES AND COMMITMENTS IN MOZAMBIQUE ..................................... 11 2.1 Safety, Health and Environmental (SHE) Policy ............................................................................. 11 2.2 Community Engagement Principles ................................................................................................ 12 2.3 Compliance with Legislation and Best Industry Standards ............................................................. 12 2.3.1 Mitigation hierarchy ..................................................................................................................... 12 3.0 PROJECT DESCRIPTION ........................................................................................................................ 13 3.1 Ancillary Infrastructure .................................................................................................................... 17 3.2 Beach Landing Jetty Construction .................................................................................................. 17 3.3 Anchorage Points ............................................................................................................................ 20 3.4 Construction Camp Laydown Areas ............................................................................................... 22 3.5 Beach Laydown Area ...................................................................................................................... 22 3.6 Transmission Line ........................................................................................................................... 25 4.0 ENVIRONMENTAL MANAGEMENT STRUCTURE ................................................................................ 29 4.1 Content of the Report ...................................................................................................................... 29 4.2 Organisational Structure and Responsibility ................................................................................... 29 4.3 Communication with Government, Communities and Stakeholders ............................................... 36 4.4 Environmental and Social Management System (ESMS) .............................................................. 36 5.0 ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN ..................................................................... 37 5.1 Register of Activities ........................................................................................................................ 37 5.2 Project Planning .............................................................................................................................. 38 5.2.1 Pre-construction Requirements .................................................................................................. 38 5.3 General Administration and Liaison ................................................................................................ 39 5.3.1 Administration and General Issues ............................................................................................. 39 1 March 2019 18103533 5.3.2 Community, Stakeholder and Government Liaison .................................................................... 42 5.4 Community Health and Welfare ...................................................................................................... 46 5.4.1 Nuisance ..................................................................................................................................... 46 5.4.2 Population Influx and Social Pathologies .................................................................................... 49 5.4.3 Communicable Diseases ............................................................................................................ 52 5.4.4 Traffic and Pedestrian Safety ...................................................................................................... 57 5.4.5 Violence and crime...................................................................................................................... 62 5.4.6 Fire .............................................................................................................................................. 63 5.5 Biodiversity ...................................................................................................................................... 63 5.5.1 General ....................................................................................................................................... 63 5.5.2 Bush clearing .............................................................................................................................. 74 5.5.3 Control of Invasive Alien Plants .................................................................................................. 77 5.5.4 Rehabilitation Management ........................................................................................................ 80 5.5.5 Cultural Heritage ......................................................................................................................... 83 5.6 Employment and Local Procurement .............................................................................................. 87 5.6.1 Employment and Labour Management ....................................................................................... 87 5.6.2 Procurement of Local Goods and Services ................................................................................ 90 5.7 Solid Waste and Materials Management ........................................................................................ 91 5.7.1 Non- Hazardous Waste Management......................................................................................... 91 5.7.2 Hazardous Waste Management ................................................................................................. 96 5.8 Water Management ....................................................................................................................... 102 5.8.1 Wastewater Management ......................................................................................................... 102 5.8.2 Stormwater Management .......................................................................................................... 107 5.8.3 Water Supply Management ...................................................................................................... 107 5.8.4 Bio-medical Waste Management .............................................................................................. 109 5.8.5 Vehicle and Materials Management (including hazardous chemicals, fuels and lubricants).... 110 5.9 Camp Sites and Lay Down Areas ................................................................................................. 116 5.9.1 Construction Camps.................................................................................................................. 116 5.9.2 Lay Down Areas ........................................................................................................................ 121 5.10 Work Sites - General ..................................................................................................................... 121 5.10.1 Access Control .......................................................................................................................... 121 2 March 2019 18103533 5.10.2 Civil, Steel and Mechanical Work ............................................................................................. 123 5.11 Work Sites - Specific ..................................................................................................................... 123 5.11.1 Pipeline Installation and Testing ............................................................................................... 123 5.11.2 Borrow Pits ................................................................................................................................ 126 5.11.3 Road Construction .................................................................................................................... 128 5.11.4 Environmental and Social Management Plan Development and Budget Estimates ................ 128 6.0 PERFORMANCE ASSESSMENT, CORRECTIVE ACTION, MANAGEMENT REVIEW AND AUDIT . 132 6.1 Environmental and Social Monitoring Strategy ............................................................................. 132 6.2 Inspections and Reporting ............................................................................................................ 140 6.2.1 Monthly Reporting ..................................................................................................................... 140 6.2.2 Corrective and Preventive Action .............................................................................................. 140 6.2.3 Environmental Committee Meetings and Reporting ................................................................. 141 6.2.4 Six-Monthly Report.................................................................................................................... 141 6.2.5 Independent Audits ................................................................................................................... 141 7.0 COMPETENCY, TRAINING AND AWARENESS CREATION .............................................................. 142 7.1 General Training Requirements .................................................................................................... 142 7.2 Specialist training material ............................................................................................................ 143 7.3 Handling of potentially dangerous snakes and other animals ...................................................... 143 8.0 EMERGENCY PREPAREDNESS AND RESPONSE ............................................................................ 144 9.0 DOCUMENT CONTROL ......................................................................................................................... 144 TABLES Table 1: Proponent details .................................................................................................................................. 10 Table 2: Primary objectives of mitigation measures for adverse environmental impacts. The objectives are listed in decreasing order of priority ............................................................................................................................. 13 Table 3: Responsibilities of organisations and personnel for environmental and social management on CTT during construction phase................................................................................................................................... 29 Table 4: Alien invasive plants identified in the CTT license areas and recommended control methods (Source: adapted from Biodynamica, 2016) ...................................................................................................................... 78 Table 5: ESMP budgets .................................................................................................................................... 129 Table 6: Monitoring requirements ..................................................................................................................... 133 Figure 1: Project Location ..................................................................................................................................... 9 3 March 2019 18103533 Figure 2: Examples of gas to power plant sites (source: www.industcards.com and www.wartsila.com) ......... 14 Figure 3: CTT Key Infrastructure ........................................................................................................................ 15 Figure 4: Conceptual layout of CTT plant site .................................................................................................... 16 Figure 5: SETA Beach landing site and route at Inhassoro ............................................................................... 18 Figure 6: Conceptual illustration of the Jetty at SETA beach landing site .......................................................... 19 Figure 7: Previously used or identified Offshore Anchorage locations ............................................................... 21 Figure 8: Conceptual illustration of CTT during construction phase .................................................................. 23 Figure 9: Conceptual Construction Camp Layout .............................................................................................. 24 Figure 10: Pylon illustrations .............................................................................................................................. 26 Figure 11: Pylon Foundations ............................................................................................................................. 27 Figure 12: Examples of Pylon construction (source: http://cscon.co.za/ and EDM)........................................... 28 Figure 13: Responsibilities for environmental and social management during construction of the CTT’ project ................................................................................................................................................................. 35 FIGURES Figure 1: Project Location ..................................................................................................................................... 9 Figure 2: Examples of gas to power plant sites (source: www.industcards.com and www.wartsila.com) ......... 14 Figure 3: CTT Key Infrastructure ........................................................................................................................ 15 Figure 4: Conceptual layout of CTT plant site .................................................................................................... 16 Figure 5: SETA Beach landing site and route at Inhassoro ............................................................................... 18 Figure 6: Conceptual illus]tration of the Jetty at SETA beach landing site ......................................................... 19 Figure 7: Offshore Anchorage locations ............................................................................................................. 21 Figure 8: Conceptual illustration of CTT during construction phase .................................................................. 23 Figure 9: Conceptual Construction Camp Layout .............................................................................................. 24 Figure 10: Pylon illustrations .............................................................................................................................. 26 Figure 11: Pylon Foundations ............................................................................................................................. 27 Figure 12: Examples of Pylon construction (source: http://cscon.co.za/ and EDM)........................................... 28 Figure 13: Responsibilities for environmental and social management during construction of the CTT’ project ................................................................................................................................................................. 35 APPENDICES 4 March 2019 18103533 Acronym or Abbreviation Description APE Agente Polivalente Elementar (APE) or Community health worker BANP Bazaruto Archipelago National Park CFC Chlorofluorocarbons CHMP Cultural Heritage Management Plan CLF Community Liaison Forum CLO Community Liaison Officer CPF Central Processing Facility CTT Central Térmica de Temane EC Environmental Coordinator ECO Environmental Control Officer EDM Electricidade de Moçambique, E.P (Mozambique Power Company) ESIA Environmental and Social Impact Assessment ESMP Environmental and Social Management Plan. (c-ESMP – construction ESMP; o-ESMP – operations ESMP and d-ESMP – decommissioning ESMP) ESO Environmental Site Officer EPDA Estudo de Pré-viabilidade Ambiental e Definição de Âmbito (Environmental Pre-feasibility and Scope Definition Report) EPRF Emergency Preparedness and Response Framework IFC International Finance Corporation ISO International Organisation for Standardisation LOCSA Liaison Officer – Community and Stakeholder Affairs IUCN International Union for Conservation of Nature MITADER Ministério da Terra, Ambiente e Desenvolvimento Rural (Mozambican Ministry of Land, Environment and Rural Development) MSDS Material Safety Data Sheets MW Megawatt NGO Non-Governmental Organisation PCB polychlorinated biphenyl PLA Project Labour Agreement POC Potentially oily contaminated 5 March 2019 18103533 Acronym or Abbreviation Description PPZ Partial Protection Zone PSA Production Sharing Agreement PVC Polyvinyl Chloride STE/CESUL Projecto de Interligação da Rede Nacional de Energia Centro-Sul (Interconnection Project of South-Central National Energy Network) ToR Terms of Reference WHO World Health Organisation 6 March 2019 18103533 1.0 INTRODUCTION The Mozambican economy is one of the fastest growing economies on the African continent with electricity demand increasing by approximately 6-8% annually. In order to address the growing electricity demand faced by Mozambique and to improve power quality, grid stability and flexibility in the system, Moz Power Invest, S.A. (MPI), a company to be incorporated under the laws of Mozambique and Sasol New Energy Holdings (Pty) Ltd (SNE) in a joint development agreement is proposing the construction and operation of a gas to power facility, known as the Central Térmica de Temane (CTT) project. MPI’s shareholding will be comprised of EDM and Temane Energy Consortium (Pty) Ltd (TEC). The joint development partners of MPI and SNE will hereafter be referred to as the Proponent. The Proponent propose to develop the CTT, a 450MW natural gas fired power plant. The proposed CTT project will draw gas from the Sasol Exploration and Production International (SEPI) gas well field via the phase 1 development of the PSA License area, covering gas deposits in the Temane and Pande well fields in the Inhassoro District and the existing Central Processing Facility (CPF). Consequently, the CTT site is in close proximity to the CPF. The preferred location for the CTT is approximately 500 m south of the CPF. The CPF, and the proposed site of the CTT project, is located in the Temane/Mangugumete area, Inhassoro District, Inhambane Province, Mozambique; and approximately 40 km northwest of the town of Vilanculos. The Govuro River lies 8 km east of the proposed CTT site. The estimated footprint of the CTT power plant is approximately 20 ha (see Figure 1). Associated infrastructure and facilities for the CTT project will include: 1) Electricity transmission line (400 kV) and servitude; from the proposed power plant to the proposed Vilanculos substation over a total length of 25 km running generally south to a future Vilanculos substation. [Note: the development of the substation falls outside the battery limits of the project scope as it is part of independent infrastructure authorised separately. Environmental authorisation for this substation was obtained under the STE/CESUL project. (MICOA Ref: 75/MICOA/12 of 22nd May 2012)]; 2) Piped water from one or more borehole(s) located either on site at the power plant or from a borehole located on the eastern bank of the Govuro River (this option will require a water pipeline approximately 11km in length); 3) Access road; over a total length of 3 km, which will follow the proposed water pipeline to the northeast of the CTT to connect to the existing Temane CPF access road; 4) Gas pipeline and servitude; over a total length of 2 km, which will start from the CPF high pressure compressor and run south on the western side of the CPF to connect to the power plant; 5) Additional nominal widening of the servitude for vehicle turning points at points to be identified along these linear servitudes; 6) A construction camp and contractor laydown areas will be established adjacent to the CTT power plant footprint; and 7) Transhipment and barging of equipment to a temporary beach landing site and associated logistics camp and laydown area for the purposes of safe handling and delivery of large oversized and heavy equipment and infrastructure to build the CTT. The transhipment consists of a vessel anchoring for only approximately 1-2 days with periods of up to 3-4 months between shipments over a maximum 15 month period early in the construction phase, in order to offload heavy materials to a barge for beach landing. There are 3 beach landing site options, namely SETA, Maritima and Briza Mar (Figure 7). The SETA site is considered to be the preferred beach landing site for environmental and other reasons; it therefore shall be selected unless it is found to be not feasible for any reason; 7 March 2019 18103533 8) Temporary bridges and access roads or upgrading and reinforcement of existing bridges and roads across sections of the Govuro River where existing bridges are not able to bear the weight of the equipment loads that need to be transported from the beach landing site to the CTT site. Some new sections of road may need to be developed where existing roads are inaccessible or inadequate to allow for the safe transport of equipment to the CTT site. The northern transport route via R241 and EN1 is considered as the preferred transport route (Figure 8) on terrestrial impacts; however, until the final anchor point is selected, and the barge route confirmed, the marine factors may still have an impact on which is deemed the overall preferable route. 8 March 2019 18103533 Figure 1: Project Location 9 March 2019 18103533 1.1 Details of the Proponent Moz Power Invest, S.A. (MPI), a company to be incorporated under the laws of Mozambique and CTT New Energy Holdings (Pty) Ltd (SNE) in a joint development agreement is proposing the construction and operation of a gas to power facility, known as the Central Térmica de Temane (CTT) project. MPI’s shareholding will be comprised of Electricidade de Mozambique E.P. (EDM) and Temane Energy Consortium (Pty) Ltd (TEC). Dr. Aly Sicola Impija, board member of EDM, is the Proponent representative and will hold the environmental authorisation should it be granted. Table 1: Proponent details MPI SNE Moz Power Invest S.A. (MPI) Sasol New Energy Holdings (To be incorporated) (Pty) Ltd (SNE): EDM TEC Hubert Naude Business Development Manager Electricidade De Moçambique (EDM) Temane Energy Corporation: Tel: +27 (0)10 344 5432 Fax: +27 (0)11 522 1175 Pedro Nguelume Globeleq Email: hubert.naude@sasol.com Project Director Ian Potgieter Tel: + 258 84 46 46 853 Business Development Manager Fax: + 258 21 32 82 33 Tel: +27 (0) 12 443 6511 Email: pnguelume@edmdipla.co.mz Email: ian.potgieter@globeleq.co.za Dr. Aly Sicola Impija Jonathan Frick EDM Board Member Business Development Manager Tel: +258 2135 36 15 Tel: +27 (0) 21 180 4595 Fax: +258 2149 1040 Email: jon.frick@globeleq.co.za Belarmina Mirasse EleQtra Environmental Manager Lauren Thomas Tel: +258 2135 3615 Developer Fax: +258 2135 3694 Tel: +258 85 363 7639 Email: belarmina.Mirasse@edm.co.mz Email: Lauren.Thomas@eleqtra.com 1.2 Scope and Objectives of c-ESMP This document is the Construction Environmental and Social Management Plan (c-ESMP) for the CTT project. It is used as a guideline for the management of the construction phase of the CTT. It is derived from the ESIA and supporting specialist studies. 1.2.1 What is included The c-ESMP is intended to identify possible impacts associated with the construction phase, propose mitigation measures and action plan for each identified impact. The ESMP is used as a guideline during the construction phase. The construction phase covers all of the physical footprints and activities linked to the construction and commissioning of infrastructure described in section 3.0 during the CTT construction phase which is expected to continue for 18-24 months. 10 March 2019 18103533 1.2.2 What is Excluded? The c-ESMP does not cover any operational or decommissioning activities. Separate ESMPs for both operation and decommissioning phases are available for this project and are referenced as (o-ESMP and d-ESMP) for operational and decommissioning activities respectively. Aspects related to compensation and resettlement are not addressed in this c-ESMP and the reader is referred to the document “Compensation and Resettlement Procedure” for the CTT project. The c-ESMP also excludes specifications regarding occupational health, hygiene or safety requirements. The client (MPI and SNE) obligations in this regard are determined by legislation and will be documented separately in the appropriate policy or procedure prior to construction activities commencing. 1.2.3 Report Structure The c-ESMP is structured as follows:  Chapter 2 describes the CTT environmental and social policies and commitments in Mozambique.  Chapter 3 describes the activities that make up construction phase of the projects covered by this c-ESMP.  Chapter 4 describes the environmental management structure, including the approach to the c-ESMP and the organisational structure and responsibilities.  Chapter 5 sets out the detailed specifications, including management of the pre-construction phase, the construction phase and the post-construction phase up to the operation phase.  Chapter 6 describes requirements for performance assessment, corrective action, management review and auditing.  Chapter 7 sets out requirements for competency training and awareness creation.  Chapter 8 outlines requirements for dealing with emergencies.  Chapter 9 specifies requirements for document control. 2.0 CTT ENVIRONMENTAL POLICIES AND COMMITMENTS IN MOZAMBIQUE 2.1 Safety, Health and Environmental (SHE) Policy The CTT shall implement a Safety, Health and Environmental Policy declaration that sets the framework for an integrated management system for the Construction, Operation and Decommissioning of the CTT. All visitors, contractors and employees are required to comply with the requirements of the policy declaration. CTT management and staff shall fully subscribe to the SHE policy declaration and shall demonstrate commitment to the policy by:  Developing and implementing an integrated management system that will comply with the requirements of the OHSAS 18001 Occupational Health & Safety, and ISO 14001 Environmental Management Systems;  Subjecting itself to third party audits conducted by an internationally recognised certification body as part of their drive towards continual improvement;  Accepting and complying with Corporate Governance requirements, Mozambican SHE - related legislation, all Financing obligations (including WB/IFC PS) and any appropriate, recognised, industry codes of practice; 11 March 2019 18103533  Engaging with the Mozambican Government regarding the implementation framework for any new legislation that affects the CTT and its activities;  Influencing suppliers and contractors to conform as a minimum to the Mozambican SHE - related legislation and to respect and adhere to the CTT codes of practice;  Sharing and communicating relevant information about safety, health and environmental performance with interested and affected parties, employees and authorities in an open and transparent manner, and making this declaration available by displaying it in all office buildings and in the induction training;  Minimising risks associated with its activities which may impact on the health and safety of its employees, communities and the environment;  Enhancing the general awareness of its employees and contractors to ensure understanding of all the SHE risks and impacts associated with their work activities;  Preventing pollution, accidents, injuries and ill health through setting and reviewing objectives and programmes;  Responding effectively to safety, health and environmental emergencies;  Providing appropriate resources to implement the above commitments;  Reviewing such a declaration of intent on an acceptable basis or as and when required by CTT SHE Governance structure. 2.2 Community Engagement Principles CTT’s community engagement principles are centred on:  Community involvement and ownership  Strengthen community leadership  Targeted impacts-driven interventions  Addressing key community priorities  Strategic research informed interventions  Monitoring and evaluation  Building capacity through partnership 2.3 Compliance with Legislation and Best Industry Standards The CTT project has committed to comply with international guidelines and standards (the Equator Principles, World Bank Group Operational Policies, International Finance Corporation Performance Standards and other applicable international and regional guidelines) where these are more rigorous or detailed than Mozambican national standards or where Mozambique standards do not exist. 2.3.1 Mitigation hierarchy The first priority of environmental management is always to prevent adverse impacts, thereafter management measures with other objectives are considered. Environmental management measures can be varied and the measures themselves can have a variety of objectives. 12 March 2019 18103533 World Bank guidelines for a best practice approach to the management of environmental and social impacts are presented in Table 2. Many of the recommendations set out in the design component of Chapter 5.0 are designed to meet the criterion for ‘avoidance’. Table 2: Primary objectives of mitigation measures for adverse environmental impacts. The objectives are listed in decreasing order of priority Avoidance  Avoiding activities that could result in adverse impacts.  Avoiding resources or areas considered as sensitive. Prevention  Preventing the occurrence of negative environmental impacts and / or  Preventing such an occurrence having negative environmental impacts. Preservation  Preventing any future actions that might adversely affect an environmental resource.  Typically achieved by extending legal protection to selected resources beyond the immediate needs of the project. Minimisation  Limiting or reducing the degree, extent, magnitude or duration of adverse impacts.  This can be achieved by scaling down, relocating, redesigning elements of a project. Rehabilitation  Repairing or enhancing affected resources, such as natural habitats or water sources, particularly when previous development has resulted in significant resource degradation. Restoration  Restoring affected resources to an earlier (and possibly more stable and productive) state, typically ‘background / pristine’ condition. Compensation  Creation, enhancement or protection of the same type of resource at another suitable and acceptable location, compensating for lost resources. 3.0 PROJECT DESCRIPTION This section describes the area and the nature of the activities that are covered by this c-ESMP. The Central Térmica De Temane (CTT) project will produce electricity from natural gas in a power plant located 500m south of the CPF. The project will consist of the construction of the following main components (Figure 2):  Gas to Power Plant with installed capacity of approximately 450MW;  Gas pipeline (±1-2 km) that will feed the Power Plant with natural gas from the CPF;  400kV Electrical transmission line (± 25 km in length) with a servitude of 100m that will include a fire break (vegetation control) and a maintenance road to the Vilanculos sub-station. The transmission line will have a partial protection zone (PPZ) of 100m width (i.e. 50m on either side of centre line). The transmission line servitude will fall inside the PPZ;  Water supply pipeline to one or more borehole(s) located either on site or at borehole(s) located east of the Govuro River; 13 March 2019 18103533  Paved access road to the CTT site and gravel maintenance roads within the transmission line and pipeline servitudes;  A construction camp and contractor laydown areas will be established adjacent to the CTT power plant footprint;  Temporary beach landing structures at Inhassoro town for the purposes of delivery of heavy and oversized equipment and infrastructure to build the power plant. This will include transhipment and barging activities to bring equipment to the beach landing site for approximately 1-2 days with up to 3-4 months between shipments over a period of approximately 8-15 months; and  Temporary bridge structures across the Govuro River, as well as possible new roads and/or road upgrades to allow equipment to be safely transported to the CTT site from the beach landing during the construction phase. Figure 2: Examples of gas to power plant sites (source: www.industcards.com and www.wartsila.com) The final selection of technology that will form part of the power generation component of the CTT project has not been determined at this stage. The two power technology options that are currently being evaluated are:  Combined Cycle Gas Turbine (CCGT); and  Open Cycle Gas Engines (OCGE). The two technology options are discussed in detail in the Environmental and Social Impact Assessment (ESIA) report (reference- 181035333-320908-2). Once a technology and vendor is selected, this ESMP must be updated accordingly. The provisional layout of the project infrastructure is indicated in Figure 3 with a conceptual layout of the CTT plant shown in Figure 4. 14 March 2019 18103533 Figure 3: CTT Key Infrastructure 15 March 2019 18103533 Figure 4: Conceptual layout of CTT plant site 16 March 2019 18103533 3.1 Ancillary Infrastructure In addition to the previously described main infrastructure components, the ancillary construction phase activities that will be undertaken and which will be managed under this c-ESMP consist of the following:  Maintenance facilities, admin building and other buildings (work shop, warehouse etc);  Telecommunications and security;  Waste (solid and effluent) treatment and/or handling and disposal by third party, (ablution facilities will be a combination of septic tanks and French drains/ soak away pits);  Site preparation, civil works and infrastructure development for the complete CTT plant, transmission line and pipelines (gas and water);  Construction camp (including housing/accommodation for construction workers); and  Road construction and/or road upgrades along either of the two transport options being considered for transporting equipment from the beach landing sites to the CTT plant during construction phase;  Beach landing laydown area and logistics camp. 3.2 Beach Landing Jetty Construction As part of the CTT construction phase, it was considered that large heavy equipment and materials would need to be brought in by a ship which would remain anchored at sea off the coast of Inhassoro. Equipment and materials would be transferred to a barge capable of moving on the high tide into very shallow water adjacent to the beach to discharge its cargo onto a temporary off-loading jetty (typically containers filled with sand) near the town of Inhassoro. As the tide changes, the barge rests on the beach and off-loading of the equipment commences. Currently, the SETA beach landing site is the preferred beach landing site (assuming the use of one of the identified anchor sites) together with the road route option to be used in transporting equipment and materials along the R241 then the EN1 then via the existing CPF access road to the CTT site near the CPF. Figure 5 indicates the beach landing site while Figure 6 indicates the Conceptual illustration of the Jetty at SETA beach landing site. The alternative beach landing sites of Maritima and Briza Mar are still being evaluated as potential options. 17 March 2019 18103533 Figure 5: SETA Beach landing site and route at Inhassoro 18 March 2019 18103533 Figure 6: Conceptual illustration of the Jetty at SETA beach landing site 19 March 2019 18103533 3.3 Anchorage Points Two anchorage points for the ships that will transport large heavy equipment and components are indicated on nautical charts; both are located off the coast of Inhassoro within Bazaruto Archipelago National Park (BANP) (Figure 7) and therefore an approval from the BANP would need to be obtained prior to utilizing these points, as well as consistency with PS 6, Mozambican legal requirements and any Management Plan of the BANP. The first anchorage point is located approximately 20km east of SETA beach landing site (7km from Bazaruto Island and 13km from Santa Carolina Island) while the second one is nearer to the mainland shore, approximately 13km east of Briza Mar beach landing site (5-6km from Santa Carolina Island and 10km from Bazaruto Island). As both previously identified anchorage sites are within the boundaries of the Bazaruto Archipelago National Park (BANP), an ongoing study seeks to identify alternative anchorage point(s) that would be located completely outside BANP, as well as being feasible from a technical, environmental, and social point of view. The anchorage point(s) and associated barge lane(s) to be used by this Project shall be fully outside BANP boundaries, unless alternative sites outside BANP either (i) are not at all available or clearly technically not feasible or (ii) would clearly have greater overall adverse environmental or social impacts than if they were within BANP. The selection of the final anchorage points therefore is subject to the World Bank’s no-objection. Should the anchorage point(s) and/or barge route(s) have to be within the BANP for the above-mentioned reasons, a) the marine studies included within the ESIA will be updated and resubmitted to the World Bank for approval and b) the ESMP shall be updated to specify any further measures that may be necessary or appropriate to enhance the conservation and management of BANP and resubmitted to the World Bank for approval. Moreover, CTT would ensure that the locations of these facilities (i) have been formally approved by African Parks (legally responsible for BANP management) and ANAC (Mozambique’s national conservation agency); (ii) are consistent with the Government-approved BANP Management Plan; and (iii) are legally permitted under Mozambican law—all in full compliance with IFC Performance Standard 6 (Paragraph 20) and the applicable Mozambican laws and regulations. It is understood that the vessel will not be anchored for extended periods of time and will most likely be anchored for a day or two at a time to offload the heavy equipment, although this will be defined once a technology option has been chosen as well as a preferred manufacturer of the various large and oversized power plant components. 20 March 2019 18103533 Figure 7: Previously used or identified Offshore Anchorage locations 21 March 2019 18103533 3.4 Construction Camp Laydown Areas A construction camp will be required to cater for the construction workforce and contractors at the CTT site. General equipment and material laydown areas for contractors at the CTT site will also be required during the construction phase. An example of the construction camp and laydown area is provided in Figure 8 below. It is worth noting that the CTT plant site, construction camp and laydown area all fall within the area which has previously been bush-cleared and de-mined for any potential unexploded ordnances. The linear features such as access roads, transmission line, gas and water pipelines have also been bush-cleared and de-mined. Prior to the commencement of construction activities, the appointed Contractor will be responsible for clearing and site preparation. The Contractor will prepare and implement its site specific Contractor ESMP on site. Figure 9 below provides an indicative construction camp layout for a number of 850-person camp. It typically provides accommodation for workers, offices, administration offices, catering facilities, medical clinic (with supporting equipment), diesel generators and diesel storage tanks, sewage treatment plant as well as water treatment facilities. There are recreational facilities as well as security facilities on site. A detailed construction camp management plan, aligned with international best practices will need to be prepared for implementation by the contractor, prior to construction. Refer to the framework construction (work) camp management plan for further guidance on this. 3.5 Beach Laydown Area It should be noted that there will be a laydown area at the chosen beach landing site. This area will be used as a staging area to manage the large equipment and materials that will be offloaded from the barges. This is only expected to be used during daylight hours and for temporary storage of materials, equipment and vehicles. 22 March 2019 18103533 Figure 8: Conceptual illustration of CTT during construction phase 23 March 2019 18103533 Figure 9: Conceptual Construction Camp Layout 24 March 2019 18103533 3.6 Transmission Line A 400 kV transmission line will be constructed from the CTT to the Vilanculos substation (this sub-station was previously authorised under a separate project). The 400kV transmission line is approximately 25km in length and will evacuate the power to the National Grid via the Vilanculous sub-station. A typical Over Head Line (OHL) uses three main types of lattice steel towers (pylons). These are:  Suspension towers: which support the conductors on straight stretches of line. Two alternative designs may be used on this Project - self-supporting or guyed V-towers;  Angle / Deviation towers: which are used at points where the route changes directions. They are self- supporting towers; and,  Terminal towers: which are used where the line terminates at substations. It is proposed to use a combination of self-supporting towers and guyed V-towers but where possible to avoid the use of guyed V-towers where economically viable, at minimum in high risk areas for collision risk posed by guy wires to birds (also fruit bats), including species of conservation concern such as several globally threatened vulture species, It is proposed that at least 3 meters of spacing between the conductors is implemented The tower height will be dependent on the terrain, height above sea level and span length (distance between towers) which will typically vary between 400m and 500m (Figure 10 provides a visual illustration of the towers). 25 March 2019 18103533 Figure 10: Pylon illustrations The typical tower height will vary between 20 – 25 m and will have a PPZ of 100m (50m on either side of centre- line) established. Depending on the tower design finally chosen, the foundations will differ between one to four foundation columns, however they will both have level bases which will be used to erect the towers (Figure 11). 26 March 2019 18103533 Steel Concrete finished and Hole TESMPlate Backfilled Centre Peg Stub Chimney Timber Packing Pyramid Block Footing Stub leg Ready to concrete Source: Mott MacDonald, Mozambique Regional Transmission Backbone Project, ESIA, 2011 Figure 11: Pylon Foundations The construction process will generally be undertaken sequentially as follows:  De-mining & bush clearing (already mostly completed to ensure safety of personnel conducting surveys);  Site preparation, including road access; 27 March 2019 18103533  Civil Works for pylon foundations;  Pylon erection;  Conductor stringing;  Compliance quality testing; and  Rehabilitation of disturbed areas. Figure 12: Examples of Pylon construction (source: http://cscon.co.za/ and EDM) 28 March 2019 18103533 4.0 ENVIRONMENTAL MANAGEMENT STRUCTURE 4.1 Content of the Report The content of the report is set out according to an internationally recognised framework, which includes the following:  Avoidance / mitigation / management measures required during the construction phase of the project;  A description of the activities necessary to achieve the mitigation measures;  Generic programming and scheduling requirements;  Definition of responsibilities, resources, communication and reporting structures;  Specification of performance evaluation requirements;  Identification of training requirements;  Identification of monitoring requirements; and  Identification of audit requirements. 4.2 Organisational Structure and Responsibility The overall organisational structure for environmental management of construction infrastructure projects is set out in Figure 13 below. The responsibilities of the personnel are described in Table 3 below. Table 3: Responsibilities of organisations and personnel for environmental and social management on CTT during construction phase Item Refers to All parties All parties shall comply with all the requirements of the CTT ESIA and ESMP and shall, in accordance with accepted industry standards and the World Bank policies and guidelines, employ such up to date techniques, practices and methods that will ensure compliance to the requirements and, in general, minimise environmental damage, control waste, avoid pollution, prevent loss or damage to natural resources and minimise effects on surrounding landowners, occupants and the general public. All parties shall prevent or minimise the occurrence of accidents which may cause damage to the environment or people, prevent or minimise the effects of such accidents and shall return the environment to a state as close to the condition existing prior to any such accident as possible. All parties shall take proactive steps to ensure that the requirements in the ESMP are met during construction activities. These shall include, but not be limited to, the following:  Employment of competent and dedicated members of staff to oversee the implementation of the ESMP.  Instruction of staff about the relevant environmental aspects and the specific measures that each employee will implement to meet the environmental protection and management standards defined by the ESMP.  Engagement with stakeholders to share information and consult, particularly with affected persons and communities on the proper implementation of protective and compensatory measures. 29 March 2019 18103533 Item Refers to CTT CTT management responsible for oversight of civil construction including engineering, procurement and construction management (EPC). Where a Managing Contractor (or EPC Contractor) is appointed, the CTT project manager will liaise with them and exercise contractual rights to ensure compliance with the ESMP. Where a Managing Contractor is not appointed the CTT manager will be responsible for all oversight of the works. This will also require adequate oversight of the implementation and management of the Resettlement Policy Framework (RPF). The Sponsor will be responsible to ensure that the RAP/ARAP/LRP is implemented according to requirements of MITADER as well as the WBG requirements (PS5). CTT Managing Contractor This role is defined as CTT’s representative, responsible for engineering, procurement and construction management (EPC) of the project. The Managing Contractor is also referred to as the EPC Contractor. Construction management includes all social and environmental management. This will also include the implementation and management of the Resettlement Policy Framework (RPF) and any tools such as the RAP/ARAP/LRP. In accordance with accepted standards, the Managing Contractor shall ensure that the Construction Contractor employs such up to date techniques, practices and methods of construction that comply with the E&S standards enunciated above, and, in general, minimise environmental damage, control waste, avoid pollution, prevent loss or damage to natural resources and minimise effects on surrounding landowners, occupants and the general public. The Managing Contractor shall regularly update the Environmental and Social Coordinator (ESC) about any non-conformance in respect of this c- ESMP and the RPF and shall advise the ESC of the actions that will be taken to rectify the non-conformance. The Managing Contractor shall employ the staff indicated in Figure 13 to monitor the Construction Contractor’s performance and shall ensure that they are competent and fully briefed about the nature of the particular project. In some instances, CTT may manage the Construction Contractor themselves, in which case the positions of Managing Contractor and Site Engineer will be members of CTT’s staff. CTT Site Engineer The Managing Contractor’s representative on site. Environmental staff (Community Liaison Officers (CLO) and Environmental Site Officers (ESOs)) shall report directly to the Site Engineer referred to as ‘the Engineer’ in all specifications below. Construction Contractor The Construction Contractor is responsible for the construction of all of the (including all sub- works required by the project. The c-ESMP shall form part of the contractors) Construction Contractor’s agreement with CTT and shall be legally 30 March 2019 18103533 Item Refers to binding. The Construction Contractor (or ‘Contractor’) shall be responsible for the actions and performance of all sub-contractors. The Contractor shall be responsible for ensuring compliance with relevant Mozambican legislation, and all pertinent elements of the ESMP and RPF including World Bank Group standards applicable to environmental management for this project. The Contractor shall take proactive steps to ensure that the standards in the c-ESMP are met during all phases of construction. These shall include, but not be limited to, the following:  Employment of competent and dedicated members of staff to oversee the implementation of the c-ESMP. All employments and replacements of staff responsible for the environmental and social management of the contract shall be subject to the Managing Contractor’s and CTT’s approval.  Active participation of such staff in the planning, construction and re- instatement of the works  Regular interaction with the Managing Contractor’s environmental and social staff In addition, the Contractor will prepare and implement its site-specific Contractor ESMP and where required RAP/ARAP/LRP. Staff must be instructed about the relevant environmental and social sensitivities and the specific measures that each employee will implement to meet the environmental and social protection and management standards defined by the c-ESMP. In addition, the Contractor will prepare and implement its site-specific Contractor ESMP. Construction Contractor The Construction Contactor’s Environmental and Social Coordinator Environmental and Social (ESC) is an employee with extensive environmental and social work Coordinator (ESC) experience. The EC shall liaise with any consultants or specialists, as necessary, during the course of the project. The ESC shall monitor environmental and social performance on the project and shall review monthly non-conformance reports. The ESC shall liaise with the Managing Contractor regarding any significant non-compliance by the Construction Contractor and the steps to be taken to rectify this. The ESC shall provide support to the ESOs and CLOs and shall review the ESO/CLO monthly reports. The ESC shall update the c-ESMP, when necessary, based on experience of the works. Any updates shall be submitted to MITADER for authorisation, as well as the World Bank for No Objection (N/O). The ESC shall oversee the re-instatement of the site and provide final sign-off following acceptable re-instatement. Together with the CTT Environmental Site Officer (ESO) and CTT Liaison Officer – Community and Stakeholder Affairs (LOCSA), the EC shall initiate, coordinate and manage all necessary communication with the Government (local, provincial and national) via the Government of 31 March 2019 18103533 Item Refers to Mozambique’s (GOM’s) environmental representative based in Maputo and in the Provinces and Districts. CTT Liaison Officer – The LOCSA is the CTT officer responsible for all ongoing communications Community and with communities and stakeholders affected by CTT’s operations in Stakeholder Affairs Mozambique. This is a permanent position. (LOCSA) The LOCSA shall guide the CLO(s) appointed under the management contractor’s staff, where necessary, and shall introduce the CLO(s) to the community leaders in the areas in which the project is situated. The LOCSA shall review the ESO/CLO monthly reports The LOCSA shall interact with the ESC on matters of common interest and shall review non-conformances in the monthly reports. Together with the ESC, the CTT Environmental Site Officer (ESO) and CTT LOCSA shall initiate, coordinate and manage all necessary communication with the Government (local, provincial and national) via the Government of Mozambique’s (GOM’s)environmental representative based in Maputo and in the Provinces and Districts. CTT Local Procurement Implement enterprise and supplier development strategies, tactical plans Officer including the required supporting business and governance processes, procedures, systems and tools in order to enable CTT to meet its preferential procurement and CTT targets for all of its Mozambique local content requirements.  Identify, nurture, grow and leverage both internal and external partnerships necessary to successfully execute the local content strategy particularly as it relates to Enterprise Development, Supplier Development and Local Procurement (Local Content Strategy/Plan)  Oversee the management of the delivery of business and technical support activities provided to CTT’s Enterprise and Supplier Development beneficiaries. CTT Community Liaison Community Liaison Officers (CLOs) shall be appointed under the Officer (CLO) Managing Contractor’s staff as the principal interface between the community and the Construction Contractor during construction. The CLO(s) shall be full time employees for the period of the contract in the case of all projects for which authorisation has been required by MITADER. The CLO(s) shall act as a guide and advisor to the Construction Contractor in respect of the c-ESMP concerning communication and local community issues. This shall be achieved by ongoing liaison with and monitoring of relations with communities, identification of problem areas and supporting their resolution. The CLO(s) shall report directly to the Site Engineer. Where advice about community issues is required, the CLO shall notify and request assistance from the LOCSA. 32 March 2019 18103533 Item Refers to The CLO shall comply with all requirements for ongoing communication with affected communities during the construction period. Responsibilities of the CLO shall be set by CTT and will include the following:  To keep communities informed about upcoming construction activities and progress with construction  To arrange occasional visits to construction sites for District Government and community leaders  To provide traffic safety educational programmes to those communities near or on access routes that will be used by construction vehicles  To support CTT in the implementation of the Project Labour Agreement by communicating to government, village leaders and community members the aims and objectives of CTT’s transparent recruitment approach for unskilled temporary construction workers, aimed at providing maximum benefit to and fair job distribution between locally affected communities  To liaise between CTT, the Managing Community Liaison Officers, the community and NGOs/service providers implementing community projects for the construction phase  To communicate and manage the CTT Compliments and Complaints Register  To report any transgressions of foreign construction workers in the communities to the Site Engineer and the CTT EC  Prepare monthly reports with the ESO.  Provide guidance on and evaluate the implementation of the social aspects of the ESMP. The core competencies and job descriptors of the CLO need to reflect the substantive role of CLOs (or other project social specialists) in implementing the social management plans and social aspects of the mitigation measures beyond purely communications in a manner more comparable to the role of the ESO. The CLO(s) shall preferably be hired from the District in which the Project is proposed, shall be trained by the Managing Contractor and LOCSA about all relevant aspects of the project, shall have experience in communication with communities and local and district authorities and shall be able to communicate in local languages. He/she shall be capable of evaluating the effectiveness of specified social management measures and shall further be capable of proposing solutions to problems identified in respect of the implementation of the c-ESMP. CTT Environmental Site The Environmental Site Officer (ESO) shall be appointed under the Officer (ESO) Managing Contractor’s staff and shall be employed on a full-time basis for the duration of the contract phase (this appointment will likely extend into operational phase). The ESO shall perform all tasks necessary to monitor the performance of the contractor with respect to the environmental 33 March 2019 18103533 Item Refers to specifications in the c-ESMP. Specific responsibilities of the ESO shall be as follows:  Ensure the protection of the environment  Perform all of the day-to-day tasks necessary to monitor the performance of the Contractor(s) with regard to the requirements of the c-ESMP  Liaise with the Site Engineer and CTT EC in the case of incidents, non-conformance or any matter where the course of action is unclear  Verify the accuracy of the information contained in the c-ESMP and bring any errors, omissions, oversights to the attention of the Managing Contractor and EC  In consultation with CTT’s EC, guide all aspects of the re-instatement process  Prepare monthly reports with the CLO(s). The ESO shall be fully briefed about the project, and receive any necessary training from the Managing Contractor and the CTT EC. Through the Site Engineer, the ESO shall guide and advise the Contractor in respect of compliance with the c-ESMP on environmental issues during the construction phase of the project. This will be achieved by ongoing internal coordination meetings, inspections / monitoring of the project, identification of problem areas and provision of action plans to avoid environmental damage. The ESO shall liaise frequently with the CLO(s) and with the Contractor’s environmental staff (Environmental Control Officer). The ESO shall have experience in environmental management. He / she shall be capable of evaluating the effectiveness of specified management measures and be familiar with environmental management techniques. He / she shall be capable of proposing solutions to problems identified in respect of the implementation of the c-ESMP. Specialist Environmental / The Managing Contractor shall employ the services of an environmental Social Consultant (Project and social specialist(s) as and when required during construction and Implementation) project implementation to ensure compliance with the requirements of the c-ESMP or to advise about environmental sensitivities that were previously unknown and are not adequately dealt with in the c-ESMP. This Specialist shall be either a person(s) directly employed by CTT, where the expertise is available, or a consultant, where the expertise is not available, as determined by the Scope of Work prepared by the ESC or ESO. The Specialist shall report directly to the ESC. Responsibilities of the environmental and social specialist shall be set by the ESC. The specialist shall have a demonstrated track record in the specific environmental or social aspect under consideration. The specialist shall advise CTT of any appropriate actions to be taken and recommend any necessary changes to the c-ESMP or RPF. 34 March 2019 18103533 Item Refers to Environmental and Social An Experienced, independent, environmental and social expert(s), familiar Auditor with auditing requirements and procedures for Environmental, Social, Health and Safety audits, appointed to audit the project every 3 months (quarterly) during the first year of construction and twice a year thereafter until the end of the construction period. The auditor(s) shall prepare a report documenting the effectiveness of environmental management, problem areas, remedial actions proposed and taken, and compliance/non-compliance by the Contractor(s) with the project standard. The specific audit objectives, the individuals and organisations that the auditor proposes to meet, the documentary evidence of performance and the locations on site that are to be visited during the audit shall be decided in pre-audit discussions with the CTT ESC. The auditor findings and corrective actions for project closure and future project are to be included in CTT’s 6-monthly reporting to MITADER and Lender as required. *Additional roles for an Environmental Manager and/or Environmental Control Officer and/or a Health and Safety Officer may be included depending on the final CTT project organogram once adopted. It should further be noted that the term “environmental” encompasses the bio-physical and socio-economic environment. Figure 13: Responsibilities for environmental and social management during construction of the CTT’ project 35 March 2019 18103533 4.3 Communication with Government, Communities and Stakeholders All communication with the Mozambique Government regarding environmental management matters shall be via CTT’s Environmental Coordinator and Liaison Officer – Community and Stakeholder Affairs (LOCSA). All communication with local structures shall be undertaken by the Community Liaison Officer(s) (CLOs) appointed for the construction period, with assistance, where necessary, from the LOCSA. CTT aims to engage respectfully and in a timely manner with all relevant stakeholders. The Stakeholder Engagement plan details its approach in relation to communications with stakeholders. Note: All communication with the Mozambique Government regarding construction matters shall be via the CTT Management (Communication Manager). All communication with local structures shall be undertaken in conjunction with the CTT Communications Manager and CLO appointed for the construction period. 4.4 Environmental and Social Management System (ESMS) There are three main tools for environmental and social management at the CTT:  The Environmental and Social Impact Assessment / Study (ESIA);  The Construction Environmental and Social Management Plan (c- ESMP); and  The Environmental and Social Management System (ESMS). In addition, the ESMS will include the operations ESMP and decommissioning ESMP’s. The ESMP is intended to guide impact management and mitigation associated with the CTT. It converts ESIA mitigation measures into actions and allocates responsibility and deadlines to those actions. The ESMS confirms management commitment to the ESMP and describes how the requirements of the ESMP will be achieved. It sets the management framework in terms of environmental organisational structure, reporting, review and monitoring, training and public disclosure. The Managing Contractor, in conjunction with the ESO and EC is to ensure that a suitable management system is implemented to ensure compliance (and be able to demonstrate compliance) to the ESMP. A comprehensive ESMS aligned to IFC ESMS Implementation Handbook – General (2015) and ISO 14001:2015 standards will be developed and implemented, inclusive of the following system elements: 1) Policy; 2) Identification of Risks and Impacts; 3) Management Programmes; 4) Organisational Capacity and Competency; 5) Emergency Preparedness and Response; 6) Stakeholder Engagement; 7) External Communications and Grievance Mechanisms; 8) Ongoing Reporting to Affected Communities; and 9) Monitoring and Review. 36 March 2019 18103533 5.0 ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN 5.1 Register of Activities The management requirements presented in this section have been compiled in rough order of construction activities. While specifications have been listed under activities, the requirements are not necessarily mutually exclusive to the activity under which the specification or requirement is listed. Should any specification be applicable to any other activity, listed or otherwise, the intent remains. For each activity identified, the following items are specified in the management plan: Ref.: A reference number for the specified management requirement / specification. Management requirements: Detail on the management requirements / specifications required. Responsible party: The person that will assume overall responsibility for ensuring that the requirement / specification is met. Scheduling: The date by which the requirement shall be achieved. Should the requirement be applicable throughout the life of construction phase or a period thereof, the date will be indicated as ‘ongoing’. Compliance/Performance indicator(s): Indicates means to determine if the requirement has been met and verified. Additional monitoring requirements are specified under Section 6.0. Note that the number of incidents, audit findings etc. shall also be used as indicators of performance. 37 March 2019 18103533 5.2 Project Planning 5.2.1 Pre-construction Requirements Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s)or verification 5.2.1.1 Authorisation granted Should authorisation for this project be granted by MITADER, it shall be CTT Pre-construction - As per by MITADER attached to this ESMP and updated were required in order to comply with any Specialist as a basis for requirement specific conditions set out by the authority. Environmental licensing of the Consultant activity 5.2.1.2 Avoidance of All project infrastructure shall be designed to minimise impacts on the natural CTT Pre-construction No damming of obstruction to surface flow of water. For linear infrastructure, this shall include appropriately sized and Managing water or water flow positioned drains, culverts etc. Other infrastructure shall be located to avoid Contractor obstructions to impact on seasonal and permanent water courses and on stormwater drainage All contractors water flow in general. Where linear infrastructure must cross seasonal or permanent drainage lines, measures must be taken to ensure that the infrastructure has limited impact on the receiving environment. 38 March 2019 18103533 5.3 General Administration and Liaison 5.3.1 Administration and General Issues Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification 1 5.3.1.1 Release of Relevant SHE requirements extracted from the ESMP will be Supply Chain (SC) Manager At the time of Inclusion of ESMP as release of requests part of relevant tenders contracts included as part of tender documentation and form part of contracts for quotation. (RFT) and contracts. when the scope of the work to be conducted or service to be At the time of provided can impact on the environmental performance of the CTT. contract preparation. 5.3.1.2 Compliance In all cases, the requirements of Mozambican legislation shall be At all times Project records with legislation met. Should this not be possible for any reason, CTT shall be Construction Contractor Absence of legal immediately notified of any breach, or pending breach. This warnings / prosecutions notification shall be accompanied by full details of the contravention ESO/CLO monthly or pending contravention and shall be accompanied by a corrective reports with reference to action plan. legal non-compliances 5.3.1.3 Compliance of The main contractor shall be responsible for ensuring the compliance Construction Contractor At all times Evidence of compliance sub- of sub-contractors with all aspects of this c-ESMP (all references to by all sub-contractors contractors the Construction Contractor means the main contractor and all sub- contractors). 1 Performance indicators are only specified where there may be additional requirements to the verification that the requirement / specification have been met. Additional monitoring requirements are specified under Section 6. Note that number of incidents, audit findings etc. shall also be used as indicators of performance. 39 March 2019 18103533 Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification 1 5.3.1.4 Working period All construction work shall be restricted to between the hours of Construction Contractor At all times ESO/CLO monthly and work 06h00 and 18h00 unless otherwise approved by CTT following reports. hours consultation with affected communities. Work hours will also need to Absence of complaints comply with local labour laws. Any approved night work shall not Contractor’s reports on create a nuisance in surrounding communities. weekly hours worked by The beach landing activities will only be permitted during daylight personnel hours and are to occur outside of the peak tourist periods (November-January, Easter and during any important tourist events that may occur such as fishing competitions as far as practical). 5.3.1.5 Personnel A site and project-specific HSE induction shall be drafted prior to Construction Contractor Prior to employment Inclusion in training / management commencement of construction and be presented to all employees Environmental Coordinator induction programme(s) before they start work on the Project. The EC shall approve the Register of attendance content of the induction. A register shall be kept by the Contractor of of induction all personnel who attend the induction. 40 March 2019 18103533 Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification 1 5.3.1.6 Bush fire A procedure for the prevention and control of bush fires shall be Construction Contractor At all times. Inclusion of smoking prevention and prepared. The procedure shall include, but not be limited to, the Environmental Coordinator areas management following: in training / induction  Sources of fire risk programme(s)  Measures to comply with any requirements of local authority fire departments  Measures to minimise the risk of accidental bush fires caused by any activity related to the works Measures to control an accidental bush fire. Smoking is only permitted outside and in designated areas and where there is no risk of starting bush fires (subject to normal safety precautions in terms of flammable materials). 5.3.1.7 Work site Workers shall not be employed at the gate of any work site. Construction Contractor At all times. No soliciting of work by employment workers observed at the campsites or work locations 5.3.1.8 House-keeping The work place shall be kept tidy and free of litter at all times. Construction Contractor At all times Inclusion in training / induction programme(s) Absence of litter on site 5.3.1.9 Disciplinary Appropriate disciplinary procedures shall be taken against offenders Construction Contractor At all times Evidence of disciplinary procedures by the contractor’s management in the event of deliberate non- procedures where compliance with any of the specifications in this c-ESMP and deliberate non- notification shall be given to the Site Engineer of the actions taken. compliance is registered 41 March 2019 18103533 Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification 1 5.3.1.10 Alcohol and No alcohol or narcotic substances shall be permitted on site at any Construction Contractor At all times Records of disciplinary drug use work site or at the construction camp and laydown areas. All aspects procedures of the code of conduct will need to be adhered to by all parties. 5.3.2 Community, Stakeholder and Government Liaison A key management principle during the construction phase of the project shall be that of ensuring that the rights of the inhabitants are not infringed and that all construction activities are conducted in a manner that is respectful of the local residents and the land and resources that belong to them. Most people are tolerant of short-term construction impacts if treated courteously and this shall be a guiding principle of all CTT’s contractors’ activities and relationships with communities. The project area is characterised by the following socio-economic conditions, which shall at all times be taken into consideration:  Subsistence living,  Extreme poverty,  Strong dependence on local natural resources,  Limited access to health and education facilities, access roads (basic services); and  Very limited employment opportunities. All communication shall be in accordance with the CTT Stakeholder Engagement Plan, and as set out, in general, in the specifications below. Note that this section does not contain specifications for liaison in respect of compensation, which is covered under the RPF for this project. Furthermore, the RPF will refer to specific tools (RAP/ARAP/LRP) that may be required to be implemented in certain instances. 42 March 2019 18103533 Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification 5.3.2.1 Management of Community leaders and residents may have expectations that CTT LOCSA At all times Absence of community community will play a supporting and developmental role within the area and that CLO complaints in expectations the project will have other positive economic benefits. In order to complaints register encourage realistic expectations, close communication shall be maintained between local communities and the Community Liaison team (the CTT LOCSA and the Community Liaison Officer/s appointed for the construction period) with the objective of clarifying the limitations to CTT’s involvement in development initiative in project-affected communities. 5.3.2.2 General Access over land, the integrity of fences, control of bush fires, Construction Contractor At all times. Absence of community littering, harassment of domestic and wild animals, sedimentation and LOCSA complaints in contamination of ground and surface waters, damage to landscape CLO complaints register and vegetation, nuisance (noise and dust) and all such environmental matters, shall be controlled in the best interests of the local inhabitants and shall, where necessary, be the subject of open communication between the parties. 5.3.2.3 Communication Prior to construction activities starting, the Managing Contractor, in Public Affairs Coordinator Pre-construction Absence of community plan consultation with the LOCSA, shall prepare a Communications LOCSA complaints in Method Statement, based on the principles and procedures CLO complaints register established in CTT’s Stakeholder Engagement Plan (2018, or as updated), including:  details of stakeholders;  methods of communication at the various levels of Government and among local stakeholders;  responsibilities for communication prior to the start of construction and during the construction phase itself; and 43 March 2019 18103533 Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification  details of the messages that are to be communicated to the different interest groups; Any local areas where there may be particular sensitivities due to proximity to construction activities shall be highlighted and specific additional measures for liaison with the affected people shall be determined. 5.3.2.4 Ongoing Ongoing communications with communities during the construction CLO Ongoing Absence of community community contract shall be the responsibility of the CLO(s). Where construction complaints in consultation by teams are active, the frequency of communication with local complaints register the CLO(s) communities shall be increased. Records of all communication shall be kept and regularly updated. 5.3.2.5 CTT Each construction-affected community shall be provided with a CLO Register to be provided Increase in compliments Compliments Compliments and Complaints Register and informed by the CLOs to local communities and a decrease in and complaints about how to use it. Information about its use shall also be included in prior to the complaints recorded in register (paper the register itself. Marginally literate and illiterate people are to be commencement of any each register copies in encouraged to obtain assistance to use the register or to contact the construction activity. communities, CLO by phone or meet with the CLO on days when the register is Weekly check of electronic checked. register by the CLO database at The Register in each community shall be inspected weekly by the CLO CTT) as a part of ongoing communication and any complaints are to be resolved within 48 - 72 hours. The Register should be structured in accordance with the requirements set out in the CTT Communications Plan. 44 March 2019 18103533 Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification 5.3.2.6 Responsibility The Contractor shall not deal directly with surrounding communities Managing Contractor Ongoing Absence of community for about construction-related issues. The Managing Contractor shall Construction Contractor complaints in communicating bring to the Construction Contractors’ attention any issues that are CLO complaints register with raised by the community that require action. The Construction stakeholders Contractor’s ECO shall stay in regular daily contact with the CLO. When requested to do so by the CLO, the Construction Contractor shall attend community meetings with the Community Liaison Team in order to resolve any issues that have arisen. 5.3.2.7 Prohibition of CTT personnel and its contractors shall not gain access to land Construction Contractor At all times Absence of community access outside of its approved areas of operation without prior consultation complaints in with community leaders and, where considered necessary by the complaints register LOCSA, the affected families themselves. Access by construction personnel to villagers’ private homes is prohibited. The property and rights of all persons shall be respected at all times. No activities that cause damage may be undertaken without prior approval by the regulatory authority, and prior communication with an agreement on appropriate compensation by the affected person/ s, and will need to be conducted in accordance with the approved RPF. 45 March 2019 18103533 5.4 Community Health and Welfare 5.4.1 Nuisance Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification 5.4.1.1 Construction No construction shall take place outside of daytime hours, as Construction Contractor As required Records of working hours working hours defined above, without the written permission of the Managing Managing Contractor Record of Managing Contractor, after due consideration of the potential of the activity to ESO (nigh-time activities) Contractor authorisation create nuisance. Some activities may be required to be undertaken Absence of community at nigh-time but this will be the exception and the approval sought complaints about night from the Managing Contractor, in consultation with the ESO. work 5.4.1.2 Dust Dust caused by construction activities shall be controlled to ensure Construction Contractor As required. Complaints registered by generation and no detrimental effect on landowners, occupants, employees or the CLO Formal monitoring as communities or employees standards public. The contractor shall comply with the Mozambique legal specified by the in the Compliments and requirements and IFC/World Bank air quality guidelines for Managing Contractor Complaints Register suspended particulates, as well as the South African National Records of timeous Standard for dust fallout. These are as follows: corrective action to resolve  Suspended Particulates (Mozambique daily standard): complaints 150 µg/m3 Records of observations in  PM10 (IFC daily standard): 50 µg /m3 ESO/CLO monthly reports  PM10 (IFC annual standard): 20 ug/m3 (Need for use of formal  Settleable dust (SA National Standard for residential monitoring equipment to areas): 600 mg/m2/day be determined by CLOs Where considered necessary by the Managing Contractor, the and ESO, based on construction contractor shall demonstrate compliance with the circumstances on site) above standard by monitoring of dust using passive air quality monitoring devices 46 March 2019 18103533 Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification 5.4.1.3 Batching plant Dust generation from batching plants shall be minimised so as not Construction Contractor During operation of Monitoring of dust levels in to create nuisance in surrounding communities. Control measures batching plant and environment that may be required include sprays, division panels, and direct related activities. Compliance with dust feed from silo to mixer or dust screens. standards at nearest sensitive receptors Complaints recorded in Compliments and Complaints Register 5.4.1.4 Use of water Dust suppression measures to meet the standard shall include dust Construction Contractor As required by visual Availability of sufficient carts to suppression along roads using water carts and, where necessary, observation water spray capacity to suppress road ‘environmentally friendly’ surface binding products to achieve dust prevent dust and work site reduction. The Construction Contractor shall ensure that sufficient Absence of community dust watering capacity is available on site to dampen dust at all work complaints in Compliments areas and along access roads used by construction traffic, and Complaints Register particularly in areas where there are nearby communities. Records of monitoring in ESO monthly reports. (Need for use of formal monitoring equipment to be determined by CLOs and ESO, based on circumstances on site) 47 March 2019 18103533 Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification 5.4.1.5 Control of Noise levels shall be controlled to ensure no detrimental effect on Construction Contractor At all times Complaints registered by noise nuisance landowners, occupants, employees or the public. All vehicles and LOCSA communities or employees equipment shall be fitted with noise suppression, as appropriate, CLO in the Compliments and and operated and maintained at all times in conformity with the Complaints Register manufacturer’s specifications, instructions and manuals. Records of timeous corrective action to resolve complaints Records of monitoring in ESO weekly and monthly reports 5.4.1.6 Noise The Construction Contractor shall comply with the World Bank Construction Contractor As required Complaints registered by monitoring guideline for daytime noise affecting communities (Laeq of 55 dBA, Managing Contractor communities or in the measured at the receiver). In cases where there is evidence of employees Complaints noise nuisance based on field observations by the Managing Register Contractor, or based on complaints received, the Construction Records of timeous Contractor shall take measurements to verify noise levels being corrective action to resolve generated by construction work and shall take the necessary complaints corrective action taken. Records in ESO monthly reports Monitoring results, when required by the ESO/CLO 5.4.1.7 Open The CLO(s) and ESO shall communicate regularly with households CLO As required Records of regular communication and other receivers living close to construction activities where ESO community liaison and with noise and dust are potentially affecting them. Most people are discussion about nuisance households tolerant of short term nuisance when treated courteously and when issues efforts are made to minimise their issues of concern. 48 March 2019 18103533 5.4.2 Population Influx and Social Pathologies Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification 5.4.2.1 Early Prior to any activities commencing on site, a Communication Plan Public Affairs Coordinator Pre-construction Inclusion of recruitment communication shall be prepared in line with the Stakeholder Engagement Plan, LOCSA issues in the of CTT including national coverage and community communication Communication Plan recruitment campaigns, starting prior to establishment on site, and strategy communicating the following CTT policies:  No hiring of job seekers on site,  No procurement at the gate,  Employment selection in agreement with agreed procedures by the Community Liaison Forum,  Maximising local content in procurement i.e. from local people and towns, whenever possible, and whenever project requirements are met (Local Content Plan). 5.4.2.2 Information Information meetings shall be held with Government and in all Public Affairs Coordinator Pre-construction and Communication in meetings affected villages, explaining the negative impacts of population LOCSA ongoing accordance with influx, the company’s recruitment policy and verification process requirements of for appointing only local people for unskilled work, and Communication Plan and harnessing their support to reduce influx of work and opportunity Communication Method seekers. Statement Records of meetings 5.4.2.3 Appointment of All unskilled employment shall be from local project-affected Construction Contractor As required by the All unskilled employment local personnel villages, if sufficient numbers of applicants are available who LOCSA Construction Contractor requests channelled comply with project requirements for unskilled workers. through the CLF Recruitment of unskilled labour shall be in accordance with the Employment as per the agreed procedures of the Community Liaison Forum (CLF), a part procedure agreed by the 49 March 2019 18103533 Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification of whose mandate is to provide CTT with unskilled personnel CLF based on a fair and transparent selection process. Number of employment selection issues registered in the Complaints Register 5.4.2.4 Record keeping Records shall be kept of the number of communication initiatives LOCSA Ongoing Records of meetings nationally, in the Province and District and in the nearest CLO Records of construction communities. Updated records shall also be kept of the number employment to local people of construction jobs awarded to people verified as ‘local’ , women Surveys of interviews with and other vulnerable people from the communities, as well as village community leaders from the District, Province and Nationally. Survey results shall be about in-migration maintained from interviews with village leaders about increases in numbers of new arrivals. 5.4.2.5 Exposure to  Employees to sign a code of conduct prior to the LOCSA Ongoing No complaints recorded in Gender based commencement of work; CLO register. No incidents or violence (GBV)  Access to the construction site must be controlled to Security Manager cases reported of CTT and sexual prevent sex workers from entering the construction camp; personnel relating to GBV exploitation and  Implement GBV and SEA campaigns (including educational and SEA recorded by abuse (SEA) awareness around risks such as sexually transmitted Police diseases) in the project affected communities; and Dismissal / disciplinary  Develop and implement SEA/GBV Prevention and action taken against Response Plan (also aligned with Community Health, employees that breach the Safety and Security Plan) code of conduct 50 March 2019 18103533 Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification 5.4.2.6 Physical and  Seek to re-align the transportation route and water pipeline Project Design Ongoing Decrease the amount of economic route to avoid any sensitive receptors along the routes (and CTT Management physical or economic displacement within the PPZs/RoW) and thus the need for resettlement or LOCSA displacement numbers as compensation (associated with the southern transport route CLO far as possible options); and  If resettlement or compensation is unavoidable, then Project-affected people must be identified and compensated accordingly viz.; in line with the process outlined in the RPF or further resettlement plans if required, which are in accordance with national legislation and IFC standards. 5.4.2.7 Disturbance to  Communication, Safety and awareness measures (such as Project Design Ongoing No complaints recorded in fishing activities educational campaigns) should be put in place to alert and CTT Management register due to (Bazaruto Bay inform community members about the duration, nature and LOCSA barging/transhipment area) schedule for the delivery of heavy equipment and pre- CLO activities as part of beach fabricated components which will be transhipped and landing that are interfering barged to the beach landing site. with local fishing activities  Compensation: If there is an economic loss or displacement (artisanal and requiring compensation, then this will be handled in commercial/sports fishing). accordance with the process set out in the RPF. 51 March 2019 18103533 Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification 5.4.2.8 Socio-economic Possible mitigation measures are identified that will minimise the Construction Contractor Ongoing No complaints recorded in impact on impact on Tourism in the area: Public Affairs Coordinator register due to Tourism industry  Maintain the practice of operating the beach landing LOCSA barging/transhipment activities outside of peak tourist seasons (November- CLO activities as part of beach January and outside Easter Holidays, as well as major landing that are interfering tourism events such as fishing competitions); with local tourism activities  Restrict the offloading to the daytime periods, and and/or tourism numbers  Only use the local Inhassoro facilities to accommodate the Records of local involved contractor staff associated with beach landing accommodation being used activities. at Inhassoro for contractors  Any extra accommodation required for CTT and that cannot and third parties involved be met at the construction camp, is to utilise Inhassoro with the project via the accommodation facilities. contractor  Compensation: If there is an economic loss or displacement requiring compensation, then this will be handled in accordance with the process set out in the RPF. 5.4.3 Communicable Diseases Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification 5.4.3.1 Management of The Construction Contractor shall prepare and implement an STI Construction Contractor Before site establishment CTT-approved STI sexually Management Plan designed to minimise the spread of HIV Public Affairs and ongoing Management Plan, as well transmitted infection and other STI’s. The plan shall be prepared with the Coordinator as ancillary plans infections (STIs) assistance of a specialist in sexually transmitted diseases. A Number and nature of typical plan would include, among other things, the following initiatives in communities measures: as per the Plan 52 March 2019 18103533 Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification  An HIV/AIDS training course and on-going education requirements on transmission of HIV/AIDS and STIs, to employees, through workshops, posters and informal information sessions;  Encouragement of employees to determine their HIV status;  Supply of condoms at the construction site(s);  Development of a comprehensive construction Camp Management Plan, including rules for on-site behaviour, entrance and exit policies and prohibition of sex workers on site. The plan shall be submitted to and approved by CTT prior to implementation.  Develop a Community Health Information System (CHIS) to collect and monitor key community health indicators in a longitudinal fashion. This may require specific Health Systems Strengthening (HSS) in the local health facilities so that they can be used as a reliable source of information, and potentially support of Community Health Agent/ Agent Polyvalent Communitaire (CHA/APE) in the respective communities. There may be a need to support better diagnostics for TB in the study area and reporting on the District Health Information System (DHIS2). Develop workplace health strategies as part of the occupational health plan or organisational health plan, to include:  A communicable disease strategy or c-EMP that has an initial workplace (including contractors and short-term 53 March 2019 18103533 Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification labourers) focus, with the view to extend to manage potential community health impacts. It is important that core interventions are implemented at an early stage so that these are in place prior to the start of construction. The focus of the programmes should include malaria control, HIV/AIDS, TB and STI control and general and personal hygiene. This plan can potentially be expanded on the c-EMP developed for the CPF to include elements such as HIV, but also TB and other communicable disease risks that may originate from the workforce. This plan will need to have specific CMR provisions;  Plan and manage construction accommodation camps so that overcrowding does not occur during development of the Project. Develop a Camp Facilities Management c-EMP based on the IFC workers accommodation and camp facilities standards where applicable (25);  Ensure adequate space is available to reduce the need for any externally contracted workforce to stay in the surrounding community as this will place pressure on available housing and potentially increases rentals;  Develop a vaccine preventable disease programme for all employees, contractors and visitors based on risk for travellers and at risk occupations;  Develop effective fitness to work procedures and programmes (especially in-coming contracted workforce) to reduce communicable disease 54 March 2019 18103533 Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification transmission by implementing an effective pre- deployment screening process for TB and other communicable conditions. Specific CMR provisions should be part of the procedure; and  Develop and/or extend outbreak preparedness policies and programmes to reduce the impact of any suspected or confirmed outbreak at the local level.  Support HSS with improved case detection and case management of TB especially from the three health centres and with support of APE programmes; and  Support with development and extension of community based integrated management of childhood illness programmes in APEs. 5.4.3.2 Mosquito vector The Construction Contractor shall prepare and implement a Construction Contractor Prior to the CTT-approved Malaria control, malaria management plan and shall align its malaria control Public Affairs commencement of Management Plan avoidance, strategy with the CTT’s communicable disease strategy, which Coordinator construction activity and Record of actions taken in diagnosis and includes vector control (such as malaria control), avoidance, Environmental ongoing accordance with the treatment diagnosis, treatment and training. Coordinator Malaria Management Plan The plan shall be submitted to and approved by CTT prior to Records of ongoing training implementation of employees in respect of malaria avoidance 5.4.3.3 General  Ensure that no waste whatsoever, including operational CTT Management; Ongoing Employee Health Communicable waste, is dumped in watercourses or at any site that impacts OHS division; Awareness Policy and Non- on villagers or their land use; Contractors; and implementation; Communicable Supervisors. Minutes of liaison meetings with local authorities; and In-situ proof of distribution 55 March 2019 18103533 Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification Disease Related  Ensure that the CTT use of water does not disturb public of printed posters, leaflets Impacts water availability and that sources of water are carefully and leaflets at health clinics selected; and community meetings.  Ensure the development of a water and hygiene code of conduct that prohibits open defecation/urination, stresses the proper water use, water conservation, hygiene and sanitation to prevent pollution of community water sources;  Evaluate opportunities for health systems strengthening (HSS) with government and key partners for improved case detection and treatment of TB;  Support community-based information, education and communication (IEC) campaigns to promote improved knowledge and awareness of TB, other infectious diseases and their associated determinants;  Reassess project impacts on community-dependent ecosystem services and develop corresponding mitigation measures. This includes the design and development of appropriate environmental health programmes to reduce the potential risk of airborne pollutants such as dust, which may impact on community health;  Develop educational materials regarding the prevention of water, sanitation and waste related diseases;  Monitor changes to footprints of animal husbandry activities adjacent to the CTT facilities; and 56 March 2019 18103533 Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification  Support the improvement of veterinary public health services in the project area, including preventative programmes such as vaccinating and sterilising dogs, vaccinating livestock and the control of the public slaughter of livestock. 5.4.4 Traffic and Pedestrian Safety Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification 5.4.4.1 Site access The Construction Contractor shall submit a Traffic Access and Construction Contractor Prior to site Plan submitted and plan Safety Plan to the Managing Contractor for approval, prior to site Managing Contractor establishment approved establishment, defining the transport routes to be used to and from Records of accidents and the construction work areas and camps, and measures that will be corrective actions taken taken to ensure community safety during construction. 5.4.4.2 Access to the The Construction Contractor shall make every effort to gain access Construction Contractor At all times Limited new access road construction to the construction right of way using existing roads. No new Managing Contractor development. right of way access, haul or maintenance roads (other than that approved within CLO Written authorisation from the ESIA) shall be constructed without the written approval of the Managing Contractor Managing Contractor.If there is an economic loss or displacement where access roads requiring compensation, then this will be handled in accordance necessary with the process set out in the RPF. 5.4.4.3 Speed limits Safe travelling speeds for each section of the route along the right Construction Contractor Ongoing Speed testing, speed limit of way shall be determined and enforced. Enforcement may Managing Contractor signage include, but not be limited to, the monitoring of vehicle speeds, the CLO Absence of community 57 March 2019 18103533 Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification erection of speed limit signs and the installation of speed humps. complaints Emphases on safety aspects amongst project drivers, explicitly Accident records ensuring that drivers respect speed limits through busy and built up areas; 5.4.4.4 Defensive All vehicle operators shall have received defensive driver training, Construction Contractor At beginning of driver’s Records of defensive driver training aimed at promoting improved driver safety performance employment contract driver training Accident records and trends 5.4.4.5 Community CTT shall conduct an ongoing traffic safety awareness campaign LOCSA At intervals during Records of traffic traffic during the construction period, particularly in communities where construction. awareness campaigns awareness construction vehicles will be most active. The awareness training shall be repeated in villages as construction moves into / passes their areas. Furthermore, CTT shall Collaborate with local communities on education about traffic and pedestrian safety (e.g. one road safety campaign at a nearby location once a month). 5.4.4.6 Injuries to In the event of an accident in which a community member is Construction Contractor In the event of an Number of near misses. community harmed, Construction Contractor shall take responsibility for accident. Number and nature of members transporting the injured person to an appropriate health facility accidents involving capable of dealing with the injuries and should cover the cost of the community members person’s medical treatment. (minor to serious) Avoiding dangerous routes and times of day to reduce the risk of accidents. 58 March 2019 18103533 Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification 5.4.4.7 Driver Fatigue Ensuring the roster and shifts structure for the project allows Construction Contractor Ongoing Roster employees plenty of opportunity for sleep and rest between shifts and on their days off; Adopting a proactive approach to managing driver fatigue, based on adequate hours of rest to avoid overtiredness; 5.4.4.8 Vehicle Ensuring contractors maintain vehicles to minimise potentially Construction Contractor Ongoing Maintenance records maintenance serious accidents such as those caused by brake failure commonly associated with loaded construction vehicles; Ensuring contractors compile a list of service schedules of all equipment deployed on site. 5.4.4.9 Pedestrian  Ensure the adoption and implementation of the CTT driving Construction Contractor Ongoing Driving and Vehicle safety and vehicle management plan during initial activities which (Traffic) Management Plan will be adopted for the construction phase. Based on this, Health and Safety Plan CTT shall adopt the best transport safety practices with the goal of preventing traffic accidents and minimising injuries suffered by project personnel and the public, as well as creating awareness amongst the local people and villages about road safety. Other mitigation should include:  Positioning traffic guides at children's crossings to control driver speeds and seeking cooperation with local educational facilities (school teachers) for road safety campaigns;  Implementing safe traffic control measures, including road signs and flag persons to warn of dangerous conditions and children's crossings; 59 March 2019 18103533 Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification  Provision of alternative transport (bus) for the construction workforce where applicable;  Minimising interaction of pedestrians with construction vehicles through collaboration with local communities and responsible authorities (e.g. police) to improve signage, visibility, and overall safety of roads, particularly along stretches located near schools or through busy areas;  Considering additional warning tape at accident-prone stretches and sensitive locations (schools and hospitals) if identified as required  As part of the Beach Landing activities, heavy and abnormal loads will make infrequent trips via either one of the two route options currently being evaluated, however the following additional measures will apply to these movements:  Communicate dates and times of vehicle movements to the communities, schools and businesses along the routes. Educate drivers on potential areas of high pedestrian and cyclist activity; and  Ensure that at least two vehicles accompany every abnormal load; one vehicle in the front and one at the back.  Educate community on dangers of construction vehicles new to their area;  Advertise the dates and times of the abnormal load movements, taking specific care to inform communities that do not have access to newspapers and other forms of media;  Liaison with the traffic authorities about the movement of abnormal loads; and  Upgrade roads and bridge crossing where necessary. The 60 March 2019 18103533 Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification deterioration over time must be monitored and a maintenance plan must be negotiated with the ANE (National Road Administration) with specific mention of the Monitoring and Planning departments that should be consulted.  If there is an economic loss or displacement requiring compensation, then this will be handled in accordance with the process set out in the RPF (which may link to specific tools such as RAP/ARAP/LRP). 5.4.4.10 Increased  EN1/CTT Access northern approach: add minimum 30 m right Construction Contractor Ongoing Driving and Vehicle construction turning lane with a 45 m taper to allow for safe queuing. (Traffic) Management Plan vehicle traffic EN1/CTT Access northern approach: add minimum 30 m left turning lane with 45 m taper;  Cover materials with tarpaulins where possible alternatively wet sand and/or provide other means of protection. Treatment of dirt/sand roads near communities would be advisable;  Indicate areas where heavy vehicles will be expected with adequate signage;  Clearly indicate pedestrian crossings;  Educate drivers on potential areas of high pedestrian and cyclist activity;  Educate community on dangers of construction vehicles new to their area; and  Upgrade roads and bridge crossing where necessary. The deterioration over time must be monitored and a maintenance plan must be negotiated with the ANE (National Road Administration) with specific mention of the Monitoring and Planning departments that should be consulted. 61 March 2019 18103533 Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification 5.4.5 Violence and crime Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification 5.4.5.1 Violence and  Sensitise and build the capacity of local governance systems CTT Management; Construction Documented proof of crime (village chairperson and councillors at the settlement level), OHS division; implementation of violence including the establishment of checks and balances for Contractors; and crime mitigation maintaining individual rights and responsibilities and for Supervisors; and measures and monitoring; managing crime; Community liaison officers.  Identify mechanisms for constructively incorporating traditional (clan) leaders into processes for promoting stability and moral ‘regeneration’ at village level;  Promote the development of a disciplined policing forum for the area, in collaboration with appropriate civil society organisations as well as the Police Department; and  Ensure the development of appropriate mechanisms as part of the CHSSP (current Framework to be expanded on). 62 March 2019 18103533 5.4.6 Fire Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification 5.4.6.1 Fire outbreak  Manage the risks of fire through specific management CTT Management; Construction Site and management requirements for hot works and through education of OHS division; meeting minutes and personnel about careless behaviour in respect of cigarette Contractors; directives to improve smoking; Supervisors; and performance in respect of Community liaison community safety,  Promote the establishment of village level fire-fighting and officers. generally; and emergency preparedness capacity, including the sourcing of Reported community safety fire-fighting equipment capacity; and and fire related incidents  Promote awareness amongst members of the settlements against the baseline to about potential fire hazards and mechanisms for promoting gauge intervention efficacy household safety from fires and impact. 5.5 Biodiversity 5.5.1 General Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification 5.5.1.1 Previously Where small areas of high biodiversity are encountered during Construction Contractor During surveying or Records of ECO training undiscovered surveying or bush clearing for road or transmission line / pipeline Managing Contractor bush clearing to identify hotspots biodiversity infrastructure, that were not identified in pre-construction studies, Environmental Coordinator Records of ECO hotspots consideration shall be given to slight re-alignment of the accompanying surveyors infrastructure. and dozer operators during bush clearing 63 March 2019 18103533 Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification Bird flight diverters shall be installed along the transmission line to Records of biodiversity reduce collisions, prioritizing areas with higher presence of hotspots and avoidance vultures and other vulnerable bird species, with at least 3 meters measures taken between the conductors. 5.5.1.2 Collecting or The harvesting or collection of fruits, vegetables, grains and other Construction Contractor At all times. Inclusion of prohibition in harvesting plant material by CTT Employees or the Contractor for use or sale training / induction fruits, is prohibited. programme(s) and vegetables, contractor tool box talks grains and any Absence of evidence of other plant plant harvesting by material employees Evidence of disciplinary procedures in the event of non-compliance 5.5.1.3 Hunting or Hunting, harassing or capturing of wild animals for sale as pets Construction Contractor At all times. Inclusion of prohibition in harassing wild shall be prohibited. training / induction animals – The purchase of wild animals for food by CTT employees and programme(s) and including Contactors shall also be prohibited. contractor tool box talks fishing Absence of evidence of hunting or animal harassment by employees 5.5.1.4 Habitat In order to minimise the impacts on the in-stream habitats during Construction Contractor At all times Records of ESO change construction of the proposed CTT Project, the following mitigation Managing Contractor accompanying measures are required: Environmental Coordinator contractors during 64 March 2019 18103533 Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification  The construction of the Govuro River crossings should take ESO construction works in place during the dry season so as to limit the intensity of these areas impact, particularly in terms of flow diversion and runoff of Records of monitoring sediments; and rehabilitation of riparian areas after  Implement low impact construction techniques to minimise the construction activities impact on the river system, especially during the diversion of any water during construction;  Where possible, keep construction activities out of the riparian areas, floodplain, inland depressions and macro channel:  Vegetation clearing should be restricted to the proposed development footprints only, with no clearing permitted outside of these areas; and  Areas to be cleared should be clearly demarcated to prevent unnecessary clearing outside of these sites.  The alignment of the road should be routed to avoid impacting the adjacent floodplain and inland depressions and any non- perennial bodies of water;  A suitable rehabilitation programme should be developed and implemented in all disturbed areas. The programme should include active re-vegetation, using locally-occurring indigenous grass and tree species; and  Monitoring the water quality and habitat downstream of the river crossing sites during construction on an at least bi-annual basis and implement an early warning system that would 65 March 2019 18103533 Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification trigger a survey of the biological responses, should water quality or habitat alterations warrant this. 5.5.1.5 Habitat Loss The final layout of the CTT Plant and the exact position of the Construction Contractor At all times Records of ESO powerline has yet to be confirmed. At this stage, only a conceptual Managing Contractor accompanying layout is available. Proposed mitigation measures for this facility are Environmental Coordinator contractors during thus focused on avoiding clearing important ecological features as ESO construction works in far as possible, and limiting the extent of clearing to the absolute these areas necessary for project activities: Records of species rescue and relocation  A targeted survey should be undertaken during the Records of marked trees wet/growing season of the CTT footprint to locate, record and and designs/re- mark important ecological features, such as large trees (DBH alignment of >20 cm), geophytic plants and termite hills that should be infrastructure and avoided during construction activities. Based on collected cleared areas where data: possible.  As far as possible, proposed infrastructure should be inland pan/depression positioned to avoid clearing large trees (DBH >20 cm) and habitats successfully termite hills. Particular tree species that should be avoided avoided during vegetation clearing are Afzelia quanzensis and Dalbergia melanoxylon;  If avoidance is not possible, replacement trees should be planted during rehabilitation at a ratio of 3:1, (i.e. three 66 March 2019 18103533 Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification replacement trees of the same species, for every individual tree lost); and  Geophytes growing within development footprints should be rescued and relocated to adjacent areas of undisturbed natural habitat.  If selected as the preferred road option, the alignment of the upgraded Shortcut Road should be re-routed to avoid impacting the adjacent inland pan/depression habitats;  A suitable rehabilitation programme should be developed and implemented in all disturbed areas. The programme should include active re-vegetation, using locally occurring indigenous grass and tree species:  Areas that should be considered priority sites for stabilisation and rehabilitation post-construction should they be negatively impacted include: a) coastal dunes at the selected beach landing site; b) Govuro River crossing point, and c) inland pan/depression habitats adjacent to the proposed Shortcut Road. 5.5.1.6 Death / Injury  An ECO should be on-site during vegetation clearing to Construction Contractor At all times Records of ESO to Fauna monitor and manage any wildlife-human interactions. The Managing Contractor accompanying ECO should be trained in inter alia, snake handling. The ECO Environmental Coordinator contractors during shall relocate slow-moving wildlife (snakes, tortoises, etc.) to ESO clearing areas. safe areas outside the project work zones; ESO training records for snake handling. 67 March 2019 18103533 Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification  Fences (or other suitable obstacle/deterrent) should be Records of training for erected to prevent fauna gaining access to construction areas, construction personnel such as open trenches and voids; on safe driving speeds, communication of  A low speed limit (recommended 20 - 40 km/h) should be policies to employees. enforced on site to reduce wildlife-collisions;  The handling, poisoning and/or killing of on-site fauna by construction workers and contractors must be strictly prohibited; and  This prohibition needs to be clearly stated in project management policies and communicated to all employees and contractors through suitable induction training and on-site signage. 5.5.1.7 Secondary  Monitor the progression of secondary habitat transformation Environmental Coordinator Every 6 months Visual comparisons and habitat using aerial/satellite imagery to identify any problem areas and ESO report assessing the loss/modificati target for further management actions. extent of change. on (due to Recommendations to resource reduce negative exploitations) impacts. Records of actions taken to address any negative impacts 68 March 2019 18103533 Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification 5.5.1.8 Activities at  New areas of primary dune and beach habitat disturbance and Construction Contractor Ongoing Records of ESO Beach associated vegetation clearance should be minimised Managing Contractor accompanying Landing site wherever possible. Areas proposed for vegetation clearance Environmental Coordinator contractors during (temporary should be clearly marked and no heavy vehicles should travel ESO construction works at jetty beyond the marked works zone CLO temporary jetty construction) Records of rehabilitation  Prohibit access to personnel outside of the defined project after construction works work sites and access roads. Train personnel to understand and removal of the sensitivity of the local environment in induction and temporary jetty ongoing tool box talks; (accompanying  Ecological clerk of works (ECOW) to be appointed for duration photographs) of construction works (temporary jetty);  The Proponent must enforce a complete ban on wildlife harvesting (hunting/trapping/fishing) for all project personnel, including any such activities by any person working on site;  The development of worker and community education programmes by the Proponent, which focus on the value of conservation of species such as sea turtles and dugong, and the generation of tourism potential, can contribute to the alleviation of hunting pressure on affected fauna species and reduce local people’s reliance on consumption of bush meat; and  An Influx Management Plan for the Project will be implemented prior to construction of the project to manage access control, prevent unplanned growth in housing development and 69 March 2019 18103533 Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification promote regional economic development, at the same time reducing pressure on ecosystems of concern and associated species for provision of natural resources.. It will be important that the IMP is developed once all project footprints and activities are finalised in order to develop a plan that responds accurately to project activities and phases. The IMP will be developed by the project Sponsor and managed and implemented by the MC through the ESO and CLO daily. The IMP will also need to be cross referenced and links to the Labour Management Plan for the project. 5.5.1.9 Activities at  Monitor erosion and accretion of sands on either side of the Construction Contractor Monthly water quality Records of monitoring Beach jetty and employ appropriately designed engineering Managing Contractor monitoring for duration (water quality) Landing site measures to prevent any significant impacts on sandy beach Environmental Coordinator of activities Records of rehabilitation (barging and habitat upshore and downshore of the jetty where necessary; ESO after construction works transhipment CLO and removal of activities)  Routes for transfer of heavy equipment should be clearly MMO temporary jetty marked and no heavy vehicles should travel beyond the (accompanying marked works zone; photographs)  Prohibit access to personnel outside of the defined access Records of marine roads. Train personnel to understand the sensitivity of the local mammal observations environment in induction and ongoing tool box talks;  Strict controls should be put in place to ensure that leakages of petrol, oils and/or lubricants from barges, transhipment vessels and heavy equipment are minimised/eliminated. Daily 70 March 2019 18103533 Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification maintenance and monitoring checks of vessels should be conducted;  Frequent monitoring of marine water and sediment quality should be implemented for the duration of transhipment and barging activities, focussing on the anchorage point, landing site and the designated barging route between them;  Strict controls on ballast water management for both barges and transhipment vessels must be enforced by The Proponent, in line with the relevant MARPOL standards (see Section 3.2). High risk ballast water (that coming from ports and coastal waters outside of Bazaruto Bay) should not be discharged within the CHAA under any circumstances. Tank-to-tank transfer of ballast water should be enforced for all barges and transhipment vessels associated with the Project and should be documented and monitored by at all times;  Monitoring for the introduction and/or spread of invasive marine algal and faunal species should be conducted on a regular basis for the duration of barging and transhipment activity, so that any introductions can be addressed timeously.  Strict speed restrictions must be enforced on barges and any other project vessels including the transhipment vessel and any small vehicles that may be used for transport between the vessel and the beach site, to protect Dugongs (and Indian Ocean Humpback Dolphin) from vessel strikes in Bazaruto Bay. The maximum allowable speed should be <5 kmph to 71 March 2019 18103533 Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification allow Dugong to move out of the way of oncoming vessels, minimising the risk of collision;  A Certified Marine Mammal Observer (MMO) must be employed by the Proponent or the Contractor responsible for such activities to observe and monitor all barge and transhipment movements. The MMO will have authority to influence the speed and direction of vessel movements where any potential risks to marine mammals are identified. If useful for reducing collision risks with Dugongs, Indian Ocean Humpback Dolphin, or sea turtles, the MMO or other trained staff shall be aboard a small boat ahead of the barge to spot these marine creatures and ensure that they leave the pathway in front of the barge as well as on the transhipment vessel; and  Barges must be routed via one designated vessel lane that avoids or minimizes overlap with any important areas of seagrass habitat. This lane (200 meters or other appropriate width) shall be marked with buoys in advance of any project- related barge traffic. All project buoys must not be made of Styrofoam (which is often ingested by marine life when small pieces break off and float away). 5.5.1.10 Establishment  The extent of seabed disturbance should be minimised Construction Contractor Ongoing Records of ESO of Anchorage wherever possible. Areas proposed for works should be clearly Managing Contractor accompanying Points Environmental Coordinator contractors during ESO 72 March 2019 18103533 Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification (including marked and no excavation or disturbances should occur construction works at operation) beyond the marked works zone; A revised marine study to anchorage points consider the selection of Records of maintenance  Site-specific surveys for coral reef and endemic gastropods the final anchorage point, of vessels should be conducted in advance of placement of the barge route and landing anchorage points to select locations which would cause least site will be prepared by potential harm to coral reef and/or endemic gastropod CTT and submitted to the populations, as well as other benthic organisms, i.e. to confirm World Bank for No that anchor sites are not on coral reefs or seagrass beds; and Objection  The selected anchorage point shall be located outside of the boundary of the Bazaruto Archipelago National Park and IBA (BANP) as well as popular recreational sites (dive/snorkelling sites), unless such a location is clearly not available or would result in clear markedly greater environmental risks (for example, if the resulting barge shipping lane through sensitive habitat were much longer, thus placing Dugongs at greater overall collision risk). Also, a buffer of at least 250 m should be maintained between the outer extent of the boundary and the anchorage points/navigation routes of the transhipment/barging vessels;  Strict controls should be put in place to ensure that leakages of hydrocarbon fuels, oils and/or lubricants from barges, transhipment vessels and heavy equipment are minimised/eliminated. Daily maintenance and monitoring checks of vessels should be conducted; and 73 March 2019 18103533 Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification  Ensure that all vessels and machinery are in sound mechanical order, do not have any oil leaks and are fitted with appropriate mufflers to minimise nuisance affecting migratory/congregatory seabird species. Other measures include restrictions in operating hours for heavy machinery and vessels. 5.5.2 Bush clearing Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification 5.5.2.1 Minimising The principle of minimising vegetation clearing, and topsoil Construction Contractor During demining and Records of extent of vegetation disturbance shall be followed at all times. Areas to be cleared bush clearing vegetation cleared clearance should be clearly demarcated to prevent unnecessary clearing (including before and after outside of these sites; photographs) 5.5.2.2 Access to work Access to areas to be cleared is to be obtained along existing Construction Contractor At all times Absence of new and sites routes of access only. No new routes or tracks shall be Managing Contractor unauthorised tracks / roads constructed, unless there is no alternative and Managing Contractor provides approval. 5.5.2.3 Width of The width of the construction right of way for linear construction Construction Contractor During bush clearing As per requirement clearing for activities shall be as small as possible. Extent of cleared areas access roads and pipelines 74 March 2019 18103533 Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification 5.5.2.4 Remaining No vegetation shall be cleared outside of the defined construction Construction Contractor At all times No disturbance outside of within the work sites without the approval of the Managing Contractor. Managing Contractor RoW areas. approved right of way 5.5.2.5 Changes to If the Construction Contractor wishes to change an approved CTT Management Prior to route change Record of notification and approved route, CTT shall be notified in advance. The notification shall Construction Contractor any approval(s) alignments include a motivation for the proposed route change. No changes Managing Contractor shall be agreed to that, in the opinion of CTT, result in an Environmental and Social unacceptable environmental or social impact. Any change shall be Coordinator certified by the ESC. If there is an economic loss or displacement requiring compensation, then this will be handled in accordance with the process set out in the RPF. 75 March 2019 18103533 Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification 5.5.2.6 Additional Borrow pits shall be de-mined by an additional 15m around the Construction Contractor During bush clearing As per requirement clearing planned outer limit of the pit in order to ensure that pedestrian and around borrow vehicle access can be maintained around the pit, as well to allow pits for the slopes to be properly contoured during re-instatement. Borrow pit areas will need to be assessed for any sensitivities once these locations are determined, prior to them being opened up and material extracted (biodiversity, cultural heritage, social etc, management plans will need to be developed taking into consideration the measures stipulated in this ESMP and RPF as required). For any new areas that are needed to be opened up (e.g. access roads or additional temporary camps) and that are not covered under the ESIA and ESMP’s, then a method of screening the areas by the ESO needs to take place. Any sensitive areas such as biodiversity, social or cultural heritage features need to be avoided. Furthermore, any impacts to such features will need to be managed as per the ESMP and management plan concerning that specific aspect. Any economic loss or displacement requiring compensation, will be handled in accordance with the process set out in the RPF. A procedure for Ancillary Facilities Screening and Management will need to be developed and implemented for any such new areas (borrow pits, additional roads/access laydown areas or camps etc) 76 March 2019 18103533 5.5.3 Control of Invasive Alien Plants Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification 5.5.3.1 Develop alien  In order to minimise the risk of introduction of alien plants, Construction Contractor Prior to importation of An alien invasive species invasive an alien invasive species control programme must be equipment or vehicles control programme being species control developed and implemented at both temporary construction into the CTT plant developed and programme sites and permanent operational sites; implemented. Records of action taken  The programme must include: and monitoring of affected  The use of both mechanical and chemical control areas treatments, as required;  Provision for periodic follow-up treatments; and  Regular monitoring.  The implementation of the programme should be overseen by an ECO officer during construction, and the environmental manager during the operational phase.  A Pest and Pesticide Management Plan must be compiled by the contractor for approval by the ECO prior to the use of any chemicals. 5.5.3.2 Cleaning of In order to minimise the risk of introduction of alien plants, all Construction Contractor Prior to importation of Records of vehicle and vehicles and vehicles and equipment shall be washed down or sprayed with a equipment or vehicles equipment washdown equipment herbicide before being brought to the CTT plant construction into the CTT plant sites. 5.5.3.3 Booklet of CTT shall prepare a booklet of alien plants, annotated with Environmental Coordinator Prior to establishment on As per requirement alien plants photographs, as a basis for identification and control by the site 77 March 2019 18103533 Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification Construction Contractor. The list of alien plants in Table 4 shall serve as a basis for alien plant control, to be updated from time to time, as necessary. The booklet shall be available on site at the Managing Contractor’s and Construction Contractors’ site offices and shall be provided to the ECO/ESOs. 5.5.3.4 Removal of If alien vegetation establishes during the construction phase, or Construction Contractor Ongoing Records of alien plant alien plants during the Construction Contractor’s warranty period, it shall be removal selectively removed. Table 4 provides guidance about removal strategies and methods for the listed alien plants. 5.5.3.5 Handover of Alien species monitoring, and control shall be handed over to the Environmental Coordinator At end of Construction Record of handover management CTT environmental team after the Construction Contractor has ESO Contractor warranty after demobilised. period construction Table 4: Alien invasive plants identified in the CTT license areas and recommended control methods (Source: adapted from Biodynamica, 2016) Scientific Name Common Name Control Method/ Recommendations Agave sisalana Sisal hemp Cut the central growth stem as low as possible and apply herbicide solution immediately after cutting (within 20 seconds). Argemone mexicana Mexican prickly poppy Hand weeding carried out before the plant has set seed. Azolla pinnata Mosquito fern Manual removal by using thin-meshed nets. This is the preferred methodology when the invaded areas are relatively small. All material should be removed from the location, as this plant reproduces vegetatively through fragments of stems that root easily. 78 March 2019 18103533 Caesalpinia Shoo fly Seedlings and saplings can be dug up or pulled up manually. Larger plants must be cut, and stumps treated with herbicide. decapetala Calotropis procera Giant milkweed Plants should be cut down close to ground level and a herbicide applied to the cut stump. Foliar spray can also be considered for control of smaller plants. Cereus jamacaru Queen of the night Single, isolated seedlings shall be uprooted and disposed of. Care must be taken that no part of the plant is left lying where it can root. Under no circumstances must pieces of the plant simply be carted away to be discarded, since this is one of the most common ways in which cactus infestations spread Datura stramonium Devil's snare Isolated plants should be hand-pulled before they set seed. Larger infestations can be controlled by manual clearing. For larger plants it may be necessary to spray with a herbicide such as Roundup, limiting as much as possible of its application to the target species. Leucaena Leucaena Plants should be manual cleared and the roots dug up and removed. If roots are not cleared, a herbicide application should be leocucephala applied to the basal stem. Opuntia ficus-indica Prickly pear Manual/mechanical pulling preceded (or not) by the stem cut (preferred methodology). In compacted substrates, uprooting must be undertaken during the rainy season so as to facilitate the removal of the root system. No fruits, large roots and cladode fragments should be left in the ground, which root easily and spread new invasion. All cleared material should be removed from the location and burned. Parthenium Whitetop weed The plants should be pulled out before they flower, making sure that all of the root system is removed to avoid regrowth from root hysterophorus remnants Pistia stratiotes Water lettuce Small scale infestations can be controlled manually. Larger infestations should be tackled using herbicide. Reapplication is likely to be necessary over time. Ricinus communis Castor oil bush The plant can be controlled through manual clearing. Herbicides can be effective as cut stump treatments or basal bark applications (painting herbicide onto the bark). Senna occidentalis Coffee weed The plant can be successfully controlled when in the seedling stage by manual clearing. Likewise, a variety of herbicides can successfully control the species. 79 March 2019 18103533 Xanthium Rough cocklebur Single plants and small infestations can be hoed, and larger infestations sprayed with herbicide. Control efforts should be aimed at strumarium preventing seed formation. * A Pest and Pesticide Management Plan must be compiled by the contractor for approval by the ECO prior to use of any chemicals. 5.5.4 Rehabilitation Management The phasing of rehabilitation of areas disturbed by civil construction will depend on the activity being undertaken. Along roads, the perimeter of the construction right of way will be rehabilitated after construction. Pipelines will be fully rehabilitated across the full right of way after construction. Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification 5.5.4.1 Topsoil stripping Topsoil shall be stripped for later use in landscaping and re-instatement. Topsoil Construction During site Details of topsoil and stockpiling stripping and management requirements shall be as follows: Contractor preparation where removal (quantity) The top 150 mm of soil shall be stripped and stockpiled, unless otherwise the removal of and topsoil stockpile specified by the Site Engineer. topsoil is required. location. Topsoil shall be stockpiled separately from subsoil or rocky material (the topsoil As per requirement contains both the seedbed and the nutrient supply necessary for plant growth: if mixed with subsoil the usefulness of the topsoil for re-instatement/ landscaping of the site will be reduced) Topsoil stockpiles shall not be compacted and shall not exceed 2 m in height. Topsoil stockpiles shall be located away from drainage lines and areas of temporary inundation. Topsoil stockpiles shall be protected from wind and rain erosion, where necessary, by placing sandbags around the base of the stockpiles to reduce water erosion. In certain instances, if the natural grass does not cover the topsoil the Engineer may specify the seeding of the stockpiles with a local indigenous grass seed. The Engineer will provide advice to contractors relating to this provision. The following other guidelines and requirements shall apply: 80 March 2019 18103533 Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification  Wherever possible construction work and the stockpiling of soils shall occur during the winter months from April to November in order to minimise water erosion from rainfall runoff.  For Pipelines, the topsoil shall be stockpiled on the dead side of the trench (i.e. opposite side of the excavation trench to where the machinery works) to ensure it does not become mixed with or inadvertently pushed into the trench during the works.  Topsoil shall not be contaminated with any other material or spoil or used for any purpose other than rehabilitation. 5.5.4.2 Removal of All temporary works shall be removed from the construction work site or along Construction Immediately Photographic record temporary works the construction right of way (linear infrastructure) when construction is Contractor following backfilling. All temporary Works completed. removed and site clean and tidy 5.5.4.3 Reinstatement of The construction right of way shall be restored to natural contours of the ground Construction Immediately Photographic record natural ground to allow for normal surface drainage. Georeferenced photographic records of key Contractor following backfilling. As per requirement contours areas before and after construction shall be taken and kept on record for future comparison with rehabilitated areas 5.5.4.4 Loosening of Compacted soils shall be loosened along the construction right of way by means Construction Immediately Photographic record compacted sub- of a plough or scarifier. Scarifying shall be carried out prior to the replacement of Contractor following backfilling. As per requirement soils topsoil. Any ripping or scarifying operation shall not exceed a depth of 100 mm 5.5.4.5 Spread of topsoil Topsoil shall be evenly spread across the rehabilitated area or right of way Construction Immediately Photographic record (linear infrastructure) to a depth of 150 mm as applicable. Contractor following backfilling. Construction Contractor 81 March 2019 18103533 Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification 5.5.4.6 Natural process of Reinstatement of natural vegetation shall be done by encouraging the natural Construction Immediately after top Records of rehabilitation process of primary and secondary succession, except in areas with steeper Contractor soiling (where reinstatement gradients and/or erodible soils, where the Managing Contractor may instruct the Managing necessary) As per requirement contractor to revegetate disturbed areas using a seed mix containing only Contractor species indigenous to the area. Environmental Coordinator 5.5.4.7 Returning brush to Cleared brush and tree limbs shall be spread over the construction right of way Construction Immediately after top Photographic record. the right of way during re-instatement to assist in the regeneration of natural vegetation, erosion Contractor soiling As per requirement control and provision of habitat for animals. Bush spreading shall be in accordance with the following:  Bush, tree limbs and timber fragments shall be retained and spread evenly across the right of way after construction.  Any remaining tree trunks and large branches are to be laid on the construction right of way so that they lie in a random fashion across the natural slope of the ground. The above will be applicable to buried pipelines, however the transmission line RoW may require also require a similar approach in assisting the return of bush growth, however, to limited height as it will be controlled during the operational phase and maintained a fire break vegetation height restrictions. 5.5.4.8 Managing erosion Where necessary, special protection methods shall be used to prevent or arrest Construction After construction Absence of material soil erosion during the period before vegetation re-establishment. Diversion Contractor erosion ditches, swales, berms, straw and hay may be specified in places where erosion Engineering works to risk exists. minimise erosion 82 March 2019 18103533 Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification 5.5.4.9 Soil Erosion CTT should undertake a visual assessment and a surface water monitoring for Construction Monthly, and weekly Evidence of erosion. all infrastructure and streams and rivers near the soils with high erodibility. This Contractor during will mainly apply to the temporary bridge crossing of the Govuro River. 5.5.4.10 Removal of alien Infestation of areas disturbed by construction with alien plants shall be monitored Construction During Rehabilitation No Alien Invasive plants and removed as per section 5.5.3. Contractor of RoW Environmental Coordinator 5.5.4.11 Soil stockpiles Visual verification of soil stockpiles Construction Annually Volume of soil Contractor stockpiled. Environmental Height of stockpile Coordinator Type of soil stockpiled. pH and salinity values; Content of major plant nutrients; Organic matter content; Heavy metals and hydrocarbons. 5.5.5 Cultural Heritage A CHMP should be developed by the Proponent to manage and monitor all cultural heritage effects for the project’s lifetime in line with IFC PS 8 and Mozambican heritage legislation (Law 10/1988 and Decree 27/1994). The CHMP should include: 83 March 2019 18103533  The preparation of a project-specific, ‘site ready’ Chance Find Procedure (CFP) to detail the requirements of the Mozambican Archaeological Heritage Prote ction Regulations (Decree 27/1994) which enforce the reporting of any archaeological assets to the local authority within 48 hours of discovery. The CFP will set out the course of action to be followed in the event that any cultural heritage artefacts are recovered. The CFP should be provided to all contractors and consultants on the project site during all construction activity and incorporated within the project’s ‘site induction’ process. It will remain in place for the lif etime of the project;  Demarcation of ‘no go’ sensitive areas e.g. sacred forests, sacred trees, sacred pools, medicinal bush, ceme teries (i.e. mitigation by avoidance). Although these sites may not be directly affected by construction activities there is a potential for disturbance of community access routes to cultural sites and to the environmental setting of the sites themselves;  Enhancement or protection of environmental setting may be required and should be discussed in conjunction with local community e.g. through planting/screening;  It may be necessary to demarcate areas to be avoided (e.g. by noisy, dust-inductive) construction vehicles at certain times of the day/year so as to avoid disturbance of traditional ceremonial activities in close proximity of construction routes;  Maintaining community access to sacred sites and facilitating respect for local intangible cultural heritage, tradition and taboo will ensure that the negative socio- cultural effects are effectively managed – regular platforms for community liaison are recommended in this regard. It is suggested that the presence of culturally significant places are highlighted to contractors at any early stage, e.g. during site induction; and  Continued liaison between the Proponent and local cultural leaders to facilitate the identification of any cultural sites not yet shared by the community and potentially affected by the proposed project. The CHMP must set out plans for stakeholder identification and a programme for long term consultation in this regard. Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification 5.5.5.1 Updating of The data base of all cultural heritage sites shall be updated, based on the CTT Pre-construction Inclusion of updated cultural heritage investigation associated with each project, and any sites within 500 m of and geo-referenced site data base construction activities shall be included in a project specific Appendix to the c- cultural heritage site ESMP. Such heritage sites shall be georeferenced for easy identification in the listings in a project- field. specific Appendix to the c-ESMP 84 March 2019 18103533 Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification 5.5.5.2 Avoidance of Where project infrastructure is within 100 m of a cultural heritage site, the area Construction At all times Absence of damage known cultural shall be flagged for special attention. In such cases, the precise location of the Contractor to any cultural heritage sites near site shall be confirmed with members of the local community. All construction Managing heritage site the construction team personnel, particularly operators of vehicles and heavy equipment, shall be Contractor Absence of works made aware of the site and advised of its importance. If considered necessary by complaints from the Managing Contractor, in consultation with local community representatives, members of the the site shall be temporarily fenced or demarcated in order to protect it from community in the damage. Compliments and Complaints Register 5.5.5.3 Collection of The Contractor shall respect local intangible cultural heritage, tradition and taboo Construction At all times Inclusion of cultural cultural heritage during construction so as to ensure that the negative socio-cultural effects are Contractor heritage sensitisation remains effectively managed. The collection of archaeological or other cultural artefacts in induction found on site by contractor personnel shall be prohibited. programme(s) and contractor tool box talks. Absence of complaints from members of the community in the Compliments and Complaints Register 85 March 2019 18103533 Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification 5.5.5.4 Maintenance of Community access to sacred sites shall, where necessary, be maintained during Construction As required by Records of community access the construction period. Access requirements shall be determined by the CLO in Contractor consultation with communication and consultation with local communities. CLO communities Absence of communication complaints from members of the community in the Compliments and Complaints Register 5.5.5.5 Change to the land Review design options to avoid impact. Construction Construction No heritage sites surface Preference is northern transport route, and to re-align powerline within the Contractor Contractor affected transmission line corridor. Adherence to Cultural Heritage Management Plan (CHMP) 5.5.5.6 Ground pollution Ensure all vehicles are well maintained. Prepare Emergency Response Plan and Construction Construction ERP and CHMP Contractor Adherence to CHMP Contractor 5.5.5.7 Chance Find The Contractor shall minimise the risk of accidental damage to heritage sites by Construction At all times Records of training of Procedure implementing the Chance Find Procedure (CFP) developed for this project. Contractor site personnel The Environmental Coordinator (EC) and ESO/ECO shall undertake training ESO / ECO Compliance with provided by a qualified specialist in order to improve their capability to identify Specialist CFP archaeological and paleontological finds. Environmental In the event of a Chance Find for which the EC determines a professional Consultant archaeologist’s opinion is required, no further construction work shall be undertaken until the archaeologist has seen the site and made a recommendation. 86 March 2019 18103533 5.6 Employment and Local Procurement 5.6.1 Employment and Labour Management Labour management will include compliance with Mozambican laws, ILO Labour Standards and World Bank OP 4.03/PS2, including adequate contracts, minimum wages, health care, adequate disability/ fatality insurance, etc. Additionally, the labour contracts and policies will include guidance for camp management plans, contractors community relations requirements, and guidelines for contractors (and subcontractors) on child and forced labour. These will also include codes of conduct with sanctions against adverse behaviour (drug and alcohol use, disregard for safety rules on and off site) and against Gender-based violence, sexual harassment and abusive behaviour. Codes of Conduct will need be signed by all workers in order to avoid and sanction misbehaviour of workers, including sexual harassment, gender- based violence and sex with minors, drug abuse, hunting, wildlife capture, improper waste disposal, etc. The Contractor will provide Worker’s manuals and training protocols to inform workers of their rights and responsibilities, including grievance redress and channels for communication. Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification 5.6.1.1 Establishment of a CTT (and not the construction contractor) is to establish a Project Labour CTT Local In advance of the Signed Project Project Labour Agreement (PLA) with the National Department of Labour (taking into Procurement construction contract Labour Agreement Agreement (PLA) consideration Mozambican law, World Bank Group policies and performance Officer Records of disputes standards on labour (PS2), and occupational health and safety requirements), which shall include the process of recruitment of local labour. The PLA shall be negotiated with the relevant labour union in consultation with Local and District authorities and with leaders of the affected communities. 5.6.1.2 Implementation of Employment shall be undertaken and managed by the Construction Contractor Construction Pre-construction and Signed Project the PLA according to Mozambican labour law and the approved Project Labour Contractor ongoing Labour Agreement Agreement (provided to the Construction Contractor by CTT). In particular the CTT Local Maximisation of following should be addressed in the PLA and implemented by the Construction Procurement labour use, where Contractor: Officer practical 87 March 2019 18103533 Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification  The maximum use of local labour during construction (where possible) Records of CLF, on activities where construction machinery could be dispensed of. showing unskilled Where enhance labour use is practical, it shall be complimented by employment from applicable skills training. project-affected  All unskilled temporary construction jobs to be for the project-affected communities communities, subject to availability of sufficient workers from these Absence of justifiable communities who qualify with project requirements for employment. complaints in the  Recruitment methods for the project shall be agreed with the local Compliments and authority and community leaders (represented in the CTT Community Complaints Register Liaison Forum) but shall under no circumstances be ad hoc recruitment at the construction sites or personnel camps.  No fees shall be levied for recruitment or preferred status for employment opportunities. 5.6.1.3 Fair distribution of Selection for unskilled employment shall further be based on the procedures Construction Ongoing Compliance with PLA jobs for unskilled developed and agreed by the Community Liaison Forum (CLF), which is intended Contractor Records from workers as a mechanism for identifying and selecting unskilled workers from local Community Liaison communities in a fair and transparent manner. Forum 5.6.1.4 Communication of In order to maintain a transparent labour recruitment process, the information CTT Local Ongoing Number and nature requirements for concerning procedures and eligibility requirements shall be communicated Procurement of communication employment through channels used by local authorities and grass roots community Officer initiatives opportunities organisations. Details of communication channels shall be included in the CTT Public Records of Communications Plan. Affairs communication. Coordinator 5.6.1.5 Grievance The PLA shall include a formal employee Grievance Procedure which provides CTT Local Ongoing Grievance procedure employees with a mechanism for raising issues with the company without fear of Procurement Procedure. 88 March 2019 18103533 Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification victimisation. Contractors shall ensure that the induction of employees includes Officer Induction regarding instruction on how to use the grievance procedure. Construction Grievance Contractor Procedure. Records of grievances and how they were resolved 5.6.1.6 Semi-skilled and Where positions are available for semi-skilled and skilled jobs, the Construction Construction Ongoing. Percentage of semi- skilled Contractor shall coordinate with local authorities and the education sector to Contractor skilled and skilled employment identify appropriate local candidates given that there are technical schools in the employees from local Inhassoro District. The Construction Contractor shall follow the ‘spiral’ principle in communities, District seeking qualified candidates, i.e. start in local communities, then the closest and Province. town, then rest of the Inhambane Province and Nationally. Evidence of use of the ‘spiral principle’ 5.6.1.7 Employment of The Construction Contractor shall weight the award of specific unskilled jobs in Construction Ongoing Percentage of women disabled favour of women, disabled and other disadvantaged people wherever practical. Contractor women disabled, and and other Targets should be developed in conjunction with the Developer and local other disadvantaged disadvantaged organisations working with vulnerable groups. people Employed. people 5.6.1.8 Alignment of The Contractor shall ensure that agreements with employees (including Construction Ongoing Records of employee employee disciplinary criteria, working conditions, payment of over-time etc.) are in line with Contractor briefings and agreements with the PLA and are properly understood by all employees. induction the PLA 89 March 2019 18103533 Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification 5.6.1.9 Understanding of The Contractor shall ensure that contract employees fully understand the Construction Ongoing Employment temporary nature temporary nature of their employment contracts. Contractor Contract and records of employment of employee briefings and induction 5.6.1.10 Employee Construction Contractors shall ensure proper supervision of employees at all Construction At all times Compliance with supervision times, including after-hours where employees are resident on site. Contractor ESMP requirements 5.6.2 Procurement of Local Goods and Services CTT will develop procedures and guidelines intended to drive preferential procurement and enterprise and supplier development in Mozambique. The success of this programme will have a major influence on CTT’s contribution to sustainable development. Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification 5.6.2.1 Procurement of CTT will create a local content guideline or plan, to be used as a guide to local CTT Local Ongoing Local suppliers in local goods and content procurement for the CTT. Goods and services shall be procured locally Procurement service provider list services whenever possible and whenever these meet CTT’s established requirements, in Officer Register and accordance with the CTT’s Procedure. However, no bushmeat or other local wildlife Construction percentage of products shall be purchased. Furthermore, all fish served to project personnel at Contractor procurement in the construction camp shall be brought in from well outside the project area, to communities, the avoid stimulating increased fishing activity within the Bazaruto Archipelago National District and Province, Park or adjacent areas of important habitat for Dugong and other threatened and nationally marine life. 90 March 2019 18103533 Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification 5.6.2.2 Preparation of a The Construction Contractor shall prepare and submit a Local Content Plan to CTT Construction Local Content Plan to Prepared and Local Content for approval in line with CTT’s Local Content Strategy or Guideline/Plan . The Local Contractor be submitted prior to implemented Local Plan Content Plan shall prohibit the purchase of bushmeat or other local wildlife products CTT Local establishment on site. Content Plan in any quantity, as well as any bulk purchases of local fish (to avoid increasing local Procurement Periodic ongoing Records of fishing pressures in the BANP or other sensitive marine habitats). The Construction Officer reporting percentage of Contractor will be expected to comply with this plan. The Contractor is to use a procurement from specific template as a part of reporting requirements to CTT. Detailed records of local communities, procurement shall be kept for submission to Government. the district, province and nationally 5.7 Solid Waste and Materials Management 5.7.1 Non- Hazardous Waste Management Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification 5.7.1.1 Non-hazardous All non-hazardous camp waste shall be collected, separated for recycling, Contractor At all times As per requirement waste temporarily stored, transported and disposed of in accordance with CTT Waste Records of waste management Management Plan. collected and recycling Manifests of waste collection and disposal at selected municipal waste disposal site 5.7.1.2 Waste  Develop waste inventories. These inventories will be updated throughout Contractor Prior to start of Record of waste generation and the project, commissioning and operations phases. ESO project. reduction and recycling 91 March 2019 18103533 Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification recycling  Stipulate the storage and disposal requirements for each waste stream. Process At all times during initiatives.  Develop waste management strategies for each waste stream based on the Engineers the project. Recycling bins on site. waste management hierarchy. Stores Managers  Prepare waste management procedures for the specific scope of work and Workshop expected waste types and volumes. Managers  Ensure worksites are kept free of litter and that any litter is cleaned up immediately.  Demonstrate efforts to reduce waste volumes, where possible, and to segregate and recycle waste where not possible. 5.7.1.3 Waste handling  Comply with applicable regulatory requirements and standards regarding Contractor At all times Evidence of waste and storage the design and operation of all waste storage areas (Decree 83/2014 of 31 ESO storage containers. December; Decree 94/2014, of 31 December) (as amended). Process Evidence of waste Engineers segregation, separate  Segregate all waste streams at source, where practicable Stores Managers bins/containers for  Label all hazardous waste containers in accordance with the labelling Workshop different kinds of waste. system as described in Annex IV of Decree 83/2014. This labelling system Managers Clear labels on bins is consistent with international guidelines. WWTP operators Evidence of waste  Store all waste in appropriately designed and clearly labelled waste bins or inspection records waste containers. Evidence of inspection  Cover or close waste receptacles that may present an issue for attraction of of waste transport pests and other fauna. vehicles.  Regard any unidentified wastes as hazardous waste and handle and store such waste accordingly.  Separate combustible wastes from ignition sources to minimise fire hazards.  Inspect and empty temporary waste bins/facilities regularly. 92 March 2019 18103533 Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification  Securely store and contain all wastes during transport to landfill facilities. Waste transport vehicle shall be in secure skips or containers which are covered during transport. 5.7.1.4 Waste transport  Comply with Mozambican waste management regulations regarding waste Contractor At all times Record of waste and disposal disposal (Decree 83/2014 of 31 December, Decree 94/2014 of 31 ESO manifest signed by December). Process ESO Engineers Certificates of safe  Stipulate the storage and disposal requirements for each waste stream. Stores Managers disposal  For items that are marketable, re-use or recycle waste materials. These Workshop materials shall be separated from the waste stream at their point of Managers generation and stored separately for collection by an accredited recycling WWTP operators contractor. Waste transportation  In accordance to the legislation, where transport of waste off-site is required, Contractor use a transporter that is certified by MITADER.  Implement a Waste Transfer Note (WTN), which is to be signed by the Site Engineer.  Correlate the waste manifests with the contractor’s waste management method statement.  Retain the WTN for at least 3 years.  Collect waste sufficiently frequent to ensure that there is no overloading of the temporary storage at the site. 93 March 2019 18103533 Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification  Have in place the means to respond appropriately to spillages of waste anywhere along the route within a time limit acceptable to the Proponent.  Provide certificates of safe disposal to the Site Engineer for all wastes disposed at the waste site.  Where possible, dispose waste in a discreet location at the waste site that permits deposition and closure independently of other waste, so that due diligence can be verified and documented. 5.7.1.5 Burying of  Prohibit the discard or burying of waste materials on site. Contractor At all times No incidents of waste waste on site ESO being buried on sites. Process Engineers Stores Managers Workshop Managers WWTP operators 5.7.1.6 Specific  Permit the burning of combustible, non-hazardous waste in a burn pit, the Contractor Daily Daily burning at EC- requirements location of which shall be identified by the EC/ESO. ESO identified location for burning of Process Absence of waste combustible Engineers unsuitable for waste Stores Managers combustion in burn pits. Workshop Managers WWTP operators 94 March 2019 18103533 Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification 5.7.1.7 Specific  Do not dispose of any waste by incineration unless emissions from the Contractor Specific As per specification requirements incinerator meet internationally accepted emissions guideline levels / limits requirements for for incineration for small, temporary installations (Basel Convention Technical Guidelines on incineration of waste of waste Incineration on Land, 2002; IFC, Environmental Health and Safety Guidelines for Waste Management Facilities, 1998; The European Waste Incineration Directive, Directive 2000/76/EC on the Incineration of Waste, 200). 5.7.1.8 Specific  Organic wastes; a composter will be used to store these at the camps. Contractor At all times As per specification requirements ESO for composting Process of organic Engineers wastes 5.7.1.9 Specific  Separate inorganic waste into appropriately labelled waste bins for recycling. Stores Managers At all times As per specification requirements Provide bins for plastics, glass, waste packaging, aluminium cans and scrap Workshop for recycling of ferrous metal. Uncontaminated wood shall be made available to communities Managers inorganic for their use (or used in a wood chipper and used for composting). WWTP operators wastes 95 March 2019 18103533 5.7.2 Hazardous Waste Management Ref. Description Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification 5.7.2.1 Compliance Comply with the Mozambique Regulations for the management of Hazardous Contractor From project Compliance with Decree with legislation Wastes (Decree 83/2014 of 31 December). The specifications below cover key initiation and at all 83/2014 of 31 December ESO requirements, but a full listing should be obtained from the regulations themselves. times. Process Engineers Stores Managers Workshop Managers 5.7.2.2 Hazardous All hazardous camp waste shall be collected, classified, labelled, temporarily Contractor At all times As per requirement waste stored, transported and disposed of in accordance with Mozambique Decree management 83/2014, and as set out in the CTT Waste Management Plan. 5.7.2.3 Hazardous  Prepare a Method Statement for Management of Hazardous Waste in Contractor Before project Authorisation by waste method accordance with Article 11 of Decree 83/2014 of 31 December, including the initiation as a basis MITADER ESO statement relevant information required by Annexure II. The plan shall include but not for licensing of the be limited to: Process activity Engineers  An inventory of all hazardous waste, together with estimated quantities, documented in accordance with the classification system in Annexures Stores Managers III and IX of the regulations. Workshop  Measures to comply with waste hierarchy requirements for minimizing Managers hazardous waste generation and recycling of waste 96 March 2019 18103533 Ref. Description Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification  Measures to safely contain and temporarily store hazardous waste prior WWTP operators to collection.  Measures to label hazardous waste in accordance with Annexure IV of the regulations.  Measures to transport hazardous waste in accordance with Annexures VI and VIII of the regulations.  Details of the licensed disposal site. 5.7.2.4 Waste  Develop waste inventories. These inventories must be updated throughout Contractor Before Record of waste generation and the project. establishment on reduction and recycling ESO recycling site initiatives.  Stipulate the storage and disposal requirements for each waste stream. Process At all times during Recycling bins on site  Develop waste management strategies for each waste stream based on the Engineers the project waste management hierarchy. Stores Managers  Prepare waste management procedures for their specific scope of work and Workshop expected waste types and volumes. Managers  Manage controlled waste as required by the Mozambican waste WWTP operators management Decree and Proponent’s SHE policy.  Demonstrate efforts to reduce waste volumes.  Recycle used oils and greases, where possible, or dispose of them appropriately according to the regulation (Decree 83/2014). 97 March 2019 18103533 Ref. Description Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification 5.7.2.5 Waste storage  Comply with applicable regulatory requirements and standards regarding the Contractor At all times Evidence of waste and handling design and operation of all waste storage areas (Decree 83/2014). storage containers. ESO Within 7 days  Segregate all waste streams at source, where practicable. Process Evidence of waste segregation, separate  Line hazardous waste containers or construct of materials that are Engineers bins/containers for compatible with the wastes to be stored. Keep containers in good condition, Stores Managers different kinds of waste. free from corrosion, leaks or ruptures and sealed to prevent spillage. Workshop Clear labels on bins  Label hazardous waste in accordance with the labelling system required by Managers, Annexure IV of Decree 83/2014 of 31 December. Evidence of inspection Hazardous waste storage  Keep Material Safety Data Sheets for stored hazardous waste, where Waste facilities/containers available, at the following locations: Transportation Contractor Presence of spill kits - the hazardous waste storage area at the Camps Record of MSDS for - the office of the Contractor’s site manager hazardous waste - the EC/ESO’s office materials  Regard any unidentified wastes as hazardous waste and handle and store Manifest of waste such waste. removal from site  Locate spill kits at hazardous liquid waste storage areas.  Handle waste chemicals in accordance with the appropriate Material Safety Data Sheet (MSDS). 98 March 2019 18103533 Ref. Description Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification  Keep temporarily stored hazardous waste at the work sites on pallets underlain by a plastic liner. All waste stored in this manner shall be removed to the Construction Camp daily.  Ensure that storage at the Camps is a concrete floored, bunded, facility, covered to provide shade and prevent ingress of rain. Bunded areas shall include a trap to collect wash-down water from cleaning of the area. If this water is likely to contain hydrocarbons, then the washdown shall be treated as POC water.  Fully secure the storage area, with lockable gates, to prevent unauthorised access.  Inspect and empty hazardous waste storage facilities regularly. 5.7.2.6 Waste transport  Comply with Mozambican waste management regulations regarding waste Contractor At all times Record of waste manifest and disposal disposal, as described in Decree 94/2014 of 31 December. signed by ESO ESO  Dispose of hazardous waste at a licensed hazardous waste disposal site. Process Certificates of safe disposal  Stipulate the disposal requirements for each waste stream. Engineers  Implement a waste manifest which must be signed by the Site Engineer. Stores Managers  Correlate the waste manifest with the contractor’s waste documentation. Workshop Managers  Maintain the waste manifest for at least 3 years.  Collect waste sufficiently frequent to ensure that there is no overloading of the temporary storage at the site. 99 March 2019 18103533 Ref. Description Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification  In accordance with the legislation, ensure that waste to be transported off site is removed by a transporter that is certified by MITADER.  Securely contain all wastes during transport to hazardous waste disposal sites or other means.  Have in place the means to respond appropriately to spillages of waste anywhere along the transport route within a time limit acceptable to the Proponent.  Provide certificates of safe disposal to the Site Engineer for all wastes disposed at the licensed waste site. 5.7.2.7 Specific Treat small quantities of soils contaminated by hydrocarbons (less than 20kg) in- Proponent At all times Records of requirements – situ using bioremediation. Where large quantities of contaminated soils are treatment/disposal Contractor ESO bioremediation involved (greater than 20kg) or if there is the potential to cause pollution to of contaminated groundwater, surface water or community water facilities, remove the Process soils contaminated soils to the area allocated by the EC at the Construction Camp for Engineers longer-term bioremediation (over a surfaced hard standing area). Contractors shall be responsible for the bioremediation of their own contaminated soil until the Stores Managers following standards are met: Workshop Managers  There is no hydrocarbon odour. WWTP operators  The soil particles do not coagulate as a result of hydrocarbon contamination.  There is no visual evidence of hydrocarbons in the soil.  Where there is uncertainty the soil shall be sent for analysis. 100 March 2019 18103533 Ref. Description Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification  Where soils are contaminated by other hazardous chemicals they shall be removed and disposed of as per hazardous waste disposal requirements, indicated in the MSDSs. 5.7.2.8 Specific Chemicals that are no longer used, or are past their shelf-life date, shall be stored Contractor, At all times Records of disposal requirements - in the hazardous waste storage area at the Camps for interim storage until disposal ESO disposal of (toxic chemicals are normally sent to incineration). unused Process chemical waste Engineers Stores Managers Workshop Managers WWTP operators 5.7.2.9 Specific  Should pesticides be used to control the mosquito vector in and around Contractor At all times Records of pesticide use requirements - worker’s camps and work sites, they shall be selected to minimise negative and eco-toxicity ESO pesticide use for effects on non-target organisms. management vector control Process  The disposal of waste pesticide and pesticide containers shall be as per the Engineers Records of selection CTT Waste Management Plan. procedure Stores Managers  A Pest and Pesticide Management Plan must be compiled by the contractor for approval by the ECO prior to use of any chemicals. Workshop Managers 101 March 2019 18103533 Ref. Description Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification WWTP operators 5.7.2.10 Specific Cement/aggregate shall be stored and mixed on compacted ground in designated Contractor Cement mixing As per requirement requirements - areas. This ground shall be lifted and disposed of in a waste site as cover fill at the ESO cement storage, end of the construction phase. use and Process disposal Engineers Stores Managers Workshop Managers 5.8 Water Management 5.8.1 Wastewater Management There are four types of wastewater streams that would be expected from the CTT project activities. These are:  Potentially oily contaminated (POC) wastewater and storm water from maintenance areas and vehicle wash bays; this would be an intermittent stream;  Domestic wastewater, which includes grey water (from kitchens and washing facilities) and sewage waste;  Oily water effluent; and  The brine and ultrafiltration reject from the water treatment process. 102 March 2019 18103533 Ref. Description Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification 5.8.1.1 Effluent Disposal  Dispose of effluent in line with Mozambican regulations on effluent water Proponent Prior to initiation of Method statement (oily wastewater) disposal requirements and irrigation - amended by Decree 67/2010 of 31 Contractor project activities available and followed by (irrigation) December or World Bank Group Effluent standards – whichever is more ESO staff stringent. Process No non-conformances  Prepare a method statement describing effluent management at Camps Engineers that shall include, but not be limited to: Stores Managers  How effluent will be stored prior to treatment. Workshop  How the effluent will be treated to meet the standards required under Managers Mozambican legislation: Decree 18/2004 amended by Decree 67/2010 WWTP of 31 December, Environmental Quality and Effluents Emission operators Standards Regulation  “Regulation on Environmental Quality and Effluents Emission Standards.”  Measures to ensure that there will be no release of polluted runoff from the site.  Measures to prevent erosion at any discharge point.  The duration of the use of the site.  Proponent/Managing Contractor shall approve the Method Statement prior to submission of the effluent management method statement to MITADER as a part of wastewater licensing requirements. 5.8.1.2 Potentially oil- In work areas for servicing of vehicles and equipment and other tasks where oils Contractor At all times POC-contaminated areas contaminated and fuel are handled, route spillages via appropriately sized mechanical oil ESO contained, and drainage wastewater separators. Undertake planned maintenance activities under roofed areas to Process routed through minimise contaminated storm water. Engineers mechanical oil traps 103 March 2019 18103533 Ref. Description Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification Stores Managers Workshop Managers WWTP operators 5.8.1.3 Potentially Keep potentially oil-contaminated (POC) storm water separate from other Contractor At all times Incident reports and contaminated drainage. If necessary, test and treat POC storm water to remove contaminants ESO corrective action report storm water before being released into the environment. Process where contaminated Engineers water is generated Stores Managers Workshop Managers WWTP operators 5.8.1.4 Compliance with Ensure that water draining from POC areas complies with the Mozambique Contractor At all times Compliance with oil and Mozambique oil specification for oil and grease in effluent discharged to the environment (20 ESO grease standard for POC- and grease mg/l). Process wastewater released into specification for Engineers the environment effluent Stores Managers Workshop Managers WWTP operators 104 March 2019 18103533 Ref. Description Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification 5.8.1.5 Vehicle wash Regard heavy vehicle wash bay(s) as POC areas. Contractor At all times Compliance with oil and bays ESO grease standard for Process wastewater released into Engineers the environment Stores Managers Workshop Managers WWTP operators 5.8.1.6 Sand washing Should sand washing be necessary, prepare a Method Statement for approval by Contractor, Prior to sand Approved and the Managing Contractor, which shall include details of, but not be limited to, the ESO, Process washing implemented method following: Engineers, statement  Location of the washing process; Stores  Estimated quantity to be washed and water volumes required; Managers,  Source of water for washing; Workshop  Any additives to be used in the washing process, including chemistry and Managers, environmental status (include MSDSs); WWTP  Methods for the management of effluent, including TDS and the monitoring operators thereof; and  Measures to prevent erosion as a result of the washing process. 5.8.1.7 Domestic  Discard grey water (kitchens) into French drains. Contractor At all times Compliance with wastewater  Drain sewage effluent from worker’s Camp activities to a brick or concrete - ESO domestic wastewater (irrigation) lined sump and treat it in a package sewage plant, the effluent from which Process specification as per shall comply with the requirements of the Mozambique regulations for Engineers Decree 18/2004 of 2 June domestic wastewater (Decree 18/2004 Appendix IV, amended by Decree 105 March 2019 18103533 Ref. Description Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification 67/2010 of 31 December), Environmental Quality and Effluents Emission Stores (amended by Decree Standards Regulation or World Bank Group Effluent standards – whichever Managers 67/2010 of 31 December) is more stringent. Workshop Managers  Size the sewage plant in order to cater for the maximum forecast loads WWTP over the project construction and operation periods. Undertake regular operators compliance monitoring of effluent quality.  In the event that the Contractor proposes a septic tank and soak away system, design this in accordance with a recognised standard such as ZA SANS 10400-P:2010. The septic tank shall accommodate at least three times the expected daily flow rate (approximately 90 litres per day worker) and the soak away shall meet the requirements of the standard or other recognised standard.  Ensure that no septic tank and soak away system is situated closer than 150 m from a community borehole.  For Camps and work sites, ensure that there is a sufficient complement of compositing toilets available. 5.8.1.8 Brine and Brine and reject will be sent to the Evaporation pond and managed. The brine Contractor Prior to operations Approved and Ultrafiltration pond will be lined with an HDPE liner. There will be regular desludging to remove ESO and at all times implemented method reject the residual salts and this will be removed by an accredited waste removal Process statement. contractor in line with the method statement. Engineers Stores Managers Workshop Managers WWTP operators 106 March 2019 18103533 Ref. Description Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification 5.8.1.9 Potentially oil- Small quantities of POC wastewater may result from washdown of spillages in Contractor At all times POC-contaminated areas contaminated the POC work areas at the Construction Camp. These include bunded areas for contained, and drainage wastewater hydrocarbon storage, the bunded generator platform and areas designated for routed through vehicle servicing and repair. mechanical oil traps 5.8.2 Stormwater Management Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification 5.8.2.1 Accelerated Accelerated erosion during storm events shall be minimised Construction Contractor At all times. Minimised alteration of erosion during all stages of construction. Should this be unavoidable, natural flows. specific erosion control measures shall be implemented for the Details of measures duration that the risk exists. These may include the packing of implemented to control sandbags in areas of storm drainage, diversion berms, temporary stormwater culverts etc. in order to minimise erosion. Absence of material erosion on site 5.8.3 Water Supply Management Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification 5.8.3.1 Permits for water The contractor shall obtain all necessary permits for the use of Construction Contractor Prior to water use Permits for use use surface water and groundwater from the relevant authorities 107 March 2019 18103533 Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification (ARA-SUL). 5.8.3.2 Groundwater use Water abstraction for the project shall be from groundwater Construction Contractor Pre-planning of facility Records of proximity of boreholes. The project shall have no detrimental impact on water location project water supply to volumes available to existing users in the area. If any borehole is Monitoring if closer than community boreholes closer than 1,000 m to the nearest community borehole, specific 1,000 m from a Monitoring of community provision shall be made to monitor the effect of construction use community borehole boreholes, if required community water supply and to supplement this supply, if Record of action taken if necessary. community borehole temporarily affected 5.8.3.3 Surface water Should the use of surface water be considered this shall be Construction Contractor All times Authorisation by use subject to the approval of the Mozambique Water Authorities. The Managing Contractor Managing Contractor use of surface water from pans and depressions in the study area Quantity and location of shall be prohibited. surface water use 108 March 2019 18103533 5.8.4 Bio-medical Waste Management Ref. Description Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification 5.8.4.1 Disposal of  Separate all medical waste from other waste. Place medical Contractor As required Certificates of disposal medical waste waste in labelled bags in accordance with the requirements of ESO Decree 8/2003. Process Engineers  Separate infectious waste in yellow plastic bags or, if not possible, any other yellow impermeable plastic bags or Stores Managers containers labelled with the wording “Infectious Waste”. Workshop Managers  Clearly identify all infectious waste container through the label “Infectious Waste” and the international Infectious Waste logo stamp.  Third party waste contractor to collect for treatment/incineration. Records of all medical waste collected shall be kept and submitted to the EC. 5.8.4.2 Procedure for Dispose of the waste at the in accordance with Proponent’s Third party waste As required Records of medical waste medical waste approved medical waste management procedures. contractor disposal. disposal 109 March 2019 18103533 Ref. Description Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification 5.8.4.3 Off-site disposal The third party waste contractor shall provide the Proponent with the Contractor As required Certificates of disposal of medical waste license of the site(s) at which the waste is to be disposed. In ESO addition, ensure that the site(s) receiving the waste provide certificates of acceptance of the waste. Process Engineers Stores Managers Workshop Managers 5.8.5 Vehicle and Materials Management (including hazardous chemicals, fuels and lubricants) Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification 5.8.5.1 Vehicle All equipment and machinery shall be maintained in good working Construction Contractor At all times Records of maintenance maintenance order so as to prevent oil, fuel or other such leaks. and inspections 5.8.5.2 Location of Planned vehicle and equipment maintenance shall only be Construction Contractor At all times Compliance with oil and planned undertaken at the Construction Camp. All drainage from vehicle grease standard for maintenance and machinery servicing areas shall be collected and passed wastewater released into facilities through a mechanical oil separator. Waste oils and other the environment hydrocarbon wastes shall be collected, drummed and recycled according to the requirements in the Waste Management Plan. No hydrocarbon-contaminated water may be voided into the environment. The Contractor shall strictly prohibit the washing of 110 March 2019 18103533 Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification vehicles or other machinery, or the changing of lubricants, in rivers, streams, ponds, or other waterways. 5.8.5.3 General All applicable laws, regulations, permit and approval conditions Construction Contractor At all times Reference to waste and requirements relevant to the storage and use of hazardous management in the weekly materials shall be complied with. All hazardous materials shall be reports of the ESO and managed in a safe and responsible manner. EC. 5.8.5.4 Method The Construction Contractor shall prepare a Method Statement, Construction Contractor Prior to establishment on Method Statement statement for approval by the Managing Contractor, which includes an Managing Contractor site as per requirement inventory of all hazardous materials that will be used on site, and measures to prevent:  Soil contamination,  Pollution of water,  Accidental fires and  Risk / injury to people or animals. 5.8.5.5 MSDS The MSDS’s of any hazardous chemicals / substances (including Construction Contractor At all times Inventory of hazardous availability that within equipment) described in the Method Statement shall be Managing Contractor materials and MSDS’s provided to the Managing Contractor, and shall be kept in the Documentation available at following locations: specified locations.  the chemical storage area,  the office of the Construction Contractor’s site manager,  the office of the Managing Contractor’s site manager, 5.8.5.6 Prohibition of Transformers and other equipment used on site shall use oils that Construction Contractor At all times Documented statement by PCBs are PCB-free. Contractor regarding PCB- free equipment 111 March 2019 18103533 Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification 5.8.5.7 Prohibition of Refrigerants used on site shall be CFC-free Construction Contractor At all times Documented statement by CFCs Contractor regarding PCB- free equipment 5.8.5.8 Location of fixed- Fixed fuel storage tanks shall not be located anywhere other than Construction Contractor At all times Location of fixed fuel fuel storage at the Construction Camp, approved plant yards, lay down areas storage as per requirement or campsites. 5.8.5.9 Enclosure and All fixed fuel storage shall be enclosed with a security fence which Construction Contractor At all times. As per enclosure and signage at fuel has a lockable gate. Signs indicating ‘no smoking’ ‘no naked signage requirement. storage areas flames’ and ‘danger’ shall be provided in appropriate languages and are to conform to a recognised standard such as the South African Bureau of Standards Code 1186 or equivalent Mozambique standards. The capacity of the tank and the product within the tank shall be displayed using the Emergency System detailed in SABS 0232 or similar international code. 5.8.5.10 Surfacing of Fixed fuel storage shall be on a flat, impermeable, surface, Construction Contractor At all times As per storage requirement storage areas surrounded by a bund wall capable of retaining at least 110% of the volume of the storage tank, in order to ensure that accidental spillage does not pollute local soil or water resources. 5.8.5.11 Refuelling at Fuel transfer at fixed fuel storage areas shall be performed on a Construction Contractor At all times As per requirement. fixed storage concrete surface draining to a mechanical oil separator. No Incident and corrective areas hydrocarbon-contaminated water shall be released into the action records. environment. 5.8.5.12 Refuelling in the All reasonable precautions shall be taken to prevent fuel and Construction Contractor At all times As per requirement field lubricant spills in the field during the course of construction. Incident and corrective Measures include the following: action records 112 March 2019 18103533 Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification  No overfilling of diesel bowsers  Regular inspections to verify that no leaking or defective refuelling equipment is brought onto site.  Capture of any fuel spills, oils or lubricants discharged during emergency vehicle servicing on site using drip trays, containers or other appropriate containment measures. 5.8.5.13 Location of Chemicals, fuels, lubricating oils and any other hazardous Incident and corrective At all times As per requirement storage in materials shall not be stored within: action records. relation to  200 m of the full seasonal extent of any river, wetland, pan or sensitive depression environments  20 m of any stormwater drainage system  100 m of any community groundwater borehole 5.8.5.14 Health risk The Construction Contractor shall make his employees aware of Construction Contractor At all times Records of training awareness and the health risks associated with any hazardous substances used conducted protective and appropriate safety behaviour when working with or near such Provision of PPE clothing substances. The Construction Contractor shall provide his workers with appropriate protective clothing / equipment in case of spillages or accidents. The necessary awareness training (including safe handling) of such hazardous substances will also be provided to employees 5.8.5.15 Below ground No fuel or any other chemicals shall be stored below ground Construction Contractor At all times As per storage requirement storage (either partially or completely). 113 March 2019 18103533 Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification 5.8.5.16 Supervisory staff Fuelling and repairs shall be carried out or supervised by Construction Contractor At all times As per refuelling for fuelling and personnel familiar with spill containment and clean up procedures. requirement. repairs 5.8.5.17 Cleaning of All vehicles or equipment that are required to cross rivers, Construction Contractor At all times As per requirement. vehicles in wetlands or floodplains shall be cleaned of oil, grease and other wetland areas contaminants damaging to aquatic life. 5.8.5.18 Diesel Diesel power generators at the Construction Camp shall be Construction Contractor At all times Spill protection around generators located on a bunded impermeable surface to contain fuel spills. generators Diesel generators in the field shall be located on a PVC liner or drip tray to contain spills 5.8.5.19 Availability of In all cases, the necessary tools and materials, including Construction Contractor At all times. Availability of spill / drip spill clean-up absorbent material, shovels and bags shall be readily available at clean-up materials at materials the Construction Camp and work sites to clean up spills. An specified locations inventory of this equipment and its location on site shall be prepared and included in the contractor’s Method Statement. 5.8.5.20 Emergency spill Key vehicles that work at the work sites for the majority of the time Construction Contractor At all times Sheeting / drip trays in all kits must be equipped with temporary sheeting / drip trays and key vehicles absorbent materials in case of emergency maintenance in the field. 5.8.5.21 Spill All spills of fuels, oils or other hazardous substances shall be Construction Contractor Immediately following Incident and corrective management cleaned up and measures taken to remediate the spill. The any spill action records. and reporting incident shall be reported to the ECO and an incident report completed. The ECO shall ensure that the spill is cleaned up and the incident closed out with the Contractor. 114 March 2019 18103533 Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification 5.8.5.22 Bioremediation Small quantities of soils contaminated by hydrocarbons (less than Construction Contractor After any spill. As per requirement. of hydrocarbon 20 kg) shall be treated in situ using bio-remediation. Large Incident and corrective spills quantities of contaminated soils (greater than 20 kg) or if there is action records. the potential to cause pollution to groundwater, surface water or community groundwater facilities shall be removed to an area at the Construction Camp allocated by the EC for longer term bioremediation. Contractors shall be responsible for the bioremediation until the following standards are met:  there is no hydrocarbon odour,  the soil particles do not coagulate as a result of hydrocarbon contamination,  there is no visual evidence of hydrocarbons in the soil. Where there is uncertainty the soil shall be sent to an accredited laboratory for analysis. 115 March 2019 18103533 5.9 Camp Sites and Lay Down Areas 5.9.1 Construction Camps Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification 5.9.1.1 Location of The construction camp shall be located within the existing bush Environmental Pre-construction or as Acceptability of location camps cleared and de-mined area on the CTT site adjacent to the CTT Coordinator required verified in pre-construction plant footprint as per the layout maps. The laydown and logistics documents or by ESC. camp associated with the beach landing activities will be finalised Ancillary approvals or based on the beach landing site option chosen, and this should be clearances where finalised with the ESC and SHE Manager/ESO’s approval and required. screened and managed in accordance with this ESMP and the RPF. Where needed site-specific ESMPs and RAP/ARAP/LRP will be prepared and approved with necessary clearances including CTT and WB N/O. 5.9.1.2 Topsoil Topsoil stripped from the site shall be stored and managed in Construction Contractor During site clearing As per requirement management accordance with the general specification in Section 5.5.4. during site construction 5.9.1.3 Security Camps shall be fully fenced and gated, with security control at the Construction Contractor During camp construction As per requirement entrance. No unauthorised entry into the camps shall be permitted. and at all times thereafter A Security Management Plan for hiring of private security shall be prepared and approved by the ECO for implementation. The plan will be developed in accordance with the Voluntary principles on Security and Human Rights. This will be cross referenced to the Community Health Safety and Security Plan (CHSSP). 116 March 2019 18103533 Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification 5.9.1.4 Sewage Sewage effluent shall be drained to a brick or concrete-lined sump Construction Contractor During camp Construction and treatment and treated in a package sewage plant, the effluent from which construction. operation of plant as per shall comply with the requirements of the Mozambique regulations Monitoring at specified requirement. for domestic wastewater (Decree 18/2004 Appendix IV). The intervals thereafter Compliance with sewage sewage plant shall be sized in order to cater for the maximum effluent wastewater forecast loads over the project construction period. Regular standard compliance monitoring of effluent quality shall be undertaken Records of treated sewage effluent monitoring and trends in ESO monthly reports 5.9.1.5 Stormwater Accelerated erosion during storm events shall be minimised during Construction Contractor During camp As per requirement. management all stages of construction. Where necessary, berms and other construction. Monitoring Evidence of stormwater stormwater management facilities shall be constructed to prevent at specified intervals management and lack of channelling of stormwater and direct it off site thereafter erosion gullying on site 5.9.1.6 Dust damping Treated sewage effluent may be used for dust damping along the Construction Contractor As required Records of use for dust using treated project access roads or shall be routed into an appropriately-sized control sewage effluent French drain system. As per requirement 5.9.1.7 Non-hazardous All non-hazardous camp waste shall be collected, separated for Construction Contractor At all times As per requirement waste recycling, temporarily stored, transported and disposed in Records of waste collected management accordance with the specification set out in Section 5.8.1 and and recycling Decree 94/2014 Manifests of waste collection and disposal at selected municipal waste disposal site 117 March 2019 18103533 Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification 5.9.1.8 Hazardous Any quantities of hazardous waste that are generated at the Construction Contractor As required As per requirement waste camps shall be disposed of in accordance with the requirements Records of waste collected management set above. by certified hazardous waste contractor Refuelling The refuelling facilities provided at the personnel camp, shall Construction Contractor Pre-construction design. Facility design drawings facilities comply with the requirements set out in Section 5.8.5. Vehicle Camp construction As per requirement wash bays shall also be designed to trap wastewater and residual oils, as specified in Section 5.8.5. 5.9.1.9 Diesel Diesel power generators shall be located on a flat, impermeable Construction Contractor Pre-construction design. Facility design drawings generators surface, bunded to contain fuel spills Camp construction As per requirement 5.9.1.10 Servicing of Vehicle and equipment servicing shall be undertaken at the Construction Contractor As required No servicing at the vehicles and Construction Camp. personnel camp equipment 118 March 2019 18103533 Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification 5.9.1.11 Services The Construction Camps shall provide services to CTT Construction Contractor At all times Compliance with relevant included at construction personnel, including: standards elsewhere in the Construction  Offices and administration facilities c-ESMP Camps  Accommodation and ablution facilities  Catering and dining facilities  Workshops, laydown, warehouses and storage area  Utilities area (water, power and sewage)  Vehicle and equipment servicing facilities,  Hazardous and non-hazardous (including recyclable) temporary waste storage facilities,  Security guard houses All service listed above shall comply with the requirements set out in the relevant sections of this c-ESMP. 119 March 2019 18103533 Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification 5.9.1.12 Light Pollution at  Identify zones of high and low lighting requirements, focusing Construction Contractor During construction No complaints from night (applies to on only illuminating areas to the minimum extent possible to ESO activities at camp and surrounding communities construction allow safe operations at night and for security surveillance; CLO laydown areas in terms of light pollution camp and laydown areas)  Plan the lighting requirements of the facilities to ensure that lighting meets the need to keep the site secure and safe, without resulting in excessive illumination;  Reduce the heights of light post where possible and develop a lighting plan that focusses on illuminating the required areas through strategically placed individual lights rather than mass light flooding;  Utilise security lights that are movement activated rather than permanently switched on where feasible, to prevent unnecessary constant illumination;  Fit all security lighting with ‘blinkers’ or specifically designed fixtures, to ensure light is directed downwards while preventing side spill. Light fixtures of this description are commonly available for a variety of uses and should be used to the greatest extent possible; and  Eliminate any ground-level spotlights as these invariably result in both direct glare and increased sky glow and cannot be effectively mitigated. 120 March 2019 18103533 5.9.2 Lay Down Areas Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification 5.9.2.1 Activities Laydown areas may include facility for the storage of equipment Construction Contractor As required As per requirement permitted in lay and supplies that are needed close the work sites. Provision for down areas fuel storage and supply may also be made at lay down areas as well as materials. Fuel storage shall comply with the requirements set out above. All vehicle and equipment servicing shall take place at the project Construction Camps. 5.9.2.2 Siting of The Environmental Coordinator shall approve the location of all Construction Contractor As required Location outside of laydown areas laydown areas including the final position of the beach laydown CTT SHE Manager prohibited areas and refuelling area, in consultation with CTT SHE Manager/ESO. Authorisation of EC sites 5.9.2.3 Securing of Where considered necessary by the Managing Contractor, Managing Contractor As required Appropriate security laydown areas laydown areas shall be fenced, and security guards shall be Construction Contractor around laydown areas stationed at the perimeter to prevent inadvertent or deliberate access by local people. 5.10 Work Sites - General 5.10.1 Access Control Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification 5.10.1.1 Access to The Construction Contractor shall provide a method statement, for Construction As required Control measures to pipeline approval by the Managing Contractor, which demonstrates Contractor avoid / prevent accidents that open trenches that could be accessed by the public: Managing Contractor at trenches 121 March 2019 18103533 Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification construction  are adequately protected by a barrier or fence of at least 1 Absence of complaints in sites m in height and as close to the excavation as is the Compliments and practicable; and Complaints Register  are provided with warning illumination or any other clear visible boundary indicators at night or when visibility is poor or any other suitable and sufficient precautionary measure acceptable to the Managing Contractor. If any sections of a pipeline cause a significant disruption of access for members of the local community, resulting in a lengthy detour, provision shall be made for temporary access across the trench. Escape ramps shall also be included. Following the laying of the pipeline and backfilling, access shall not be restricted, and community access shall be re-instated. 5.10.1.2 Open The CLO shall keep nearby inhabitants informed about the location Construction At all times Records of trenches of open trenches, alternative access arrangements, and the Contractor communication with along schedule for closing them. CLO communities about pipelines access. Absence of complaints in the Compliments and Complaints Register 5.10.1.3 Access to Access across any road construction site leading to camps shall, in Construction At all times As per requirement road general, not be restricted, except as necessary to ensure Contractor Record of consultation construction community safety in the immediate area of construction. Access with authorities and sites along secondary gravel and dirt roads leading to a road construction communities regarding site may be restricted for construction purposes for short periods access following consultation with local communities and authorities. 122 March 2019 18103533 5.10.2 Civil, Steel and Mechanical Work Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification 5.10.2.1 Welding Any welding or other sources of heating of materials shall be Construction Contractor At all times As per requirement done in a controlled environment wherever possible and under Absence of bush fires appropriate supervision, in such a manner as to minimise the risk of bush fires and injury to staff. 5.10.2.2 Pipe cleaning Pipe cleaning may involve the use of acids / caustic soda. This Construction Contractor During pipe cleaning As per requirements of requires specialist management with regards to delivery, CTT’s WMP handling, storage and disposal and shall be done in accordance with the requirements of CTT Waste Management Plan in a manner which minimises any potential environmental impacts. 5.11 Work Sites - Specific 5.11.1 Pipeline Installation and Testing Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification 5.11.1.1 Animal Trench excavations shall be left open for the minimum period of Construction Contractor Ongoing Record (including protection time possible. Excavations left open during construction shall be photographs) of animal checked daily (especially once the rainy season begins) to removal from trench. ensure that animals trapped in the trench are safely removed and released away from construction activities. Escape ramps shall also be included. 123 March 2019 18103533 Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification 5.11.1.2 Removal of At least two members of the Managing Contractor’s and/or Construction Contractor In advance of site Training records dangerous Construction Contractor’s teams shall be trained in the handling Managing Contractor establishment Presence of trained staff animals of poisonous snakes and other animals. The Contractor shall on site at all times ensure that there is always a trained snake handler on site. Where practical anti-venom for the most common poisonous snakes should be kept on site at the medical facility in the event of an emergency. 5.11.1.3 Waste disposal No waste shall be disposed of in any trench or pipeline / pipeline Construction Contractor As required Records of waste disposal. in trenches excavation. Building rubble and solid cement may be disposed of in borrow pits in accordance with the requirements in the Section below. 5.11.1.4 Replacement of Where the land is naturally armoured (significant amounts of Construction Contractor After pipe-laying. Photographs (before / rock armouring surface rock and stone), this material may be returned over the after) construction right of way in approximately the same proportions as occurred prior to construction. 5.11.1.5 Disposal of The Managing Contractor shall authorise the proposed location Construction Contractor After trenching Record of authorisation waste rock and method of disposal of any waste rock excavated from the Managing Contractor As per requirement pipeline trench. As a general rule, windrowing of waste rock along the perimeter of the trench shall be prohibited. Waste rock and other granular material shall be collected and transported to a disposal site approved by the EC / ESO. Erosion gullies or old borrow pits shall be identified for the preferential disposal of this material. The method statement shall include the measures that are proposed to stabilise and re- instate the disposal site. 124 March 2019 18103533 Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification 5.11.1.6 Backfilling Soil shall be replaced in the trench in the order of removal, i.e. Construction Contractor Backfilling. Photographs. subsoil first, followed by topsoil. Final topsoil levels may be mounded slightly in order to allow for settlement of material in the trench. Refer to general topsoil management and rehabilitation requirements in the sections above. 5.11.1.7 Drainage control The Construction Contractor shall prevent the development of Construction Contractor After backfilling. Photographs. preferential flow paths that may develop along the pipeline trench following backfilling. This is more likely to occur where the pipeline is aligned with the direction of flow. This effect can be reduced by creating low, 100 mm high, 2-5 m wide, lenticular shaped berms at 50 – 100 m intervals near-perpendicular to the pipeline route across the width of the servitude. 5.11.1.8 Hydrotesting / Water for hydrotesting shall be obtained only from boreholes Construction Contractor Hydrotesting. Quantities of water used to pipeline testing approved for the project. No water shall be obtained from the be recorded. Govuro River, barrier lakes or from the identified coastal Records of supply streams. Necessary permits for the use of water shall be Authorisation for water obtained from the authorities (ARA-SUL) abstraction 5.11.1.9 Hydrotesting / No contaminated water shall be discharged into the environment. Construction Contractor During hydrotesting As per requirement. pipeline testing Should biocides or corrosion inhibitors be used during MSDS’S for corrosion hydrotesting, they shall be ‘environmentally friendly’. Every effort inhibitors used shall be made to reduce residence times of water in the pipeline demonstrating low toxicity so as to avoid the need for biocides and corrosion inhibitors. The management of wastewater from hydrotesting shall comply with the requirements set out in the CTT Waste Management Plan. 125 March 2019 18103533 5.11.2 Borrow Pits Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification 5.11.2.1 Authorisation of The Construction Contractor shall obtain approvals for borrow Construction Contractor Prior to excavation of Mining Permit borrow pits pits in accordance with the Mozambique mining law (Decree borrow pit Environmental license 62/2006, Chapter IX). A permit is required under this law. Borrow pits are also classified as Type B activities in terms of the Environmental Regulations (Decree 54/2015) and must be licensed on the basis of a Simplified Environmental Impact Study to be submitted to MITADER in accordance with the requirements for Type B activities. 5.11.2.2 Borrow pit The Construction Contractor shall also submit the location of Construction Contractor Prior to excavation of Authorisation by location proposed borrow pits to the Managing Contractor for submission Managing Contractor borrow pit Managing Contractor to the Government of Mozambique for authorisations. Where Record of absence of necessary, the Managing Contractor shall call upon specialist sensitive site features consultants to verify the acceptability of the location in terms of any environmental and social sensitivities that may be associated with such a site in accordance with this ESMP and the RPF. 5.11.2.3 Minimising the Borrow pit development shall be minimised wherever possible, Construction Contractor As required Report on borrow pit site number of e.g. open one instead of several. The Construction Contractor selection borrow pits shall also take cognisance of the existence of borrow pits developed for previous projects in the area and investigate re- opening these rather than opening new borrow pits. The location of borrow pits shall be authorised by the Managing Contractor after screening in accordance with this ESMP and the RPF. 126 March 2019 18103533 Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification 5.11.2.4 Borrow pit No Borrow pit shall be operated without prior approval of a site Managing Contractor Prior to opening borrow Pre-excavation development and specific ESMP and approval and implementation of a site- Construction Contractor pit. photographic records closure specific RAP/ARAP/LRP, if required. Photographic records shall be kept of borrow pits before any activity on site in order to establish a baseline condition. The expectation shall be that the Contractor shall reinstate the borrow pit to a condition that will facilitate eventual recovery of vegetation to similar to the pre- construction status. Alternatively, with local community concurrence, the borrow pit could be restored to a pond or wetland (with gently sloping sides), suitable as a livestock or wildlife watering area, only where practical. 5.11.2.5 Borrow pit The Contractor shall comply with the CTT Framework Construction Contractor During establishment, As per Work Instruction development and Decommissioning and Rehabilitation Plan for the borrow and closure requirements closure decommissioning and rehabilitation of borrow pits. 5.11.2.6 Borrow pit No borrow pit shall be used as a waste disposal site for domestic Construction Contractor Closure of borrow pit As per approved Method development and or hazardous waste, either temporary or permanent. Building Managing Contractor Statement closure rubble and solid cement may be disposed of in borrow pits in accordance with the requirements of the CTT Framework Decommissioning and Rehabilitation Plan 127 March 2019 18103533 5.11.3 Road Construction Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) or verification 5.11.3.1 Road drainage The Construction Contractor shall take measures that will Construction Contractor Ongoing As per Section 5.5.4 and erosion prevent erosion along unsurfaced roads during construction. control 5.11.3.2 Reinstatement Re-instatement and rehabilitation shall be in accordance with the Construction Contractor Post construction. As per Section 5.5.4 and rehabilitation specifications in previous subsections. 5.11.3.3 New road No new road construction will take place without the approval of Construction Contractor Ongoing As per Section 5.5.4 construction the Managing Contractor. Any new road construction will require Managing Contractor a site specific ESMP and approval and implementation of a site- specific RAP/ARAP/LRP, if required. 5.11.4 Environmental and Social Management Plan Development and Budget Estimates At this stage of the CTT project, a full suite of management plans and procedures have not yet been developed. The core management plans, some of which have been developed as frameworks will still need to be expanded on once the final CTT project technology is selected as well as final selection of routes, beach landing site, barge navigation route and anchorage point. The implementation of these management plans, in conjunction with the c-ESMP will be the responsibility of the EPC Contractor during construction phase. This c-ESMP, as well as the management plans and framework plans completed to date, will form part of the construction tender documents to be published in order to ensure that the activities required to be placed under the responsibility of the EPC Contractor will be accurately costed as part of their proposals. The c-ESMP for each contractor will include a budget to be approved by CTT with World Bank N/O. The full Environmental and Social Action Plan (ESAP) is an annex to the ESIA. The following table provides a preliminary ESMP budget estimate, based on the main costs for implementation, including all remaining plans and procedures that need to be developed. It should be noted that resettlement costs are not included in the following table. A resettlement budget estimate is provided in the RPF. 128 March 2019 18103533 Table 5: ESMP budgets Item / Action Timing Budget Comment Existing Plans / Frameworks ESIA for CTT and 25 km T-line Complete 0 Construction ESMP (c-ESMP) draft for bidding documents Complete 0 Draft Operations ESMPs Complete 0 Draft Decommissioning/Rehabilitation ESMPs Complete 0 Resettlement Policy Framework Complete 0 New Plans / Procedures / Items to be developed Contractor Local Procurement Plan for Goods and Services, as Prior to EPC contract $20,000 part of EPC contract. signature Project Stakeholder Engagement Plan (for construction, Prior to EPC contract $100,000 operations, and decommissioning phases). GRM and linkages signature to resettlement committees Project Human Resources Manual Prior to EPC contract $25,000 Including: (i) HR Policy, (ii) project specific T&C's, (iii) Code of signature Conduct covering community health & safety, (iv) employment contract requirements, (v) applicability to all contractors and sub- contractors. 129 March 2019 18103533 Item / Action Timing Budget Comment Detailed RAP/RAIP/LRP approved for each affected group (land 60 days following financial $100,000 holders, roadside vendors, Tourism operators, fishermen and close; prior to construction communities) Final Project ESMS 60 days following financial $100,000 close; prior to construction Final E&S Management Plans 60 days following financial $200,000 close; prior to construction SEA/GBV Prevention and Response Action Plan 60 days following financial $30,000 close; prior to construction Final operations ESMPs and Decommissioning and 60 days after commercial $50,000 Rehabilitation Plan operations date Ongoing monitoring as required under all management plans Construction and $300,000 Operations Phase, as per frequencies discussed in ESAP Environmental studies updated for the final preference of [Prior to earlier of approval $100,000 anchorage point, barge route and beach landing site of the guarantee or EPC signature] (to be confirmed) (identification of alternative anchorage sites endeavoured to be complete by approval of guarantee) 130 March 2019 18103533 131 March 2019 18103533 6.0 PERFORMANCE ASSESSMENT, CORRECTIVE ACTION, MANAGEMENT REVIEW AND AUDIT The assessment of performance and provision for corrective actions has three key aims:  Confirmation of compliance with the requirements as set out in the c-ESMP and RPF, i.e. Construction Contractor (and CTT) performance measured against the c-ESMP;  Measurement of environmental and social performance (degree of success of the c-ESMP specifications in managing social and environmental impacts); and  Ensuring that any deficiencies in the Contractor’s or project’s performance or the c-ESMP itself are identified and remedied. These aims shall be met by monitoring of performance as follows:  Ongoing monitoring / inspections undertaken by full time site staff (the ESO(s) and CLO(s) as part of the Managing Contractor’s team);  Senior staff review (the CTT Environmental and Social Coordinator);  Review by independent consultants (where considered necessary by the Managing Contractor or CTT Environmental and Social Coordinator);  Auditing by independent consultants; and  Corrective action by the Construction Contractor or CTT shall ensure that any identified problem areas identified by the Managing Contractor’s team , CTT or the independent auditor are effectively addressed. Specifications for monitoring, review and auditing are provided in the sections below. 6.1 Environmental and Social Monitoring Strategy A monitoring strategy must be defined to ensure that the effectiveness of mitigation measures can be tracked and corrective action (see Table 6) taken as necessary. Monitoring is not only intended to verify the contractor’s compliance with the c-ESMP but also to assess the effectiveness of environmental management, independently of whether the specifications in the c-ESMP have been complied with. Table 6 defines, in broad terms, the monitoring requirements necessary during the construction phase of a project. Monitoring is undertaken by the Managing Contractor’s team, with assistance where necessary, from the CTT Environmental and Social Coordinator and from Specialist Consultants. Much of the monitoring in this kind of construction contract involves the ESO or CLO being present when potentially significant construction activities are taking place, being observant, and checking that the Construction Contractor is not materially deviating from the requirements set out in the c-ESMP. There are some specific metrics that define performance and are based on actual quantitative measurements (dust and noise are examples), but much of the monitoring is simply careful observation to check that the Construction Contractor is meeting the obligations set out in the c-ESMP. Even in the case of noise and dust, it is not always necessary to measure performance against the quantifiable standards, and this judgement must be made at the time by the ESO and the EC, depending on the circumstances. The performance standards often provide an indirect measure of effectiveness – for example, the monitoring of the Contractor’s compliance with local employment requirements and the communication of these requirements widely is an indirect measure of the control of in-migration. Non-hazardous and hazardous waste, and wastewater monitoring, are included in the CTT Waste Management Plan. 132 March 2019 18103533 It is the responsibility of the Contractor to ensure that adequate monitoring is undertaken to demonstrate compliance with the requirements of the ESMP and RPF. In some cases, performance indicators have been indicated in the ESMP and RPF standard and thus additional monitoring may be required in addition to that presented in the table. It should be noted that there are several additional plans that are currently framework documents that will need to be finalised prior to construction. The monitoring requirements outlined below will therefore need to be updated as required upon finalisation of the abovementioned plans, as well as additional parameters and monitoring criteria added for plans that still require further development (such as, but not limited to SEA/GBV action plan, detailed IMP, CHSSP and RPF etc). Table 6: Monitoring requirements Parameters / Monitoring Frequency of monitoring Performance indicator/threshold value Reporting Responsibility Activities to be location monitored Community To be based on the Daily observation at key Observation Monthly ESO/CLO ESO/CLO Nuisance (Dust) location of sensitive locations where dust is being ESO to monitor and log dust incidents where dust control is progress reports receptors in relation generated near sensitive ineffective or only partially effective in sensitive areas. Log to to construction receptors include time of day, period over which incident occurs, and activities. ESO/CLO Passive sampling when apparent severity (low, medium, high). to prioritise specified by the ESO /CLO in Community Concerns locations in which cases where dust impact is in Number of community complaints recorded in the monitoring is question either due to visible Compliments and Complaints register or made directly to the required evidence of public complaint CLO Quantitative Monitoring PM10 (daily): 50 ug/m3 TSP (daily): 150 ug/m3 PM10 (annual): 20 ug/m3 Fallout Dust: 600 mg/m2 (measured over 30 days) Community To be based on the Daily observation at key Observation Monthly ESO/CLO ESO/CLO Nuisance location of sensitive locations where noise is being ESO to monitor and log noise incidents where noise control is progress reports (Noise) receptors in relation generated near sensitive ineffective or only partially effective in sensitive areas. Log to to construction receptors include time of day, period over which incident occurs, and activities. ESO/CLO Noise monitoring using an apparent severity (low, medium, high). to prioritise integrating noise meter when Community Concerns 133 March 2019 18103533 Parameters / Monitoring Frequency of monitoring Performance indicator/threshold value Reporting Responsibility Activities to be location monitored locations in which specified by the ESO/CLO when Number of community complaints recorded in the monitoring is there is clear evidence of Compliments and Complaints register or made directly to the required community nuisance. CLO Quantitative Monitoring Daytime LAeq: 55 dBA Population Camp sites, work Ongoing watching brief Compliance with PLA employment requirements Construction Contractor CLO/ESO influx and social sites Community feedback No ad hoc employment at the work sites or camp sites Communications Plan Construction pathologies Adherence to closed camp, alcohol-free camp policy ESO/CLO progress Contractor Evidence of implementation of communicable disease reports programmes Compliments and Complaints Register Communicable Non-specific Ongoing watching brief CTT-approved STI Management Plan STD Management Plan ESO/CLO Diseases Number and nature of initiatives as per the plan Malaria Management Construction CTT-approved Malaria Management Plan Plan Contractor Record of actions taken in accordance with the Malaria ESO/CLO monthly Management Plan reports Record of STI and malaria incidents recorded among Malaria / STD incidence Contractor staff reports Record of induction training and tool box talks Traffic and Principally areas Ongoing watching brief Vehicle accident records Accident / incident ESO/CLO Pedestrian where households Pedestrian accident records reports Construction Safety and construction Near misses ESO/CLO progress Contractor teams interact Compliance with speed limits reports Advanced driver training for Contractor heavy vehicle staff Community safety references in induction briefings and 134 March 2019 18103533 Parameters / Monitoring Frequency of monitoring Performance indicator/threshold value Reporting Responsibility Activities to be location monitored ongoing toolbox talks Safety briefings of communities Compliments and Complaints Register Water Use Community Ongoing Records of groundwater use Record of community Construction Management boreholes within 1 License for use of water in terms of 43/2007 and Decree borehole monitoring Contractor km of project 18/2012 Groundwater ESO boreholes Records of monitoring of impact on community water supply abstraction report Surface water when Project supply closer than 1 km to community borehole Surface water abstraction sites Records of corrective action, where necessary abstraction report Record of authorisation of use of surface water ESO monthly report Vehicle and Camp sites, work Ongoing watching brief Records of inspection and maintenance of vehicles and ESO progress reports Construction Materials sites equipment Logistics Contractor Management Approved method statement for handling of hazardous Superintendent materials on site progress reports Compliance with requirements of approved method SHE advisor progress statement reports Inventory of hazardous materials and MSDS’s Camp manager Documentation available at specified locations progress reports Documentation confirming PCB and CFC free equipment Protection of fuel storage and camp generators as per requirement Availability of spill / drip clean-up materials at specified locations Availability of sheeting / drip trays in all key vehicles Incident and corrective action records Provision of appropriate PPE to employees 135 March 2019 18103533 Parameters / Monitoring Frequency of monitoring Performance indicator/threshold value Reporting Responsibility Activities to be location monitored Records of induction training and tool box talks Records of bio-remediation Biodiversity – Project footprint and Ongoing watching brief Induction and toolbox talks about wild animal and plant ESO progress reports ESO general and surrounding areas protection bush clearing Record of training of dozer operators to minimise Project footprint Record of training vehicle operators to remain within the approved Project footprint Records of dangerous animal removal from work sites and camps Records of communication with IUCN regarding reptile identification Absence of evidence of hunting or animal harassment Absence of evidence of unauthorised vehicle access outsider of the approved Project footprint Records of ESOs accompanying surveyors and dozer operators during bush clearing and salvaging of threatened species or relocation of infrastructure to avoid local areas of high biodiversity Footprint compliance with c-ESMP buffer zones and access restrictions Biodiversity – Project footprint and Ongoing watching brief Records of wash-down of site vehicles and equipment prior Records of vehicle ESO alien invasive surrounds to use on site to remove alien weeds wash-down species Production of illustrated alien invasive species booklet Records of alien plant Photographic record and GPS locations of alien infestation in identification and Project footprint area removal 136 March 2019 18103533 Parameters / Monitoring Frequency of monitoring Performance indicator/threshold value Reporting Responsibility Activities to be location monitored Records of removal strategy ESO monthly report Biodiversity – Project footprint Ongoing watching brief Record of induction and toolbox talks for dozer operators Photographic record ECO/ESO rehabilitation Record of training of dozer operators regarding topsoil pre-bush clearing management removal ESO monthly report Absence of contamination of topsoil with other material Evidence of reinstatement as per rehabilitation requirements of the specification Biodiversity – Beach landing sites, Monthly water quality monitoring Monitoring records and no adverse change in water quality. Specialist report and ESO Marine & barge routes and and visual inspections No marine fauna injuries or fatalities. data analysis on water MMO Coastal Habitat anchorage/tranship quality. MMO records of Specialist and species ment site marine fauna interactions or observations Cultural Project footprint and Ongoing watching brief Records of training of key personnel to identify cultural / Specialist Report (if ESO/CLO Heritage surrounding area archaeological artefacts significant artefacts Specialist Record of communication with communities to verify location found) archaeologist of sacred sites when construction is within 100 m of a known ESO/CLO monthly cultural heritage site report Compliments and Complaints Register Compliance with Chance Find Procedure and subsequent recommendations by specialist where artefacts are found Employment Project Area Ongoing watching brief Signed Project Labour Agreement (PLA) Project Labour Construction Evidence of maximising labour use in preference to Agreement Contractor machinery, where practical Records of employment CTT Local 137 March 2019 18103533 Parameters / Monitoring Frequency of monitoring Performance indicator/threshold value Reporting Responsibility Activities to be location monitored Compliance with the Community Liaison Forum procedure for Grievance Procedure Procurement selection and vetting of unskilled personnel CTT Local Procurement Officer Compliance with the PLA Officer monthly report Records of communication initiatives to improve understanding of Project-affected communities about how to apply for a job Percentage of unskilled workers from Project-affected communities Evidence of vetting semi-skilled and skilled workers according to the ‘spiral’ principle Percentage of women disabled, or otherwise disadvantaged people employed Provision and briefing of personnel about a grievance procedure Workers understanding and use of the Grievance Procedure Frequency of complaints in the Compliments and Complaints Register rand the Grievance Procedure Local Project Area Ongoing watching brief Implementation of CTT Local content plan/procedure Construction Contractor Construction Procurement Local procurement records in compliance with approved Local Content Plan Contractor Local Content Plan, developed in accordance with the CTT CTT Local Procurement CTT Local procedure Officer monthly report Procurement Local content spends in relation to total spend Officer 138 March 2019 18103533 139 March 2019 18103533 6.2 Inspections and Reporting 6.2.1 Monthly Reporting The ESO and CLO shall be full time appointments for the CTT project as it requires MITADER authorisation, and shall produce a monthly compliance monitoring report, which covers all aspects of compliance with the specification in this c-ESMP. The content of the report shall include, but not be limited to:  Main site activities during the month  Community nuisance (dust, noise)  Community health and safety (and investigations of accidents and near-misses)  Traffic and pedestrian safety  Marine and coastal ecology  Hazardous waste management  Non-hazardous waste management  Spills and hazardous product management  Wastewater management  Cultural heritage  Biodiversity  Bush clearing and topsoil stockpiling  Rehabilitation  Control of alien invasive plants  Erosion and sedimentation  Communication with stakeholders  Compliments and complaints  Trends in performance  Corrective actions / Conformance Certificate.  The format of the report may be modified with the agreement of the CTT Environmental Coordinator and Public Affairs Coordinator. 6.2.2 Corrective and Preventive Action The need for corrective action shall arise from material deviations from:  A predetermined baseline or limit (as detected by monitoring); or  General inspections based on ESMP requirements. The Managing Contractor shall establish an incident and non-conformance reporting procedure which shall be implemented prior to the initiation of any works. The procedure shall set out a structure for the proper recording of incidents / non-conformances and shall determine the necessary reporting channels. 140 March 2019 18103533 Incident recording shall include a brief description of the non-conformance with the contract specification, the date it was first logged, the reason for the non-conformance, the responsible party, the result (consequence), the corrective action taken and any necessary follow up required. Repeated non-compliances in respect of the same issue shall be highlighted Corrective actions may include:  the implementation of a specific action to remedy an identified non-conformance; or  a recommended change to the targets or objectives set in the ESMP2. In this case, following discussion and agreement with CTT, the proposed change shall be brought about in the c-ESMP, which shall be submitted to Government as a part of CTT six monthly reporting cycle (refer to Section 6.2.4) Should a Government Authority audit find that construction activities are causing unacceptable environmental damage, the Managing Contractor shall immediately consult with CTT and agree, in consultation with the Government, the remedial measures to be taken. Such agreed measures shall be implemented as quickly as possible to prevent further damage and to repair any damage that may have occurred. 6.2.3 Environmental Committee Meetings and Reporting The Managing Contractor shall establish an environmental and social committee that shall include as a minimum the ESO, the CTT ESC, a member of the Community Liaison Team and the Contractor’s environmental representative. This committee shall meet on at least a fortnightly basis to review environmental and social performance, including incidents/non-conformances reported, corrective actions implemented, monitoring results and ESMP and RPF compliance (of all supporting plans). The meeting shall be documented. 6.2.4 Six-Monthly Report The CTT Environmental Coordinator shall prepare a 6-monthly report for submission to CTT management and MITADER. The six-monthly report shall summarise environmental and social performance over the 6-month period, and examine any trends and corrective actions taken to comply with the c-ESMP, and. The report shall:  Evaluate environmental and social performance by reviewing monitoring results;  Consider trends over the period as an indication of improving or deteriorating performance  Identify any critical areas of performance that requires immediate improvement  Evaluate changing circumstances and lessons learned that may need to influence and be reflected in the c-ESMP.  Set new objectives or specifications in the c-ESMP, as appropriate; 6.2.5 Independent Audits An independent auditor shall prepare the project audits. An audit procedure shall be developed by CTT to ensure that audits are sufficiently comprehensive, and comply with the requirements of Mozambican Decree 25/2011, the Regulation on the Environmental Audit Process. The audit procedure shall include (but not limited to) the following:  Audit approach; 2 Modification to the ESMP may only be made by the CTT Environmental Co-ordinator. If the changes are major or are material changes as defined in CTT’s license, an independent environmental specialist shall verify their applicability and the ESMP shall be submitted to MITADER 141 March 2019 18103533  Scheduling;  Reporting; and  Responsibilities. It is anticipated that there shall be the following audits for the CTT project during the construction phase, scheduled as follows:  One audit every three (3) months during the first year of construction, thereafter;  One audit twice a year until the end of the construction phase;  a post-construction audit report based on a site visit, the review of monthly monitoring reports and discussion with the Contractor’s environmental and social team, CTT’s environmental and social team, community and PAP representatives and any other party whose views/opinions are considered relevant.  a final audit report at the end of the construction contract and at the end of the maintenance period (one- year post contract sign-off), prior to the CTT’s representative issuing a closure certificate for rehabilitation. Auditing shall consider the results obtained from monitoring and inputs from PAPs and stakeholders to assess whether c-ESMP and RPF objectives and targets have been met, and whether there has been any material non-conformance with stipulated c-ESMP, RPF and legal and WBG policy requirements. The audit shall also assess whether ESMP and RPF implementation has been undertaken according to the planned staffing and administrative arrangements and that the ESMP and RPF themselves (and related plans and methods) are being appropriately updated. The audit shall confirm that any identified corrective action has been undertaken and assess the effectiveness of that action as a basis for recommendations for improving contractor performance and the effectiveness of the c-ESMP and RPF. 7.0 COMPETENCY, TRAINING AND AWARENESS CREATION 7.1 General Training Requirements The Contractor shall ensure that training is provided to all employees about CTT’s commitment to conduct the proposed activities in a manner that is respectful to local people, and which minimises impact on their lands, resources and the natural environment and social environment. Training shall take the form of, but not be limited to:  Induction training;  Use of educational posters; and  Daily environmental and social discussion topics prior to the start of each shift (toolbox talks). The Contractor shall provide the induction training material and key educational posters to the Engineer for approval prior to establishment on site. Ongoing toolbox talks (to include reinforcement of safe work procedures, code of conduct etc), and other educational posters shall be structured to meet specific needs, depending on the activity being undertaken. The Contractor shall maintain an updated list of all training sessions for review at the monthly meetings. For induction training, the material shall include but not be limited to the following:  CTT’s corporate environmental, social, health and safety policies and applicable Mozambican environmental regulations, World Bank Group policies and guidelines;  Avoidance of activity outside of the approved construction right of way;  Traffic and pedestrian safety; 142 March 2019 18103533  Permitted communication and courteous behaviour in interactions with communities;  Purchase of food and goods from hawkers, including prohibition of bulk fish or any bushmeat purchases;  Management of STDs and malaria;  Alcohol and drug policy;  Code of Conduct in general and sanctions;  SEA/GBV and sexual harassment policies, accountability framework and referral system;  Minimising nuisance impacts in local communities;  Minimising impacts on cultural heritage (including Chance Find procedure);  Minimising impacts on natural heritage (prohibition of hunting, harassing animals, plant collection, animal capture for pets);  Safe relocation of snakes or other potentially dangerous animals;  Handling potentially hazardous and polluting substances;  Use of sanitary facilities on site;  Dealing with pollution spills;  Littering, especially with plastics or other non-biodegradable wastes;  Firefighting procedures;  Procedure for emergency response; and  Reporting of incidents. Toolbox talks shall be structured to provide more detail around the specific tasks and behaviours that are the responsibility of the construction crew. Contractors and CTT shall make financial provision for unforeseen potential impacts that may require specific mitigation / management measures 7.2 Specialist training material CTT shall prepare and provide to the Contractor the following field booklets for use by key members of staff and for dissemination to employees, as requested:  ‘Encountering Wild Animals’: the booklet shall contain easy to understand, fully illustrated informa tion about wild animals that could be encountered, whether they are dangerous, and the necessary actions to be taken in the event that they are found.  ‘Managing Alien Invasive Plant Species’: The booklet is to include all alien plant species listed in th e c- ESMP, with clear illustrations and recommended methods of eradication.  ‘Good Relationships with Communities’. The booklet is to provide all personnel with basic rules of courteous communication with community members when encountered in the field as well as good behaviour in general with respect to the community including aspects related to prevention of SEA/GBV.. 7.3 Handling of potentially dangerous snakes and other animals The Contractor is to train selected members of staff in safe methods of handling snakes and other potentially dangerous animals. Sufficient capacity shall be developed to ensure that there is always a trained member of 143 March 2019 18103533 staff on site in the event that a snake needs to be safely removed from a work site or camp. The necessary snake handling equipment is to be provided to the employees responsible for removing snakes. All animal relocations are to be photographed, logged and reported at the monthly meetings. All snakes and other slow- moving wildlife (such as tortoises) shall be safely released in suitable habitat away from project work sites. In cases where reptiles that are captured could be rare (including snakes, skinks, lizards) they should be photographed and, if needed, temporarily kept in safe containment until they can be positively identified by a specialist. 8.0 EMERGENCY PREPAREDNESS AND RESPONSE CTT shall develop an Emergency Preparedness and Response Plan for the CTT activities (the current Emergency Preparedness and Response Framework (EPRF) shall be expanded on). The purpose of the EPRF is to outline the minimum requirements about emergency management to ensure that the appropriate resources and plans are prepared and available for an effective response to mitigate, control and recover from incidents. The detailed EPRP shall identify the potential for, and response to accidents and emergency situations in accordance with Mozambique law and recognised international standards. The plans shall also address measures to prevent such situations and to mitigate environmental impacts that may be associated with them (SHE Manager). The emergency plans shall include the establishment of a network of communication between CTT, employees, contractors, the Sasol CPF emergency medical and security personnel, as well as available emergency services including police, health department, fire departments, community associations, specialist services etc. that may be available in the area. The emergency plan(s) shall be tested on a regular basis through the use of drills and mock emergencies so as to identify and rectify any shortcomings (Production Manager and SHE Manager). 9.0 DOCUMENT CONTROL The c-ESMP forms the basis for the management of environmental and social impacts on site, during the construction phase. Based on the results of future performance assessment and review processes, the c-ESMP may be modified as the project progresses. Modifications shall only be permitted by the CTT SHE Manager, who shall retain a single master copy of the c-ESMP on the company ESMS at the CTT plant site. All changes to the c-ESMP shall be tracked, including details of the change, date of the change and name of the reviewer. The CTT SHE Manager shall ensure that any modifications are communicated, explained to and discussed with all affected parties (the Contractor, CTT management and any directly affected party who requests this information), and shall be submitted to and approved by MITADER and receive non-objection from the World Bank. CTT shall prepare a document control procedure / change management procedure which the Contractor shall comply with. This procedure shall define:  Document distribution;  Document retention; and  Management of c-ESMP and RPF revisions. The document control procedure shall also apply to the Incident and Non-Conformance Reporting described in Section 6. 144 March 2019 18103533 Signature Page Golder Associados Moçambique Limitada LN/AS/ln NUIT 400196265 Directors: G Michau, RGM Heath Golder and the G logo are trademarks of Golder Associates Corporation g:\projects\18103533 - sasol mgip esia\6. deliverables\drafts\cemp\mz trep p160427 ctt revised c-esmp wb gcr_golder revision_tracked version.docx 145 golder.com