AshesiUniversity

Environmental & Social Review Summary

This Environmental and Social Review Summary is prepared and distributed in advance of the IFC Board of Directors’ consideration of the proposed transaction. Its purpose is to enhance the transparency of IFC’s activities, and this document should not be construed as presuming the outcome of the Board of Director’s decision. Board dates are estimates only.
Any documentation which is attached to this Environmental and Social Review Summary has been prepared by the project sponsor and authorization has been given for public release. IFC has reviewed this documentation and considers that it is of adequate quality to be released to the public but does not endorse the content.

Project number	27152
Country	Ghana
Sector	Education Services
Department	Health and Education
Company name	Ashesi University College
Environmental category	B
Status	Pending Disbursement

Date ESRS disclosed	January 6, 2009

Previous Events	Signed: April 3, 2009 Approved: March 30, 2009

View Summary of Proposed Investment (SPI), click here

Overview

Category & Applicable Standards

Key Issues & Mitigation

Community Engagements

Client's Documentation

Overview of IFC's scope of review

IFC’s review of this project consisted of appraising technical, environmental and social information submitted by the project Sponsor, including a review of:

- The site plan for the proposed university campus
- Ashesi’s “Employee Handbook”
- Plans for waste-to-biogas technology for sustainable management of domestic wastewater and biodegradable municipal solid waste
- Response to a questionnaire given to the Sponsor by IFC

In addition, IFC met with the project team at the existing Ashesi University College in Accra and also visited the project site at Berekuso, located approximately 25 kilometers north of the city of Accra.

Project description

This expansion project is to relocate Ashesi University College (“Ashesi” or “Sponsor”), a private liberal arts college in Ghana, and to enable the first phase of construction for Ashesi’s permanent campus in Berekuso, peri-urban Accra, approximately 25 kilometers north of the capital city of Accra. The new campus will be built in phases and has a planned capacity of 2,000 students. For the first phase of the new campus development, Ashesi is seeking funding of US$8.2 million to develop academic capacity for 600 students including: campus infrastructure, academic buildings, libraries, cafeteria and dormitories for 240 students. For this project, Ashesi will secure $5.2 million in philanthropic grants for the academic buildings and infrastructure, and is seeking another $3.0 million in debt to finance construction of student dormitories. IFC has been asked to provide the debt funding of up to US$2 million for this phase and a further $1.0 million in debt for student village housing.

Identified applicable performance standards

While all Performance Standards are applicable to this investment, IFC’s environmental and social due diligence indicates that the investment will have impacts that must be managed in a manner consistent with the following Performance Standards:

PS1: Social and Environmental Assessment and Management Systems
PS2: Labor and Working Conditions
PS3: Pollution Prevention and Abatement
PS4: Community Health, Safety and Security
PS6: Biodiversity Conservation and Sustainable Natural Resource Management

The project appraisal also assessed the applicability of the following Performance Standards:

PS5: Land Acquisition and Involuntary Resettlement
PS7: Indigenous People
PS8: Cultural Heritage

The land for the project site was acquired by Ashesi from the chief of Berekuso through a willing buyer-willing seller agreement. Under the current development plan, Ashesi is expecting that the access road leading from the highway to the project site, which is part of the development plan of the Town and Country Planning Department, will be upgraded by the local authorities. If it is, it would not be considered as an associated facility as it would be serving as a thoroughfare between two villages. PS5 would not, then, apply to this project. Despite the fact that the road is not an associated facility, Ashesi would use reasonable endeavors to influence the local authorities to follow PS5 during their land acquisition process. Should, however, the local authorities not construct the road in time for the opening of the campus, Ashesi would have to acquire the land and upgrade the road itself. Under those circumstances, PS5 will apply and Ashesi would need to develop a land compensation plan as only economic displacement would take place. In any case, the Environmental and Social Impact Assessment (ESIA) for the project is considering the social and environmental impact of upgrading the road.

There are no groups in the project area that would be considered as Indigenous People for the purposes of PS7, so this Performance Standard does not apply.

No cultural heritage sites are known to be on the project site. However, since the project is a green-field development, Ashesi will, in collaboration with the Ghana Archaeological Department, establish and implement a chance find procedure as part of its environmental and social assessment before construction begins. According to the information available at this time, PS8, Cultural Heritage does not apply to the project.

Environmental and social categorization and rationale

The project involves a green-field development in a peri-urban area. The key social, environmental, health and safety issues associated with this project will include:

- Solid waste management;
- Wastewater treatment;
- Storm water drainage;
- Energy and water conservation;
- Worker health and safety; and
- Life and fire safety.

The project itself will have limited impacts on the surrounding environment. The abovementioned issues can be addressed through known and accepted procedures and technologies to avoid or mitigate social and environmental impacts. Thus, this project has been classified as a Category B according to IFC’s Environmental and Social Review Procedure.

Key environmental and social issues and mitigation

The Sponsor has presented plans to address the identified impacts to ensure that the proposed project will, upon implementation of specific, agreed upon measures, comply with the environmental and social requirements: (i) the host country laws and regulations, (ii) IFC’s Performance Standards on Social and Environmental Sustainability, and (iii) the World Bank/IFC environmental, health and safety (EHS) guidelines.

PS 1: Social and Environmental Assessment and Management Systems

Environmental and Social Assessment: The Sponsor has hired an external consultant to conduct a social and environmental assessment of the project and to develop an Environmental and Social Impact Assessment (ESIA) to meet the requirements of the Ghana Environmental Protection Agency (EPA). The assessment will also ensure that the requirements of the IFC Performance Standards and the World Bank/IFC EHS guidelines are met. As part of the Ghana EPA social and environmental procedure, a public review of the ESIA will take place.

Management Program: Ashesi will develop a program of mitigation and performance improvement measures that will address the project’s impacts and risks identified in the ESIA and which can be applied throughout the life of the project. As part of this program, Ashesi will develop an Environmental and Social (E&S) policy and an Environmental and Social Action Plan (ESAP). The ESAP will be developed based on the Supplemental Action Plan (SAP) attached to this ESRS, and will include any other identified actions that will be needed to comply with the IFC Performance Standards, World Bank/IFC EHS guidelines, and the requirements of the Ghana EPA. It will also be updated annually to reflect campus expansion and further measures to reduce project social and environmental impacts that may be identified in the future.

Organization, Monitoring and Reporting: Ashesi will identify and designate a person to take responsibility for managing the social and environmental issues associated with the project. This person will, among other things, ensure that the attached SAP and Ashesi’s ESAP are implemented, monitor the E&S performance of the project and update the ESAP, at least annually, to reflect identified actions that need to be taken to improve on the project’s E&S performance. The designated person will also report on the monitoring results to Ashesi’s senior management and local stakeholders such as the Ghana EPA. Ashesi will also make a practice of publicly displaying information on resource savings from its application of waste-to-biogas technology and water conservation measures, e.g., resource savings will be reported to students.

Training: Because the proposed technology for treating liquid waste is sophisticated, Ashesi will ensure that its operators have received the training necessary to operation and maintain it.

Community Engagement: Ashesi will designate a community liaison officer who will be responsible for local community consultations, which will include, among other things, disclosing the ESAP to the local communities. Ashesi also needs to develop a community grievance mechanism for the local communities to voice their grievances about the E&S performance of the project. This mechanism will have a procedure for ensuring that complaints are fairly and transparently treated and a response given within a defined time. The point of contact for the grievance mechanism will be the community liaison officer. Ashesi will also make copies of this ESRS publicly available.

PS 2: Labor and Working Conditions

Human Resources Policy: Ashesi has a Human Resource (HR) policy that outlines its terms of employment and a standard grievance procedure for employees, but does not include a policy relating to the minimum age of employees, the right to collective bargaining agreements, workers’ organizations, and non-discrimination and equal opportunity, as they pertain to Ghanaian labor law. Ashesi will make these additional provisions explicit in its HR policy and publish internally the updated HR policy to all employees.

Contractors: Ashesi will include labor and working conditions requirements consistent with IFC Performance Standard 2 and national labor law into all contracts with contractors and sub-contractors. Compliance with these requirements will be monitored by Ashesi.

Worker Health and Safety: During construction, the use of personal protective equipment (PPE) will need to be enforced to reduce the risk of work-related accidents and injuries. Ashesi will need to train workers (including contractors and sub-contractors) on the use of PPE and health and safety procedures.

PS 3: Pollution Prevention and Abatement

Solid Waste Management: Ashesi plans to install a biogas plant on its new campus to treat organic waste that will be generated. Solid waste will be segregated at source into biodegradable organic waste (e.g., kitchen waste) and inorganic waste (e.g., metal, textile, paper). Students’ awareness will be created to achieve a high segregation rate. Steel scraps will be sent to steel melting plants, while paper will be sent to paper recycling plants.
Wastewater Treatment: The biogas plant will be designed and constructed such that grey water will be piped separately from sewage flows. Sewage flows will be channeled to the primary treatment chamber, which is essentially a bio-digester, for a designed retention period that will ensure over 99% destruction of all types of pathogens and to attain biological wastewater parameters that meet environmental quality guidelines and standards for discharge to surface waters. The bio-digester effluent will be channeled into gravity filtration beds with carbon as a secondary treatment facility for odor and particulate removal to reduce total dissolved solids. Finally, the effluent will be subject to tertiary treatment by non-chlorine, state-of-art copper-silver ionization system for destruction of residual pathogens, viruses, algae, and bacteria. This will render the treated wastewater recyclable for non-critical applications, especially for irrigation and landscaping throughout the year, as well as make it non-hazardous or non-infectious for continuous recycle to supplement potable water for the operation of toilets. The treated effluent will be tested periodically.
Stormwater Drainage: Water drainage channels will be constructed as part of the design of the new campus to control flooding during the rainy season.
Resource Conservation: The new campus will be designed such that there will be maximum air circulation to limit the use of air conditioning. Biogas generated from the treatment of human waste, which contains methane, will be used for cooking and for security lighting purposes. The school’s sewage system will be designed to use toilets with cistern capacity of 4.5 liters instead of the current 9 liters. This smaller size will reduce water demand for the water closets by 50%. The continuous generation and reuse of treated effluent will reduce the demand for potable water for landscaping, particularly during the dry season.
Greenhouse Gas Emissions: The new campus will obtain power from the national grid, but for this phase of the project, it will have a back-up generator capacity of 600kVA. This is below the level where IFC guidelines on air emissions apply. However, to limit air emissions, the generators will follow a maintenance schedule to ensure that they are operating efficiently. Diesel for the generator will be obtained as and when it is needed, so there will be no mass storage of fuel on-site.

The on-site treatment of human waste will prevent the emission of methane directly into the atmosphere and thus reduce equivalent carbon dioxide emissions. Ashesi intends to monitor the emission reductions and to seek a possible buyer for its Certified Emission Reductions.

PS 4: Community Health, Safety and Security

Potable Water: Water for the new campus will be obtained from an on-site borehole and will be treated prior to using. Ashesi will be required to test the water quality before the campus starts operating and at least annually thereafter.
Life and Fire Safety: The new campus will be designed, constructed and operated in accordance with internationally accepted life and fire safety (L&FS) standards and local fire department regulations. Ashesi will submit to IFC an L&FS Master Plan that will identify, among other things, major fire risks, applicable codes and mitigation measures. The L&FS Master Plan will be prepared by a suitably qualified professional, acceptable to IFC, who will certify that the design meets the requirements of IFC’s L&FS guidelines. The qualified professional will also undertake a review at the time of L&FS systems testing and commissioning and certify that construction of these systems has been carried out in accordance with the accepted design.

In addition to the above, Ashesi will need to put in place a training program for staff and students that will cover fire prevention and response and designate qualified personnel who will be responsible for implementing the training program.

Security Personnel: Ashesi uses private security personnel who are not armed.

PS6: Biodiversity Conservation and Sustainable Natural Resource Management

The project site is located in a modified habitat with mostly elephant grass and a few remnants of forest species, including a teak plantation. As part of the landscaping of the new campus, and for the purposes of biodiversity conservation, Ashesi will preserve the forest species and identify other areas of protection.

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