E-Power S.A.

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	27274
Country	Haiti
Sector	Utilities
Department	Infrastructure
Company name	E-Power S.A.
Environmental category	B
Status	Pending Disbursement

Date ESRS disclosed	January 23, 2009

Previous Events	Signed: July 1, 2009 Approved: June 5, 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 appraisal of this project consisted of desk review of environmental, social, health and safety, and labor information, including the revision of the first and final draft of Environmental Impact Study (EIA) and the Environmental and Social Management Plan (ESMP) for the project, prepared by the consortium ENTRIX (Environmental and Natural Resources Management Consultants, www.entrix.com) and Paredes Consultores Ambientales, S.A. (www.pcambientales.com). Furthermore, an environmental specialist based in IFC HQ in DC performed a site visit to E-Power site in Port au Prince (PAP), and held meetings with the sponsor’s Environmental Manager, representatives from ENTRIX, and with representatives from the Haitian Environmental Ministry. During the site visit, the IFC team visited the empty lot where the power plant will be built, and held extensive discussions with the sponsors to improve the EIA process, ESMP, and assure compliance with IFC’s Performance Standards on Social and Environmental Sustainability.

Project description

The proposed E-Power Thermal Power Plant (“the Project”) involves the construction, operation, maintenance and decommissioning of a 31.2 MW diesel power plant using heavy fuel oil (“HFO”) on a build-own-and-operate (“BOO”) basis in PAP. The project will be constructed in Drouillard, Cité Soleil, on a 50,000 m2 site located in the Hispaniola Investment Company (HINSA) free zone, west of the PAP International Airport. The facility will consist of 8 (eight) Hyundai HIMSEN H32/40 generating sets, operating at 720 rpm, on Bunker C#6, four heavy fuel treatment units, one heat recovery steam generator (HRSG), one steam turbine set, a cooling tower, and associated auxiliary facilities. Each thermal power plant will consist of a 9-cylinder turbo-charged, highly efficient HIMSEN engine. Each engine will have its own generator. The units will be fired using #2 distillate fuel oil but will run on #6 Heavy Fuel Oil. Additionally the project will involve a 3-km-69 kw transmission line and a 4.5-km long pipeline.

Engineering, Procurement and Construction (“EPC”) contractors will be the Korean companies Hyundai and DECCO, on a full-turnkey basis. Construction period is expected to be eighteen months. Total project costs are estimated at US$50 million to be financed on a 75:25 debt to equity basis.

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 System.
- PS2: Labor and Working Conditions.
- PS3: Pollution Prevention and Abatement.
- PS4: Community Health Safety and Security.

The following PSs have not been triggered by the project:

PS5: Land Acquisition and Involuntary Resettlement – The new plant requires a plot of land located in an agricultural transition, located in the outskirts of PAP, west of the city’s largest airport. The site has an area of 50,000 m2 and was purchased under a willing-buyer-willing seller agreement. No economical or physical displacement of people is expected.

PS6: Biodiversity Conservation and Sustainable Natural Resource Management – the project is located within a highly-intervened-peri-urban area, with no ecological or conservation value.

PS7: Indigenous Peoples - the project is located within a highly-intervened-peri-urban area, and will not affect indigenous people or territories.

PS8: Cultural Heritage - the project is located within a highly intervened-peri-urban area, with no archeological and cultural value.

Environmental and social categorization and rationale

E-power involves the construction of a new small diesel power generation plan on a highly intervened peri-urban area (HINSA free zone), located in Drouillard, Cité Soleil, on a 50,000 m2, west of the country’s largest airport. The plant has been designed to meet IFC Performance Standards on Social and Environmental Sustainability, as well as the Thermal Power: Guidelines for New Plants, included in the World Bank’s Pollution Prevention and Abatement Handbook (1998).

All the potential environmental, social and health and safety impacts and risk are of limited magnitude, mostly localized to the direct project influence area, and can be avoided or mitigated by adhering to generally recognized performance standards, guidelines, and/or design criteria. Therefore, this project has been categorized as a B operation.

Key environmental and social issues and mitigation

PS1 – Social and Environmental Assessment and Management Systems:

Environmental and Social Assessment: The sponsors performed an exhaustive EIA for the construction, operation, and decommissioning of the E-Power energy generation plant. This EIA was prepared by a consortium constituted by the international environmental consultant firm of ENTRIX (Environmental and Natural Resources Management Consultants, www.entrix.com) and the local Dominican Republic’s Paredes Consultores Ambientales, S.A. (www.pcambientales.com), and assessed potential environmental impacts associated with construction, operation, and decommissioning of the proposed 31.2 MW thermal power plant. The affected environmental components encompassed by this EIA include water resources, biological resources, cultural resources, geological resources, recreation and visual resources, socioeconomic resources, transportation, air quality, noise, and safety. The EIA describes the proposed project, the affected environment as it currently exists (baseline), and the potential environmental consequences that could result from construction, operation, and decommissioning of the proposed project. Furthermore, given the social volatility of Haiti, the EIA also considers safety and security issues. Additionally, the consulting consortium prepared a separate document outlining the Socio Environmental Management Plan (SEMP) and the Emergency Response Plan.

The project was conceived to be in compliance with potential lending institution’s environmental, health, and safety (EHS) guidelines, and therefore the EIA specifically articulates the need to comply with applicable World Bank guidelines and International Finance Corporation (IFC) Performance Standards (PS).

Prior to construction commencement, the sponsors will provide the lenders with complete environmental and social assessment associated with the construction and operation of the transmission line and pipeline, as well as the respective approving Environmental Licenses. No major environmental or social impacts are expected from these facilities, and no physical or economic displacement of people is expected from ROW easement

The key environmental, social, and health and safety impacts and risks associated with the project’s construction phase are those typically associated with construction and civil works such as (a) increased noise and air emissions, (b) construction solid waste and waste water management, (c) occupational health and safety of construction workers, and (d) risks associated to the operation and handling of heavy equipment and machinery. All these impacts and risks can be managed with existing pollution prevention and control technologies and with standard environmental management practices.

The key environmental, social, and health and safety negative impacts and risks associated with the project’s operation are: (e) increases NOx, SOx, and PM emissions, (f) increase emission of GHGs, (g) increase noise, (h) increased soil erosion, (i) increase water usage with the potential consequent aquifer depletion, (j) increase solid waste and wastewater generation, and (k) increased risks of accidental fuel spills and/or fuel tank explosions or other accidents. Given the project location, it is exposed to natural hazards such as floods and hurricanes.

It is important to note that once in operations this project will provide approximately 15% of the nominal energy demand of the great PAP metropolitan area. Given the current energy deficit -the city’s power supply is only about 12 hours a day- small private power generators are distributed all around PAP. These small power generators use mainly high sulfur diesel with inefficient emission controls, which significantly contribute to damage the air quality of PAP and surrounding areas. It is expected that once in operation the project will contribute to the substitution of private diesel generators, and therefore the improvement of PAP air quality.

Management Program: As part of the EIA process, the sponsors have designed a Socio Environmental Management Plan (SEMP) to assure:

-Protection to the environment and the health of the employees and the general public.
- Compliance with Haitian laws, regulations and norms pertinent in matters of health, safety, and environment, and if there
aren’t any specific national regulations apply international EHS standards, such as International Finance Corporation Performance Standards and EHS Guidelines.
- Compliance with E-Power Policy in terms of environment, health, and safety.
- Development of an organizational structure to accomplish an efficient implementation of the SEMP.
- Monitoring compliance with normative requirements and mitigation measures.
- Execution of corrective actions, as needed.
- Efficient employees’ training on the different components of the SEMP program.

In brief, the purpose of the SEMP is to design programs that ensure that the potential risks and impacts that could result from the project’s construction, operation, and decommissioning have been appropriately identified, and will be adequately measured, mitigated, and controlled. It includes a total of seven (7) programs for action:

(a) Prevention, Mitigation, and Compensation Plan, which contains measures to minimize, control, and compensate the potential environmental and social impacts that may arise from the project. More specifically, it outlines specific procedures to (i) reduce and control atmospheric emissions, (ii) mitigate any significant negative impact on air quality, (iii) control erosion and sedimentation, (iv) prevent soil, surface water, and ground water contamination, and (iv) control and mitigate industrial and ambient noise.

(b) Labor and Working Conditions Plan, which has the following objectives: (i) to establish, maintain and improve the worker-management relationship, (ii) to promote worker’s fair treatment, non-discrimination and equal opportunity, and compliance with national labor and employment laws, (iii) to protect the workforce by addressing child labor and forced labor, (iv) to promote safe and healthy working conditions, and (v) to protect and promote workers’ health. This program establishes procedures to minimize personnel’s occupational health risks, reduce the risk of incidents and accidents that could affect the health of the employees, and be adequately prepared in case of accidents or emergencies (see PS2).

(c) Social Management Plan, which establishes procedures that guide E-Power’s community relations and engagement (see Community Engagement section below)

(d) Industrial Health, Safety and Environmental Training Plan, with the objective to assure constant and exhaustive training across the company on the SEMP, and includes (i) basic operational health and safety training, (ii) new tasks employee and contractor training, (iii) visitor orientations, and (iv) emergency brigades training.

(e) Waste Management Plan, which includes procedures to (i) identify and classify waste, (ii) prevent and minimize waste generation, (iii) recycle and re-use when possible, (iv) treat, and (v) dispose.

(f) Affected Area Regeneration Plan, which defines the procedures to recover areas that could be affected by project activities, and includes (i) contaminated soil remediation program, and (ii) a vegetation cover and restoration program.

(g) Environmental and Social Monitoring Plan, which outlines the associated phase of the project (construction and/or operation), media to be monitored, the impacts to be assessed, sampling location, parameters to be measured, frequency, responsibility, and reporting. This Plan also includes a (i) Social Monitoring Program with the objective of assessing the status of the community support, and the appropriate execution of the non-discriminatory and equal opportunity programs, (ii) Annual Internal Environmental Audits - IEA, and (iii) Biannual External Environmental Audit – EEA.

Organization: The responsibility of assuring the application, implementation and supervision of the SEMP will be managed corporately by Basic Energy. Basic Energy Corporate Environmental and Occupational Health and Safety Managers based in Santo Domingo, Dominican Republic, will respectively have a local Environmental Superintendent and a Health and Safety Supervisor in the plant in PAP.

Training: Most of the programs outlined above have a training component. E-Power has defined a training program divided in (i) identification of training needs and requirements, (ii) defining training priorities, and (iii) allocating appropriate training resources. Training includes awareness of the importance of the SEMP, SEMP’s General Concepts, Legal Requirement, Environmental Practices in Processes, E-Power’s EHS Policies and Procedures, Waste Management and Hazardous Wastes, Monitoring Systems and Evaluation, Performance Evaluation, Training of Contamination Prevention and Energetic Efficiency, ISO 9000, ISO 14000, and OHSAS 18001 as tools to facilitate procedures and registries.

PS2 – Labor and Working Conditions:
Human Resource Policy and Management: Human Resources will be managed by Basic Energy, in accordance with its existing policies and procedures, and in compliance with Haitian and Dominican Republic labor laws and regulations, which are consistent with IFC PS2 requirements. Basic Energy has a well developed and establish HHRR department with written procedures associated with (i) hiring procedures, (ii) different types of contracts, (iii) salaries and compensation, (iv) capacity building and human development, (v) hiring of relatives, (vi) job induction and training, (vii) vacation and leaves, (viii) work shifts and schedules, (ix) food and lodging, and (x) health insurance.

E-Power will give priority to hiring local people where skills match available jobs. For the construction of the power plant, at least 80 workers will be needed for different tasks: machinery operators, welders, electricians, construction workers, plumbers, carpenters, engineers, topographers, among others. The workforce in the operation phase will be reduced, in comparison to construction workforce. Human resources that will be employed will require higher levels of education and training, such as electrical and mechanical engineers and accountants, among others. Less trained human resources will also be needed for security, cleaning, and maintenance tasks. For the operation of the power plant, at least 50 workers will be needed, since the plant will be operate in three 8 hour shifts - 24 hours a day – 7 days a week. Operative personnel at the plant will work in three shifts of up to 48 hours per week, with a maximum of 12 extra hours. Work on extra hours and holidays are compensated in accordance with Haitian laws. All salaries are above the legal minimum wage and those earning less than 2 legal minimum wages receive additional subsidies for transportation and food. E-Power’s workers are not expected to unionized, but in compliance with Haitian law, workers are allowed to form or join worker’s organizations and to bargain collectively, if they desire.
The EPC contractor and subcontractors will be legally required by E-Power to comply with Haitian Labor Laws, and with Basic Energy HHRR policies and procedures. The EPC contractor has in place its own HHRR policies and procedures which are also consistent with Haitian Law, but which will be updated to ensure that they give priority to hiring local people where skills match available jobs.

In the ESMP, E-Power has its HHRR Policy which includes commitments to provide workers with all relevant information regarding their rights under national labor and employment laws, including their rights related to wages and benefits; including (i) entitlement to and payment of wages and permissible wage deductions; (ii) overtime payments; hours of work and any legal maximums; (iii) entitlement to leave for holidays, vacation, illness, injury, and maternity and other reasons; (iv) entitlement to other benefits, (v) disciplinary and termination procedures and rights; and (vi)Grievance mechanisms. Furthermore, the employees’ have the right to form and join workers’ organizations and to bargain collectively without any interference or retaliation from the employer.

Additionally, E-Power HHRR Policy includes (vii) the prohibition to employ children in a manner that is economically exploitative or is likely to be hazardous or to interfere with the child’s education, or to be harmful to the child’s health or physical, mental, spiritual, moral, or social development, (viii) the prohibition to use any type of forced labor, and (ix) emphasis on local hiring and procurement.

Occupational Health and Safety: The SEMP includes a Labor and Working Conditions Plan, as one of its seven fundamental action pillars. This plan establishes procedures to minimize personnel’s occupational health risks, reduce the risk of incidents and accidents that could affect the health of the employees, and adequately prepare in case of accidents or emergencies. It assures that all personnel will be trained in all relevant aspects of industrial safety to avoid risks that may affect their health and safety, and includes (i) General Guidelines, which include the mandated used of PEP, procedures to prevent and react to fires, install toilets and showers, specification for potable water supply, eating areas, lighting, air supply, and worksite allowable temperatures, among other, (ii) Communication Guidelines, which include the labeling, codes, and signaling protocol for equipment and HAZMAT, and (iii) Work Permit Guidelines, which classifies the type of work to be performed, the area, the potential dangers involves, type of equipment and tools to be used, PEP, and risk prevention measures associated with the operation, and other relevant safety recommendations, (iv) Medical Control, (v) Control and Treatment of Occupational Diseases, (vi) Hydrocarbons, Fuel and Chemical Substance Storage and Handling Procedures, and (viii) Procedures to Monitor and Report occupational incidents, accidents, and diseases.

As a work policy, a Security Supervisor will be permanently present in the field, during construction, operation, and decommissioning activities. The people in charged of controlling the Industrial Health and Safety of the project have the following responsibilities:

- Implementing, communicating, and enforcing the Occupational Health and Safety Plan.
- Develop and encourage the participation and intervention of employees and contractors in industrial health and safety programs of the Labor and Working Conditions.
- Assume the responsibility of controlling the themes and activities related with safety in relation to the work environment, instruct their subordinates about the plan’s contents and implement it in the workplace.
- Perform inspections that guarantee the compliance of norms, rules, and actions established in the occupational health and safety programs.
- Immediately report, and if applicable, suspend the execution of works, when any act or situation could affect the employee’s or the facility’s physical integrity.

Personnel are issued appropriate Personal Protective Equipment (PPE) and provided continuous training on OH&S issues. All employees including those working for the EPC contractor and subcontractors will be covered by an Occupational Risk Insurance and are required to abide by the company’s OH&S procedures. Compliance with OH&S provisions on behalf of its staff and third parties working at the plant site will constantly monitored by the company and reported to management.

PS3 –Pollution Prevention and Abatement:

E-Power was designed to meet the Thermal Power: Guidelines for New Plant included in the Pollution Prevention and Abatement Handbook of the Word Bank groups (1998).

Air Emissions and Air Quality: Background air quality data in the area surrounding the proposed project were not available, therefore during the EIA process the sponsors measured air quality at four different sites and in two separate occasions approximately six months apart. The proposed project is located in an industrial area, with several nearby potential air pollutants sources such as the International Airport, a steel manufacturing facility, and another power generation plant. Ambient Air Quality (AAQ) sampling was performed during field work in four monitoring sites for a period of 24 hours (continuous) on each site. The monitoring locations where selected with consideration to the power plant location and local climate conditions, and in coordination with Haitian Environmental Minister representatives. The first monitoring site was located inside the proposed E-Power sitting in order to assess the existing AAQ on site. The second monitoring point was located in a soccer field approximately 9 km south-east and downwind from E-Power proposed sitting. The third point was located in the Environmental Ministry Office in Petionville, where the best air quality was expected. The fourth sampling point was located in the National Radio in downtown PAP to collect data expected to present high concentrations of air pollutants. Based on the monitoring of AAQ performed, and according to the National Ambient Air Quality Standards (NAAQS) which are acceptable to Haitian Regulators, the air-shed was categorized as non-degraded.

Emissions stack will be constructed in two groups of four chimneys. The bore diameter will have 677 mm. They will be 20 meters high and constructed according Good Engineering Practices.

Based on air-shed quality data and on Table 1 (see Annex 1), it can be stated that the project is being designed to comply with all emission parameters in the WBG PPAH 1998. If the new IFC EHS Guidelines for Thermal Power Plants were in effect (still in draft when this project was mandated), the project would only meet NOx emission level, and would exceed by a small margin SOx and PM permissible emission values. The abatement of PM is simple and inexpensive. If there are concrete plans to increase power generation over 50 MWe in the foreseeable future, PM emissions should be closely monitored as they are likely to exceed applicable PPAH 1998 emission values of 50 mg/Nm3. PM abatement measures as electrostatic precipitators (ESP) are considered in the SEMP, and will be installed to meet NAAQS, if required.

Mathematical models performed during the EIA obtained mean annual concentrations, hourly maximums, 8 hours maximum and 24 hours maximum concentrations at the same time. The mathematical model results determined that SO2, NOx and PM concentrations are below international guidelines for ambient air quality (WHO-NAAQS). However, if air quality monitoring results show higher values than those obtained by the dispersion models, E-Power has committed to implement appropriate mitigation measures.

GHG: The EIS reported the results of a study of the Greenhouse Gases (GHG) emissions on the Haitian territory performed by the Ministry of Environment in August 2001. This study stated that the Energy production sector contribution to the GHGs emissions of Haiti, represents 0,0017 of the total cumulative inventory of Haitian GHGs emissions. As one could expect it the quantity of GHGs emitted on the Haitian territory is negligible when compared with the emissions of any developed country.
The project is expected to generate about of 146,000 tonCO2/year, or about 656 gCO2/KWh. CO2 emissions performance of the average oil-fired generation in Haiti is 581 gCO2/kWh (2004-2006 average), according to the most recently published International Energy Agency (IEA 2008) Statistics, which is slightly lower than that expected from the project.

Assumptions Used:
1. Annual electricty output: 223,000,000 kWh/year
2. Fuel consumption rate: 198.45 g/kWh
3. Calorific value of fuel 42,700 kJ/kg (LHV)
4. CO2 emissions factor for HFO: 774,000 kgC02/TJ (LHV)

C02 emissions per year: 223,000 kWh/y x 198.45 g/kWh x 1kg/1,000 x 42,700 kJ/kg (LHV) x TJ/10E(09) kJ x 774,000kgCO2/TJ =
146,259,000 kg/C02 / = 146,000 tonC02/year

Noise: The proposed project location is 1440 m northwest from the western side of the PAP International Airport, therefore the noise from airplanes is noticeable from the site. The contiguous terrain to the east has a racing track where there are improvised races mainly on weekends. No measure registered Leq values above IFC ambient noise level guidelines for industrial areas (70 dB[A]). The highest noise levels registered were near the main road located north of the proposed sitting. Leq values where between 66.4 and 44.5 dB[A]. Background noise levels at the proposed project sitting were established on the basis of 10 minutes integrating measures as 56.5 dB[A] for daytime and 55.5 dB[A] for nighttime. According to the noise attenuation model used for the EIA, and without considering any physical barriers or any other kind of mitigation measure, the noise generated by power engines will not result in an increase above IFC noise level guidelines. Power plant noise will be slightly noticeable from nearest sensible receptors located 500 m away (52,7 dBA generated by power plant) and noise level increments will be minor (background levels are above noise generated by power plant at nearest sensible receptor). Noise baseline measurement where performed at the nearest receptors in Drouillard and Raket to assure that once in operation, E-Power will not worsen the noise pressure (>3dB[A]) in this neighboring community. Once in operation, noise will be measured at the plant periphery and at the nearest receptors to validate the model, and all mitigation measures will be taken to assure that noise values do not exceed IFC established levels (or increase more than 3 dB[A] from the existing baseline).

Groundwater withdrawal: The power plant will use an average of 109 m3/day of groundwater from the aquifer underneath the project site. Excessive groundwater withdrawal may cause salting of the resource, level decrease, and subsidence. These parameters will be monitored daily, in order to avoid impacts to the resource, and efforts will be made to avoid increase groundwater usage. Long term, moderate impacts on groundwater resources may be expected, as water will be pumped continually during operation phase to fulfill water consumption requirements. As the aquifer is used for community supply, additional monitoring to the existing community water wells will also be performed.

Waste-water: There are four different potential wastewater sources:
Sewage System: Sanitary water from the powerhouse, offices, and bedrooms will separately be connected to a treatment system before discharging to the municipal sewage.

Oily Water System: The separate oily water system will collect oily water from the powerhouse including the fuel oil treatment room, and the tank farm to the water/oil sludge separator. The oily water will be separated and treated.

Surface Water System/Storm Water System: The surface water drain system will channel water away from the tank farms and roads. The surface runoff will be routed to an API separator before it is discharged to an existing open drainage channel outside the site. Storm water will be discharged into the existing open drain channel.

Drainage of Tank Farms: Water discharge from tank farms will be connected to both the oily water and storm water systems. Clean water will be led to the storm water drainage system and oily water will be led to the oily water system. The discharge is to be controlled by manually operated valves.

Process and domestic wastewater will be treated before discharge to meet IFC General EHS Guidelines “ Indicative Values for Treated Sanitary Sewage Discharges” (Domestic waters: Table 1.3.1), and Process waters: Table 1 of WB guidelines for New Thermal Power Plants, 1998.

Solid waste: Hazardous wastes, mainly oily wastes, will be incinerated in cement furnaces as the first option. In case cement companies in Haiti do not comply with minimum emission EHS standards, as a second option, an incinerator will be constructed in E-Power’s site. The SEMP leaves this issue open as meetings with Haitian cement company representatives was still pending at the time of appraisal. HAZMAT management and disposal procedure will be finalized prior to first disbursement.

PS4 – Community Health, Safety and Security

Emergency Preparedness and Response: E-Power has developed an Emergency Response Plan to provide safety measures and procedures for all the personnel with the purpose of minimizing or avoiding injuries, damages, and/or service interruptions during emergencies. This Plan also foresees an orderly protocol for the communication with emergency authorities in and outside the plant, as well as the coordination of emergency procedures and the notification to possibly affected people.

In case of emergency, according to E-Power’s policy, priority assets to protect/safeguard in order of importance are: (i) guarantee personnel and community safety, (ii) protect the energy generation facilities and equipment, and (iii) minimize energy generation losses. Furthermore, the policy also states that, in case of emergencies or life threatening situations, all people not specifically assigned to emergency response labors must be evacuated from the plant.

The Plant’s manager is responsible for guaranteeing correct implementation of the plan and that all personnel are informed and trained in relation to their responsibilities. There is an Emergency Response Committee which will function during significant cases/events. This Committee is comprised of an Emergency and Crisis Response Committee Leader, a Communications Leader, an Operations Leader, and an Environment and Safety Leader. The plan outlines clear responsibilities and duties for each of these functions.

Crisis response may require significant additional resources or support beyond E-Powers’s availability/capability at the local or regional level. In most cases, during a crisis, a crisis management team will be activated and it will lead the mobilization of all, or part of, the support equipment for these situations. Furthermore, E-Power will have the following emergency brigades, which will receive specific training according to their function: Fire Brigades, Communications Brigade, Spills Brigade, Evacuation Brigade, Rescue Brigade, and First Aid Brigade.

E-power will implement several safety controls, to assure appropriate emergency control, preparedness, and response. These include (i) Ground wires, which will assure that efficient grounding system will be constructed to connect all equipments that can generate static electricity such as storage tanks, pumps, compressors, centrifuges, among others; (ii) Fire Detection and Suppression System, which will be operated by photo electrical detectors (smoke and heat) and ultraviolet detectors inside the power house; and (iii) Spills Detection System will be implemented to be able to detect oil spills in the control room and pipelines pressure will be surveyed.

Community Health, Safety and Security: E-Power will make sure to involve communities in its influence area in the emergency readiness and response plan, and also will include - as much as possible - the fuel storage/supplier company. E-power agreed to consider involving other companies with same supplier (e.g. Shell) and perhaps start efforts to promote initiatives such as UNEP's Awareness and Preparedness for Emergencies at Local Level (APELL - http://www.unep.fr/scp/sp/) which coordinates local government agencies, communities, local fire-fighters, and other private companies in the area to better respond to emergencies. As part of this process, emergency response drills will be conducted periodically.

Security Forces: It is important to note that the area near the plant (Cite Soleil) is an area with a history of violence. As part of ESMP, E-power has prepared a Personnel and Physical Security Plan which specifically articulates compliance with IFC’s PS4 requirements. This Plan includes measures to assure that security personnel will act in manner consistent with the company’s principles of conduct, including proportionality and appropriate conduct toward workers and the local community, and require them to act within the applicable law. Furthermore, it includes steps to prevent, avoid, and dissuade, before the use of security forces, and assures coordination with official security forces such as the police or the army that will protect basic HHRR in cases of social upheavals or violence.

Client's community engagement

As outlined above, E-Power specifically has a Social Management Plan, which articulates the strategy to assure adequate community information and engagement, and has the purpose of (i) establishing cooperative relationships with local authorities to avoid conflicts with nearby communities that could affect the normal development of the company’s activities, (ii) supporting, as much as possible, SRI initiatives in the areas of health, education, and employment, (iii) promoting fair treatment, non-discrimination, and equal opportunity of employees, and (iv) assuring compliance with national labor and employment laws. This plan includes the Information and Citizen Participation Project, which has the purpose of assuring constant communication with authorities and local communities about the impacts, risks, benefits, and generalities of the project and its SEMP, as to assure they obtain clear and sufficient knowledge of the project, and foster a relationship of mutual trust and respect between the company, contractor’s, and the community.

The communication and information between the company and the community will be dealt, when possible, through the Community Assembly’s mediation. For this purpose, E-Power will assign a person responsible for Community Relations who will maintain a space of dialogue with local authorities and community leaders to receive and respond their proposals or observations. This person will be the link between the company and the community. Information will be transmitted to the community only through the person responsible for Community Relations or through meetings organized by him/her to avoid rumors or the circulation of false information.

Additionally, E-Power will prepare and implement an Operations Personnel’s Behavior Guidelines, which will define the procedures employees must follow when interacting with the local community. These guidelines will be known by all employees as well as the community.

Local access of project documentation

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